### Revision to the



# New Hampshire State Implementation Plan

Request for Redesignation of the Boston-Manchester-Portsmouth ( SE), NH 8-Hour Ozone (1997 Standard) Nonattainment Area

Submitted March 2, 2012

Amended September 21, 2012



# Air Resources Division

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### TABLE OF CONTENTS

1. INTRODUCTION
1.1 Original Designation of Ozone Nonattainment A reas.............

........................ ............. ..1
1.2 Description of the Southeast New Hampshire No nattainment Area.................................. .4
1.3 Status of Air Quality........................................................................

................ ..4

2. ATTAINMENT OF THE STANDARD............................................................ ............ 5
2.1 Ozone Monitoring Network............................................................... ...................5
2.2 Summary of Ozone Monitoring Data.......................................

.............................. .6
2.2.1 Annual Fourth-Highest Ozone Values...........................

................................. ..6
2.2.2 Ozone Design Values.................................... ..............................................6
2.2.3 Threshold Analysis........................................................................... ..........8

2.2.4 Ozone-Related Parameters......................................................... ...................9
2.2.4.1 Oxides of Nitrogen (NOx)................................................... ...................9
2.2.4.2 Volatile Organic Compounds (VOC)........................... ............................10
2.3 Summary of Meteorological Analyses.................................

................................. ..12
2.3.1 Temperature vs. Ozone......... ......................................................................13
2.3.2 Wind Direction Frequency.........................................................

... ...............13

3. STATE IMPLEMENTATION PLAN FOR NONATTAINMENT AR EA.................................15

3.1 Recent SIP Revisions........................................................................... .............15
3.2 Reasonably Available Control Technology Requi rements.............................................16

3.3 1-Hour Ozone Attainment Demonstration........................ ....................................... 16
3.4 Reasonable Further Progress Requirements...............

...... ..........................................17

3.5 Clean Data Rule for 8-Hour Ozone Attainment...... ....................................................17

4. PERMANENT AND ENFORCEABLE EMISSION REDUCTIONS... ...................................18
4.1 Emission Control Programs............................................................ .....................18
4.2 Upwind Emission Reductions.........................................................

..................... 23

4.3 In-State Emission Reductions................................................... ...........................25

5. COMPLIANCE WITH SECTION 110 AND PART D OF THE CLEAN AIR ACT.....................27
5.1 Requirements of Section 110(a)(2)....................................

.................................... 28
5.1.1 Emission Reporting and Recordkeeping........................ ....................................29
5.1.2 Periodic Testing and Inspection.................................

... ..................................29
5.1.3 Transportation-Related Control Measures......... .................................................29
5.1.4 Continuous Monitoring and Recording of Emi ssions............................................. 29
5.1.5 Legal Authority and Emergency Powers..................

.......................................... 29
5.2 Continuance of Existing Control Requirements after Redesignation................................. 30
5.3 Permitting of Stationary Sources....................................... ....................................32
5.4 Monitoring of Stationary Sources....................................... ...................................32
5.5 Transportation Conformity............................................................

..................... .33
5.6 Vapor Recovery: Stage II and Onboard Refuelin g......

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### 5.7 Resource Commitments........................................................................... ..........35

5.8 Future Revisions to the Plan................................................... .............................35

6. MAINTENANCE PLAN...................................................................................... ...36 6.1 Attainment Inventory........................................................................... .............36

6.2 Maintenance Demonstration............................................. ...................................37 6.2.1 Projected 2012 and 2022 Emissions Inventory

........................... ........................ 38 6.2.2 Air Quality Modeling.....................................................................

...... ......39 6.2.2.1 EPA Modeling Analysis for the Nonroad Lan d-Based Diesel Engines Standards......... 39 6.2.2.2 EPA Modeling Analysis for the CAIR Rulema king.........................................40 6.3 Air Quality Monitoring Network............................................. ..............................41

6.4 Verification of Continued Attainment.................. ...................................................41 6.5 Contingency Plan......... ....................................................................................41 6.5.1 ICI Boilers (at Major Point Sources)..................... ............................................43 6.5.2 Emulsified Asphalt Paving...................................................... ......................43

6.5.3 Consumer Products...............

...... ............................................................... 43

6.5.4 Additional Controls on Boilers....................................... ................................43 6.5.5 Other Contingency Measures................................................... ......................44

7. ADMINISTRATIVE DOCUMENTS............................................................ ...............45

8. SUMMARY AND CONCLUSIONS............................................. ..............................46

LIST OF FIGURES

Figure 1-1 Map of New Hampshire’s Former 1-Hour Ozo ne Nonattainment Areas..................... .2 Figure 1-2 Map of New Hampshire’s Attainment Status for 1997 8-Hour Ozone NAAQS............ ..3 Figure 2-1 Ozone-Related Air Quality Monitors in Ne w Hampshire....................................... .5 Figure 2-2 8-Hour Ozone Trends in the Southeast New Hampshire Nonattainment Area,

1990-2011..............................................................................................7 Figure 2-3 8-Hour Ozone Trends in New Hampshire Att ainment Areas, 1990-2011..................... 7 Figure 2-4 8-Hour Ozone Design Value Trends in the Southeast New Hampshire

Nonattainment Area, 1990-2011.................................................................. ...8 Figure 2-5 NOx Trends in New Hampshire, 1998-2010...... .................................................9 Figure 2-6 NOx Trends in Maine, 1998-2010.............................. .......................................9 Figure 2-7 NOx Trends in Massachusetts, 1998-2010......

................................................ ...10 Figure 2-8 Ozone-Season Average NOx Concentrations in the Ozone Transport Region,

1998-2010..................

........................................................................... 10 Figure 2-9 TNMOC and PAMHC Trends in New Hampshire, Maine, and Massachusetts,

1998-2010............................................................................................. .11 Figure 2-10 Average TNMOC and PAMHC in Nashua, New Hampshire, 2006-2010.....................11 Figure 2-11 Average TNMOC and PAMHC on Pack Monadno ck in Peterborough,

New Hampshire, 2006-2010.........................................................................11 Figure 2-12 Number of Days with Exceedances of the 1997 8-Hour Ozone Standard in

New Hampshire, 1985-2011.........

..................... ........................................... 12Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page iii



### Figure 2-13 Number of Days with Maximum Temperature s above 85 F and Number of Days

with Ozone Exceedances in New Hampshire, 1985-2011...

..................... ...... ........13 Figure 2-14 New Hampshire Wind Direction Frequencie s in the Months of April through

September, 1995-2010...............................................................................14
Figure 4-1 Ozone-Season NO X 

### Emissions from All NOx Budget Trading Program Sourc es............24 Figure 4-2 Ozone-Season NOx and VOC Emissions in th e Eastern United States by

Source Category: 1997, 2002 and 2004............................................. ...............25
Figure 4-3 Ozone-Season Daily NOx Emissions in New Hampshire by Source Category:

2002, 2005, and 2008.................................................................................26
Figure 4-4 Ozone-Season Daily VOC Emissions in New Hampshire by Source Category:

2002, 2005, and 2008.............................................................................. ...26

LIST OF TABLES

Table 1-1 New Hampshire Designations/Classification s for 8-Hour Ozone Standard:

Nonattainment Areas, Effective June 15, 2004..................

.................................... ...4 Table 2-1 8-Hour Ozone Monitoring Data: 2012 Thresh old Values and 2010-2011 Design Values

Based on Fourth-Highest Annual Maxima (ppb)...................... ..............................8 Table 4-1 Federal Emission Control Programs for NOx and VOC in the Southeast New Hampshire

Nonattainment Area.........

......................................................................... ...19 Table 4-2 State Emission Control Regulations for NO x and VOC in the Southeast New Hampshire

Nonattainment Area......

.............................. .............................................. ...20

Table 4-3 NOx and VOC RACT Orders Issued in New Ham pshire, 2001-Present..................... ...23 Table 4-4 NOx and VOC Emissions in New Hampshire, 2 002, 2005, and 2008 (tons/year)............ .26 Table 5-1 2008 and 2022 Motor Vehicle Emission Budg ets for the Southeast New Hampshire

Nonattainment Area (tons per summer day)........................... ........................................34

Table 6-1 2008 vs. 2012 and 2022 NOx and VOC Emissions in the Southeast New Hampshire

Nonattainment Area (pounds per day)..............................................

................... .38 Table 6-2 Summary of CAIR Modeling Results for Ozon e Levels in New Hampshire (ppb)............ ..40

Table 6-3 Estimated Emission Reductions from Three BOTW Control Measures............... .........43 Table 6-4 Potential Contingency Measures for Redu cing Ozone Levels

......... ....................................45

LIST OF ATTACHMENTS

ATTACHMENT A Technical Support Document for Redesig nation of the Boston-ManchesterPortsmouth (SE), NH 8-Hour Ozone (1997 Standard) No nattainment Area

ATTACHMENT B 8-Hour Ozone Data ATTACHMENT C Chemical Analyses
ATTACHMENT D Meteorological Analyses

ATTACHMENT E Administrative Documents
ATTACHMENT F MOVES Input/Output Files for 2008 and 2022 Motor Vehicle Emissions Budgets

ATTACHMENT G Documentation for 2008 Emissions Inven tory ATTACHMENT H Projected 2012 and 2022 Emissions Inve ntoriesRequest for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page iv



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### 1. INTRODUCTION

The New Hampshire Department of Environmental Servi ces (NHDES) presents this report as documentation for its request to the Environmental Protection Agency (EPA) to redesignate the Boston-Manchester-Portsmouth (SE), NH ozone nonatta inment area to attainment of the 8-hour ozone standard of 0.08 parts per million (ppm) prom ulgated in 1997. Ground-level ozone monitoring data from 2002-2011 show these New Hamps hire counties are now in attainment for this

standard.

Section 107(d)(3)(E) of the Clean Air Act (CAA) est ablishes that, for an area to be redesignated, several determinations and approvals from the EPA A dministrator are required. EPA provided guidance on redesignation in the General Preamble f or the Implementation of Title I of the CAA Amendments of 1990, on April 16, 1992 (57 FR 13498) , and supplemented this guidance on April 28, 1992 (57 FR 18070). EPA has provided further g uidance on processing redesignation requests in subsequent memoranda. The following lists the d eterminations and approvals required from the

EPA Administrator:

• 

### A determination that the area has attained the 8-ho ur ozone standard,

• 

### Approval of a State Implementation Plan (SIP) for t he area under Section 110(k) of the Clean Air Act,

• 

### A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementati on of the SIP and other federal requirements,

• 

### Approval of a maintenance plan under Section 175A o f the Clean Air Act, and

• 

### A determination that the state has met all Title I, Part A, Section 110, and Part D requirements

for the area.

Each of these requirements is addressed within the main body of this submittal. In addition, a technical support document is provided in Attachmen t A. The technical support document is presented in two sections. The first provides a co nceptual description of the nature of ozone formation and transport in the Northeast. The seco nd describes a photochemical air quality modeling assessment that was undertaken in 2007 by New Hampshire and other Ozone Transport Region states. The results of this modeling assess ment were used by states for attainment demonstrations and other SIP planning purposes. Th ey are offered for review in the technical support document because they support the conclusio ns of this redesignation request.

NHDES is also submitting as part of this redesignat ion request a 2022 motor vehicle emissions budget (MVEB) for the area. The MVEB will be used to assure that emissions from on-road mobile

sources do not exceed levels consistent with mainte nance of the 1997 8-hour ozone standard.

1.1 Original Designation of Ozone Nonattainment A reas

Under the 1990 Clean Air Act Amendments, all or por tions of five counties in New Hampshire were designated as nonattainment areas for the former 1- hour National Ambient Air Quality Standard (NAAQS) of 0.12 parts per million (ppm) for ground- level ozone (see Code of Federal Regulations 40 CFR 81.330):

• 

### All of Strafford County and large portions of Hills borough and Rockingham Counties were designated as “serious” nonattainment areas;Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 2

• 

### The remaining portions of Hillsborough and Rockingh am counties plus all of Merrimack County were designated as “marginal” nonattainment areas; and

• 

### All of Cheshire County was designated as a nonattai nment area with incomplete data.

These former 1-hour ozone nonattainment areas are s hown in Figure 1-1.

Figure 1-1 . Map of New Hampshire’s Former 1-Hour Ozone Nonattainment Areas



# STATE OF NEW HAMPSHIRE

1-Hour Ozone
Nonattainment Areas

Seacoast Serious Area

Southern Serious Area

Marginal Area

Nonattainment/ Incomplete Data

Attainment or
Unclassifiable
Areas

Pelham Hudson

Nashua Hollis Brookline Mason New Ipswich Rindge Windham

Salem Atkinson Newton South Hampton Seabrook

Hampton North Hampton Rye Ports mouth New Castle

Hampstead Derry San

down Dan Ville Kings

ton East Kings
ton Kens ington Hamp

ton Falls Exeter Strat
ham Brent Wood Fremont Epping Newmarket

Newfields Green

land Newing

ton Durham Madbury Dover Rollingsford Sommersworth Rochester

Barrington Milton

Farmington

Strafford

Nottingham Lee Northwood

Deerfield

Raymond Candia

Auburn

Chester

London Derry Manchester Hookset Concord

Allens

town Bow Pembroke Hopkinton

Weare

Goffstown

Bedford

Amherst Merrimack

Litchfield New Boston

Lynde borough Mt.

Vernon

Milford Wilton

Temple Dunbarton

Fitzwilliam Richmound Winchester Hinsdale Chesterfield West moreland Keene

Swanzey

Troy Jaffrey

Dublin Marl borough Roxbury Harrisville

Peter borough

Sharon Greenland Frances

town Hannock Benning

ton Deering Antrim Stoddard

Nelson Sullivan Gilsum

Surry Walpole Acworth Lempster

Langdon Charles

town

Alstead Marlow Washington Hillsborough Henniker Bradford Warner Newbury Goshen Unity Claremont Cornish Plantfield Lebanon Hanover

Enfield

Enfield

Grantham

Croydon

Newport Sunapee

Springfield Grafton Orange

Danbury Alexandria

Wilmot

New London

Sutton Salibury

Andover Hill Bristol Hebron
Bridge

water New Hampton Meredith

Sanbornton

Franklin

Northfield

Webster Canterbury

Loudon

Epsom Pittsfield Gilmanton Belmont Tilton Laconia

Gilford

Alton

Barnstead New

Durham Brook
field

Middle

town Wakefield Wolfboro Moulton borough

Tuftonboro Ossipee Lyme Orford Piermont Haverhill Bath

Warren

Benton

Wentworth

Dorchester

Groton

Rumney Ellsworth Woodstock Lincoln Easton Landaff Monroe Lyman

Lisbon Sugar
Hill Franconia

Bethlehem Littleton

Carroll

Livermore

Waterville Valley

Thornton

Campton

Plymouth Holderness

Ashland Sandwich

Hebron Albany

Tamworth

Freedom

Effingham Conway

Madison Eaton Hebron Jackson

Chatham Beans Purchase Sargents
Purchase Crawfords
Purchase Low&Burbanks Grant

Beans Grant Martins Loc.

Greens Grant

Pinkhams Grant

Hales
Location Dalton Whitefield Jefferson

Lancaster North Umberland

Kilkenny

Randolph Berlin

Gorham Shelburne

Sucess Milan Stark Stratford Columbia Colebrook Stewartstown

Dixville

Millsfield

Odell

Dummer Cambridge Errol Wentworths Location Second College Grant Dixs
Grant Atkinson & Gilmanton Academy Grant Clarksville Pittburg

Ervings
Location



### On July 18, 1997, EPA promulgated a new 8-hour ozon e standard to replace the 1-hour standard for ground-level ozone (62 FR 38855). The 8-hour ozone NAAQS, which was set at a level of 0.08 parts per million (ppm) and is based on an 8-hour a verage of ambient ozone concentrations, more directly relates to ozone levels associated with ad verse health effects. After the resolution of numerous legal challenges, on April 30, 2004, EPA p ublished final attainment designations (69 FR 23857) for the 1997 8-hour ozone NAAQS.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 3



### The Boston-Manchester-Portsmouth (SE), NH nonattain ment area (hereinafter referred to as the Southeast New Hampshire Nonattainment Area) was cre ated covering the southeastern-most portion of the state (see Figure 1-2). This nonattainment area, which includes portions of four counties (Hillsborough, Merrimack, Rockingham, and Strafford ), was classified as “Subpart 2/moderate”
nonattainment for the 8-hour ozone standard. 1 

### The area designations/classifications were based on 2000-2002 data and the recommendations of NHDES in a letter submitted to EPA on July 15, 2003.
The moderate nonattainment classification was selec ted to be consistent with contiguous
nonattainment areas in Massachusetts and Maine.

Figure 1-2. Map of New Hampshire’s Attainment Stat us for 1997 8-Hour Ozone NAAQS



# STATE OF NEW HAMPSHIRE

8-Hour Ozone
Nonattainment Area

Southeast New Hampshire
Moderate Area

Attainment Areas

Pe lham Huds o n

N as hua Holli s Broo k line Ma son N ew Ips wic h R ind ge W indha m

Sal em Atk inson Ne wt on So uth Ha mpton Se abrook

Hampt on North Ha mpto n Ry e Ports mo ut h Ne w C as tle

Ha mpstea d D erry San

dow n Da n
Vill e Ki ngs

t on East Kings
ton Ke ns ing ton H amp
ton
Fall s Exe te r St ra t ha m B re nt W ood Fre mont Ep pin g Ne wma rk et

Ne wfi elds G ree n

la nd N ew ing
to n Du rha m M adbury Dov er R ol lin gsford Sommers worth R oc hes te r

Ba rri ngt on M ilton

F a rmi ng t on

Straf ford

No tt ingha m Le e Nort hwo od

De erfi eld

Ra ymond Ca ndia

A ub urn

Ches te r

Lon don Derry Manc h es te r H ook se t Co nc ord

Alle n s

town Bow Pembrok e H opk in ton

Wea re

Go ff st own

B ed ford

A mhe rst M e rrima ck

Li tc hf ie ld N ew B os ton

Ly nd e bo roug h M t.

Ve rnon

Milfo rd Wil ton

Temple Dunbarto n

Fitzw ill iam R ic hmo und Winche st er Hi ns dale Che st erfi eld We st
more la nd K ee ne

Swa nzey

Troy Ja ffrey

D ub li n M arl borough R ox bury Ha rris vi lle

Pe te r borough

Sha ron Gree n land Fra nce s

tow n H an noc k Be nning

ton D ee ri ng A nt rim Stod dard

Ne ls on Sulli va n Gi lsu m

Surry Wa lpo le A cw ort h Lempst er

La ng don Ch arle s
tow n

Als te ad M arlow Wa shin gton Hi llsb orough He nni ke r Bra dfo rd Wa rne r New bury G oshen Un it y Cla re mont Cornish Plan tfie ld Lebanon Hanov er

Enfi eld

En fie ld

Gra nt ham

Croydon

N ew port Suna pe e

Springfie ld G raf to n Ora nge

Da n bury Ale xa ndria

Wi lmot

New
Londo n

Sutt on Sal ibury

A ndove r Hill Bris tol Hebron Bridge

wa te r Ne w Ha mpton M ere di th

Sanb orn ton

Fra nk lin

Northf iel d

W eb s te r Cant erb ury

L ou don

E ps o m P ittsf iel d Gil man ton Bel mont Ti lton La co nia

G ilford

Alt on

Ba rns te ad N ew

D urh am Brook fie ld

M id dl e

tow n W ak efiel d W ol fb oro M oulton borough

T uf tonboro Oss ipe e Lyme Orford Pie rmont Hav erhill Ba th

Wa rre n

Bent on

We nt worth

Dorche st er

Groto n

Ru mne y Ells wo rth Woods to ck Li nc o ln Eas ton La nda ff Monroe Ly man

Lis bon Su gar

Hi ll Fran c onia

Be thle he m Lit tle to n

Ca rroll

Live rmore

Wa te rv ill e Va lle y

T horn ton

Campt on

Pl ymo uth H ol de rne ss

As hland S andwic h

Hebron Alb an y

Ta mwo rth

Fre edom

Ef fingham Conwa y

Ma d ison Eat on H ebron Ja ck s on
C ha th a m Be ans Purc h as e Sarg en ts Purc has e Craw fords
Pu rc h as e Low&B urba nk s G ra nt

Bea ns Gran t Ma rtins Loc .

Gre ens Gran t

Pi nk hams
G ra nt

Ha les Loc a tion Da lto n Wh it efiel d Je ff ers on

La n ca st er N ort h U mbe rland

K ilk en ny

R an dolp h B erlin

Gorham Shel burne

S uc es s Mi lan Sta rk Stra tf ord C ol umb ia C ol ebrook St ew arts tow n

D ixv ille

Mill sf iel d

O de ll

Dummer Ca mbri dge

Errol We nt wo rths
Loc at ion Sec ond Colle ge Grant Dix s Grant Atk inson & Gil manton Aca demy Gra nt C lark sv ille Pit tbu rg

Ervings
L oc a tion

1 Subpart 2 refers to Subpart 2–Additional Provisions for Ozone Nonattainment Areas of Title I, Part D o f the Clean Air Act, which supplements, and is more prescriptive th an, the general requirements for nonattainment area s found in Subpart 1.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 4



### 1.2 Description of the Southeast New Hampshire No nattainment Area

The Southeast New Hampshire Nonattainment Area incl udes 52 cities and towns in Hillsborough, Merrimack, Rockingham, and Strafford Counties (Tabl e 1-1). According to the 2010 census, these communities have a total population of 729,071. Ma nchester is the largest municipality in the area with a population of 109,565, followed in order by Nashua, 86,494; Derry, 33,109; Dover, 29,987; Rochester, 29,752; Salem, 28,776; and Merrimack, 25 ,494.

Table 1-1. New Hampshire Designations/Classificati ons for 8-Hour Ozone Standard:

Nonattainment Areas, Effective June 15, 2004 (FR 69 23857)

Area County Cities and Towns Included Designation/
Classification

Hillsborough (part) Amherst, Bedford, Brookline, Goffstown, Hollis, Hud son,

Litchfield, Manchester, Merrimack, Milford, Nashua, Pelham Nonattainment Subpart 2/Moderate

Merrimack (part) Hooksett Nonattainment Subpart 2/Moderate

Rockingham (part) Atkinson, Auburn, Brentwood, Cand ia, Chester, Danville,

Derry, E. Kingston, Epping, Exeter, Fremont, Greenl and, Hampstead, Hampton, Hampton Falls, Kensington, Kingston, Londonderry, New Castle, Newfields, Newin gton, Newmarket, Newton, North Hampton, Plaistow, Portsmouth, Raymond, Rye, Salem, Sandown, Seabrook, South Hampton, Stratham, Windham Nonattainment Subpart 2/ModerateBoston-ManchesterPortsmouth Area (Southeast New Hampshire Area)

Strafford (part) Dover, Durham, Rochester, Rollinsf ord, and Somersworth Nonattainment Subpart 2/Moderate



### 1.3 Status of Air Quality

Ground-level ozone monitoring data for each three-c onsecutive-year monitoring period from 2002 to 2011 show that air quality in the Southeast New Hampshire Nonattainment Area has met the 1997 NAAQS for 8-hour ozone. (EPA reached the same conclusion after examining data for the 2007-2009 monitoring period; see next section). Th is fact, accompanied by documented decreases in ozone-precursor pollutant emissions from in-stat e and upwind sources, is the basis for requesting redesignation of the nonattainment area to attainme nt for the 1997 8-hour ozone standard, in accordance with Section 107(d)(3)(E) of the Clean A ir Act.

Air quality data summaries describing improvements in local ambient ozone concentrations are included in the next section, 2. ATTAINMENT OF THE STANDARD 

### . Emission reductions contributing to the improved ozone levels are described in 4. PERMANENT AND ENFORCEABLE EMISSION

REDUCTIONS



### .Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 5



### 2. ATTAINMENT OF THE STANDARD

The determination of New Hampshire’s 1997 8-hour oz one attainment status is based on extensive analysis of real-time ozone and photochemical data collected from monitoring stations installed and maintained by NHDES at strategic locations across t he state. Using quality-assured, certified data for the monitoring period 2007-2009, EPA determined that air quality in the Southeast New Hampshire Nonattainment Area (moderate) had attaine d the 1997 8-hour ozone NAAQS (76 FR 14805, March 18, 2011). This determination is cons istent with EPA’s Clean Data Rule (40 CFR 51.918); see 3.5 Clean Data Rule for 8-Hour Ozone Attainment . [In a separate but related action, EPA issued a proposed rule determining that the Bos ton-Lawrence-Worcester MA-NH serious onehour ozone nonattainment area met the November 15, 2007, deadline for attaining the one-hour NAAQS for ozone, based on quality-assured, certifie d data for the 2005-2007 monitoring period (76 FR 77739, December 14, 2011).]

2.1 Ozone Monitoring Network

New Hampshire’s current ozone monitoring network ha s a total of 14 sites, located as shown in Figure 2-1. Eleven of these ozone monitors are ope rated by NHDES and three are operated by partner agencies. Included in the ozone monitoring network are three ozone-related monitors that measure for oxides of nitrogen (NOx) and two sites that measure for Photochemical Assessment Monitoring Stations (PAMS) pollutants.

Figure 2-1. Ozone-Related Air Quality Monitors in New Hampshire

Keene

Nashua

Concord

Odiorne
State Park Portsmouth Laconia Camp Dodge

Lebanon

Isles Of Shoals Durham Mt. Washington (Summit)

Miller
State Park (NCore) 

# State of New Hampshire

Ozone Related Monitor Network

2011

Ozone

PAMs NOx/NOy

Ozone Monitors Operated by the University of New Ha mpshire DES Monitor Key

Ozone Monitors Operated by the Hubbard Brook Resear ch Foundation Hubbard Brook

Londonderry

(NCore)Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 6



### All 11 NHDES stations operate throughout the ozone season from April 1 through September 30. Four of the ozone monitors – those at Londonderry, Nashua, Portsmouth, and Rye (Odiorne) – are located within the Southeast New Hampshire Nonattai nment Area. Although the Portsmouth and Rye monitors are only a few miles apart, they repre sent different airsheds: continental population (Portsmouth), and coastal-oceanic (Rye). Also situ ated within the nonattainment area are two NOx monitors (Nashua and Londonderry) and one PAMS inst allation (Nashua).

2.2 Summary of Ozone Monitoring Data

Real-time ozone data collected from the monitoring network are used in a variety of analyses to determine whether monitored areas are meeting the 1 997 NAAQS for 8-hour ozone. The following definitions are instrumental to assessing attainmen t status:

• 

### Annual fourth-highest value : the fourth-highest 8-hour ozone concentration for a given

ozone season at a monitored location.

• 

### Design value : the 3-year average of the annual fourth-highest 8-hour ozone concentration at

a monitored location.

• 

### Threshold value : the fourth-highest monitored 8-hour ozone concen tration for a given ozone season that would cause that year’s design value at a monitored location to exceed the 8-hour ozone NAAQS.

A description of 8-hour ozone data handling convent ions is provided in Attachment B; also included is a table of the annual fourth-highest values, ann ual design values, and 2012 threshold values for each of the Manchester, Nashua, Portsmouth, and Rye monitor sites. Ozone concentrations at these locations represent ozone levels for the entire Sou theast New Hampshire Nonattainment Area.

2.2.1 Annual Fourth-Highest Ozone Values

Figure 2-2 displays annual fourth-highest 8-hour oz one values in parts per billion (ppb) since 1990 for monitoring locations in the nonattainment regio n. (In addition to ozone values for the four named locations, the chart includes values for moni tor sites in Brentwood and Rochester that operated for shorter periods). Figure 2-3 shows co rresponding values for ozone monitors in the remainder of the state. While meteorological condi tions contribute to yearly variations, it is clear

that ambient ozone concentrations in both attainmen t and nonattainment areas are trending downward. It is important to note that all ozone d ata through September 30, 2011, have passed all quality assurance requirements and have been entere d into EPA’s Air Quality System (AQS)

database.

2.2.2 Ozone Design Values

Trends in the 8-hour ozone design values for monito ring locations in the Southeast New Hampshire Nonattainment Area are illustrated in Figure 2-4. As the graph shows, design values have been declining since 1990, and all stations have demonst rated attainment since 2003; i.e., design values for the four Southeast New Hampshire Nonattainment Area monitors have remained below the level of the 8-hour NAAQS during each of the periods 2002 -2004, 2003-2005, 2004-2006, 2005-2007, 2006-2008, 2007-2009, 2008-2010, and 2009-2011. (T here are some gaps in the data plots due to relocation of monitor sites.) To be valid, design values require three years of quality-assured data collected at the same location. Based on quality-a ssured data through the 2011 ozone season, 8-hour ozone design values for the period 2009-2011 were n o greater than 70 ppb at all locations, with mostRequest for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 7



### sites in the southern part of the state displaying values in the low- to mid-60’s ppb range. See

Attachment B for a technical discussion of data han dling conventions and design value calculations.

Figure 2-2. 8-Hour Ozone Trends in the Southeast N ew Hampshire Nonattainment Area,

1990-2011

Ozone Trends in New Hampshire's Nonattainment Area (Annual 8-Hour Ozone 4th High Values)

40 50 60 70 80 90 100 110 120

1 99 0

1 99 1

1 99 2

1 99 3

1 99 4

1 99 5

1 99 6 1997 1998 1999 2000 2001 2002 2003 2 0 04 2 00 5 2 00 6 2 00 7 2 00 8 2 00 9 2 01 0 2 01 1

YearConcentration (PPB)

Brentwood

Manchester

Nashua

Rochester
Rye

Portsmouth

1997 NAAQS



### Figure 2-3. 8-Hour Ozone Trends in New Hampshire A ttainment Areas, 1990-2011

Ozone Trends in Attainment Areas of New Hampshire (Annual 8-Hour Ozone 4th High Values)

40 50 60 70 80 90 100 110 120

1 9 90 1991 1992 19 9 3 19 9 4 1995 1996 1997 1998

1 9 9 9 2 0 0 0 2001 2002 2003 2004 2 0 0 5 2 0 0 6 2007 2008 2009 2010 2011

YearConcentration (PPB) Camp Dodge

Claremont

Concord
Conway

Haverhill

Keene

Laconia

Lebanon
Pittsburg

1997 NAAQSRequest for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 8



### Figure 2-4. 8-Hour Ozone Design Value Trends in th e Southeast New Hampshire Nonattainment Area, 1990-2011

Ozone Trends in New Hampshire's Nonattainment Area

(Annual 8-Hour Ozone Design Values)

40 50 60 70 80 90 100 110 120

1990

1 99 1 1992 1993

1 99 4 1995 1996

1 99 7 1998

1 9 99 2 00 0 2001 2 00 2 2003 2004 2 00 5 2006 2007 2 00 8 2 00 9 2010 2 01 1

YearConcentration (PPB)

Brentwood

Manchester

Nashua

Rochester
Rye

Portsmouth

1997 NAAQS



### 2.2.3 Threshold Analysis

The threshold analysis presented in Table 2-1, base d on supporting data in Table B-1 of Attachment B, further demonstrates that the Southeast New Hamp shire Nonattainment Area is likely to remain in attainment once redesignated. While two of the four monitor sites represented in the table have had at least one value over the threshold, this val ue would not influence the design value unless it accounted for the season’s fourth-highest concentra tion. In fact, not one of these sites has had a fourth-highest value above its 2012 threshold at an y time in its monitoring history. Therefore, it is highly probable that the Southeast New Hampshire No nattainment Area will continue to achieve attainment. This prospect is supported by the prev ious introduction of large-scale emission control

measures that have reduced NOx emissions across the region – particularly the NOx SIP call and the phase-in of mobile source controls.

Table 2-1. 8-Hour Ozone Monitoring Data: 2012 Thre shold Values and 2010-2011 Design

Values Based on Fourth-Highest Annual Maxima (ppb)

4 th Highest Value Design Value * Most Recent Year at

or above Threshold Monitor
Location AQS

Number 2008 2009 2010 2011 2010 2011 2012

Threshold

Value ** 1 st

Highest 4 th

Highest



### Manchester 330110020 64 60 63 *** 

### 62 *** *** 

### None None

Nashua 330111011 67 66 67 65 66 66 123 None None

Portsmouth 330150014 69 70 66 64 68 66 125 1988 Non e Rye 330150016 75 68 66 66 69 66 123 1991 None

* Example: The 2010 design value is the 3-year average of the annual fourth-highest 8-h our ozone concentration for the period 2008-2010.

** The 2012 threshold value is the fourth-highest m onitored daily maximum 8-hour ozone value during th e 2012 ozone season that would cause the 2012 design value to exceed the 8-hour oz one NAAQS.

*** No data; monitor was moved to Londonderry in 20 11.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 9



### 2.2.4 Ozone-Related Parameters

The PAMS stations are set up to monitor ozone, NOx, speciated volatile organic compounds (VOC, mainly hydrocarbons and carbonyl compounds), and me teorological parameters. New Hampshire’s current PAMS monitors are located in Nashua (Gilson Road) and on the summit of Pack Monadnock Mountain (Miller State Park), in Peterborough. For its investigation of ozone trends in the Southeast New Hampshire Nonattainment Area and surrounding re gion, NHDES analyzed data from the two PAMS sites in New Hampshire and nine PAMS sites in Maine and Massachusetts. The analyses confirm that the many efforts to control NOx and VO C emissions in recent years have resulted in

lower ambient concentrations of NOx and TNMOC durin g the ozone season. Background information, descriptions of the analyses performed , and graphs of the chemical data are presented in Attachment C. The meteorological portion of the analyses is included in Attachment D.

2.2.4.1 Oxides of Nitrogen (NOx)

Figures 2.5 through 2.7 depict average NOx concentr ations in New Hampshire, Maine, and Massachusetts during the PAMS reporting season of J une 1 to September 30 for the period 1998- 2010. Because of monitor site changes in New Hamps hire, there are only a few years of data for each PAMS location in the state. Nevertheless, ave rage NOx concentrations at each of the New Hampshire sites either decreased or held nearly con stant over the respective measurement period. The more complete data sets from PAMS sites in Main e and Massachusetts demonstrate a clear decline in NOx concentrations over the last decade, indicative of a regional downward trend in the

Northeast.

Figure 2-5. NOx Trends in New Hampshire, 1998-2010

Figure 2-6. NOx Trends in Maine, 1998-2010Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 10



### Figure 2-7. NOx Trends in Massachusetts, 1998-2010

The observed decline in NOx concentrations in the t hree-state area is reflective of the general trend across the Ozone Transport Region (OTR) 2 

### . Since 1998, ozone-season average NOx levels in t he OTR have fallen steadily by more than 40 percent (F igure 2-8).

Figure 2-8. Ozone-Season Average NOx Concentration s in the Ozone Transport Region, 1998-2010

0 5 10 15 20 25

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 201 0

YearConcentration (PPB)



### 2.2.4.2 Volatile Organic Compounds (VOC)

Figure 2-9 exhibits seasonal averages of total nonm ethane organic carbon (TNMOC) and total PAMS-measured hydrocarbons (PAMHC) for the combined data sets of New Hampshire, Maine, and Massachusetts. Both categories of VOCs have de creased in concentration significantly since 1998. In particular, despite year-to-year variatio ns, average concentrations since 2003 have been consistently lower than those in the five preceding years: the average PAMHC concentration was 18 ppbC in 2003-2009 versus 28 ppbC in 1998-2002.

2 The OTR consists of eleven states in the northeast ern U.S. plus the District of Columbia.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 11



### Figure 2-9. TNMOC and PAMHC Trends in New Hampshir e,

Maine, and Massachusetts, 1998-2010

0 5 10 15 20 25 30 35 40 45 50

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 201 0Concentration (PPBC)

TNMOC

PAMHC



### The most recent VOC data from New Hampshire’s PAMS sites (Nashua and Pack Monadnock) are graphed in Figures 2-10 and 2-11. For the period f rom 2006 to 2010, TNMOC and PAMHC seasonal average concentrations at both sites were relatively stable. The seasonal averages at Pack

Monadnock reached their lowest values in 2010.

Figure 2-10. Average TNMOC and PAMHC in Nashua, Ne w Hampshire, 2006-2010

TNMOC and PAMHC Seasonal Averages

Gilson Road, Nashua

0 5 10 15 20 25 30 35

2006 2007 2008 2009 2010Concentration (PPBC)

TNMOC

PAMHC



### Figure 2-11. Average TNMOC and PAMHC on Pack Monad nock in

Peterborough, New Hampshire, 2006-2010

TNMOC and PAMHC Seasonal Averages Pack Monadnock Summit, Peterborough

0 10 20 30 40 50 60

2006 2007 2008 2009 2010Concentration (PPBC)

TNMOC

PAMHC Note: 2010 data were not

yet available for all states as of this publication.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 12



### For Nashua, the 2009 seasonal averages were higher than in 2006-2008; but this phenomenon was due to contamination by local emissions. Extensive paving near the Nashua monitoring site began on July 16, 2009, and continued during the rest of the summer. This activity caused elevated values of certain unknown hydrocarbons as well as those on the target list, including 1,2,3- Trimethlybenzene and 1,2,4-Trimethylbenzene, throug h the end of the PAMS season in September. This local influence resulted in higher averages of PAMHC and TNMOC for the entire 2009 season. PAMHC and TNMOC dropped to more historically consis tent levels in 2010. In fact, the 2010 seasonal averages are lower than those of any prece ding year.

Conclusion: Given the relatively stable or declinin g pattern in recorded ozone and ozone-precursor levels at New Hampshire monitors over the last 5 to 6 years, and observed longer-term regional decreases in both NOx and VOC emissions (see 4. PERMANENT AND ENFORCEABLE EMISSION

REDUCTIONS 

### ), it is expected that ozone concentrations in New Hampshire will remain at

attainment levels in the future.

2.3 Summary of Meteorological Analyses

Meteorology is a major factor in the formation and transport of ozone and its precursors. High ozone concentrations in southern New Hampshire occu r most often when low-pressure systems approach from the Great Lakes or southern Canada wh ile high pressure is situated just off the eastern seaboard. When such a scenario is in place , it provides warm temperatures, clear skies, and southwesterly winds to allow the transport of ozone and its precursors into the Northeast.

Upwind states have successfully begun to address th e problem of regional transport and made it possible for New Hampshire to reach attainment of t he 8-hour ozone standard. This fact is reflected by the recent decline in the number of days, year t o year, in which New Hampshire’s ozone levels have exceeded the NAAQS (see Figure 2-12).

Figure 2-12. Number of Days with Exceedances of th e 1997 8-Hour Ozone Standard in New Hampshire, 1985-2011

8 9 13 27

11
9 13

8 8 9 9

6 10

7 10

1 11 13

1 5 4
2 8

2
0 0 1

0 5 10 15 20 25 30

198 5 19 86 19 87

1 988 19 89

1 990

1 991 1992

1 993 1994 1995 1996 1997 199 8 19 99 200 0 2 001 20 02 2 003 20 04 2 005 2 006 2007 2 008 2009 2010 201 1

YearNumber of Days



### As required by EPA guidance for the redesignation p rocess, New Hampshire must show evidence that

unusual weather conditions would not have been the essential cause of the area’s newly acquired attainment status. NHDES has prepared two types of graphical analyses for this purpose – temperature vs. ozone and wind direction frequency – presented in detail as Attachment D and summarized below:Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 13



### 2.3.1 Temperature vs. Ozone

Because warm weather is a principal condition for o zone formation, hotter summers tend to experience greater frequency of ozone exceedances. Figure 2-13 contains a bar graph depicting the number of days each year between 1985 and 2011 in w hich the National Weather Service recorded a maximum daily temperature above 85 F in Concord, Ne w Hampshire. These data are sorted in ascending order by temperature (rather than by chro nological order). Summers have varied from the relatively cool summer of 1996, with 20 days having maxima above 85 F, to the very hot summer of 2010, with 63 days having maxima above 85 F.

Also included in Figure 2-13 is a blue line graph s howing the number of days with 8-hour ozone values exceeding 85 ppb. The upward-sloping trend line of exceedance days against the plotted temperature profile illustrates the expected correl ation of ozone exceedances and higher temperatures. The light blue ovals on the line graph identify dat a points for 2003-2011, a period in which the frequency of exceedances was markedly below the exp ected frequency based on temperature patterns. Note that the number of exceedances was well below the linear trend line in each year since 2003, despite some very warm summers in 2005, 2007, and 2010. In fact, 2010 had the highest number of days with a maximum temperature o ver 85 F, but no ozone exceedances. These findings indicate that the decline in ozone levels since 2003 is not solely or primarily due to a decrease in summer temperatures.

Figure 2-13. Number of Days with Maximum Temperatu res above 85 F and Number of Days

with Ozone Exceedances in New Hampshire, 1985-2011

0 10 20 30 40 50 60 70

199 6 1986 2009 20 0 8 19 9 2 2 00 0 2 00 4

1 99 7 2 00 6 198 9 1985 19 8 7 19 9 8 2 00 3

1 99 9

1 99 4 1988 1993 19 9 0 20 0 7 20 1 1 20 0 1 2 00 2

1 99 1 200 5 1995 2010Number of Days Max Temperature >85 F

Ozone Exceedances

Linear (Ozone Exceedances)

2006 2003 2007 2005

2004 2009 Notes: Temperatures are National
Weather Service data from Concord Airport.

Data are sorted by number of days with maximum temperature >85 F (therefore, years are not in chronological order). 2008 2010

2011



### 2.3.2 Wind Direction Frequency

Because transport of ozone and its precursors from outside state borders plays a critical role in elevated ozone levels in New Hampshire, another sig nificant factor to consider is wind direction.

Surface winds from the southwest are conducive to t ransport along the Northeast Corridor from metropolitan areas upwind.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 14



### Figure 2-14 presents composite wind roses for the m onths of April-September for the period from 1995 to 2010. To provide the most consistent basis for comparison, data were taken from the longterm databases of the National Weather Service for airport sites in Concord and Portsmouth, New Hampshire. The data were separated into two period s, 1995-2002 and 2003-2010, to distinguish between the wind direction patterns of the earlier period and those of the more recent period characterized by fewer exceedances. The wind roses are based on hourly wind observations for the entire summer season, without regard to ozone conce ntration.

The Concord and Portsmouth wind roses display very different, site-specific wind patterns; but for each location, the wind direction frequencies were consistent over time. While the number of exceedances was declining, the wind direction patte rns for 2003-2010 were remarkably similar to the wind direction patterns for 1995-2002. Therefo re, the observed decline in the number of ozone exceedances since 2003 is not merely a consequence of shifts in wind direction.

Figure 2-14. New Hampshire Wind Direction Frequen cies in the Months of

April through September, 1995-2010

Wind Direction Frequencies at Concord Airport

National Weather Service Data

1995-2010

1995-2002

2003-2010 N

E W

S Wind Direction Frequencies at Pease Airport, Portsm outh
National Weather Service Data

1995-2010

1995-2002

2003-2010 N

E W

S



### Conclusion : As the graphical analyses show, the reduced numbe r of ozone exceedances in recent years has occurred despite normal variations in tem perature and consistent wind direction patterns. Thus, monitored attainment of the Southeast New Ham pshire Nonattainment Area is not primarily due to unusual meteorological conditions. Should m eteorological conditions during future summers favor transport of pollutants into New Hampshire, o zone levels in the Southeast New Hampshire Nonattainment Area are not expected to exceed the N AAQS because large-scale NOx emission reductions that began with the NOx SIP Call in 2003 will continue to mitigate upwind contributions. Furthermore, the upwind source regions impacting Ne w Hampshire (i.e., southern New England and the New York metropolitan area) have higher and mor e frequent ozone exceedances than New Hampshire and are taking additional steps to contro l emissions contributing to this situation. These steps will further reduce the amounts of ozone and its precursors available for transport to New Hampshire.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 15



### 3. STATE IMPLEMENTATION PLAN FOR NONATTAINMENT AR EA

New Hampshire’s original state implementation plan (SIP) was submitted to EPA on January 27, 1972, and approved on May 31, 1972 (37 FR 10842). It has undergone many revisions since then to meet new federal requirements as they occurred. Ne w Hampshire’s approved SIP is published in the Code of Federal Regulations at 40 CFR 52 Subpar t EE.

3.1 Recent SIP Revisions

Recent revisions to New Hampshire’s state implement ation plan, all of which are effective for the Southeast New Hampshire Nonattainment Area, include the following:

• 

### RACT Certification. Pursuant to 40 CFR 51.912 and Clean Air Act Secti ons 172(c)(1), 182(b)(2), and 184(b)(1), this plan revision was su bmitted to certify reasonably available control technology (RACT) requirements. The submis sion certified that New Hampshire’s RACT regulations for the former 1-hour ozone Nation al Ambient Air Quality Standard (NAAQS), combined with all RACT orders issued by NH DES, satisfied RACT requirements under the 1997 revised 8-hour ozone NAAQS of 0.08 p pm. NHDES submitted the RACT SIP revision to EPA on January 28, 2008.

• 

### Interstate Transport Provisions. In 2005, EPA entered into a consent decree with E arth Justice that obligated EPA to determine whether sta tes had made SIP submissions to meet the requirements of the Clean Air Act, Sections 110(a)( l) and (2). On April 25, 2005, EPA published a finding that all states had failed to submit SIP revisions addressing interstate transport for

the 1997 8-hour ozone and PM 2.5 

### NAAQS (70 FR 21147). Accordingly, on March 11, 20 08,

NHDES submitted a SIP revision to EPA to fulfill th e requirements of the Finding of Failure and section 110(a)(2)(D)(i) relating to interstate transport of those pollutants.

• 

### 8-Hour Ozone Certification. The consent decree with Earth Justice also obliga ted EPA to

determine whether states had made submissions meeti ng the remaining “infrastructure” requirements of CAA Sections 110(a)(l) and (2) for 8-hour ozone and fine particulate matter. To the extent that existing SIPs already satisfied these requirements, states needed only to certify that fact to EPA. NHDES submitted New Hamp shire’s certification of adequacy for 8-hour ozone on December 14, 2007. EPA approved th is SIP revision in a final rule published on July 8, 2011 (76 FR 40248).

• 

### PM 2.5 

### Certifications. In similar fashion, NHDES submitted New Hampshire ’s certification of adequacy for the 1997 24-hour and average annual PM 2.5 

### standards on April 3, 2008. EPA published a completeness finding for this submissio n on October 22, 2008 (73 FR 62902). NHDES followed this, on September 18, 2009, with su bmittal of a certification of adequacy

for the 2006 revised 24-hour PM 2.5 

### standard.

• 

### Regional Haze Plan. In 1999, the Environmental Protection Agency (EPA ) issued regulations to improve visibility in 156 national p arks and wilderness areas (Federal Class I areas) across the United States. The Regional Haze Rule applies to any state having a federal Class I area as well as any state that contributes to visibility impairment at any (downwind) Class I area. Each state’s plan for regional haze takes the form of a SIP revision and must include reasonable progress goals for visibility im provement and a long-term strategy with enforceable emission reductions to meet those goals . On January 29, 2010, NHDES submitted New Hampshire’s regional haze plan to EPA and provided copies to the FederalRequest for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 16



### Land Managers. Following receipt of agency comment s, NHDES made adjustments to the plan, adopted Env-A 2300 Mitigation of Regional Haze, and resubmitted the package as a final SIP revision on January 14, 2011. In respons e to additional EPA comments, NHDES submitted further amendments on August 26, 2011. O n February 15, 2012, the Regional Administrator signed a proposed rule, approving the Regional Haze SIP revision.

3.2 Reasonably Available Control Technology Requi rements

For areas of New Hampshire previously designated as 1-hour serious ozone nonattainment areas, Section 182(b) and (c) of the Clean Air Act require d the state to adopt RACT rules for VOC sources covered by Control Technique Guidelines (CTGs) issu ed before and after enactment of the 1990 Clean Air Act Amendments. These sections also requ ired the state to implement RACT requirements for all other major sources of VOCs in the classifi ed nonattainment areas. Note, however, that because New Hampshire is part of the Ozone Transpor t Region, Section 184(b) requires implementation of VOC RACT for all areas of the sta te regardless of attainment classification. New Hampshire met these requirements through the adopti on of various VOC regulations and individual VOC RACT determinations for all major VOC sources n ot covered by the CTGs. New Hampshire’s VOC RACT rule, codified at Env-A 1204 Stationary Sources of Volatile Organic Compounds (VOCs) , applies to facilities in designated source catego ries that have the potential to emit as little as 10 tons/year of VOCs, depending o n the category. This rule expired in 2010 and was readopted with amendments, effective June 1, 20 11. The rule, renumbered as Chapter Env-A 1200, was amended to address the CTGs issued by EPA in 2006, 2007, and 2008 for Group II, III, and IV source categories, respectively; and the applica bility threshold for sources in those categories wa s set at 3 tons/year of actual VOC emissions, prior t o controls. The readopted rule was submitted to EPA as a SIP revision on July 26, 2011.

Section 182(f) required states to make similar prov isions for major stationary sources of NOx. Accordingly, New Hampshire established NOx RACT reg ulations covering major NOx sources in

all areas of the state and issued NOx RACT determin ations for several such sources. New Hampshire’s NOx RACT rule, codified at Env-A 1211 Nitrogen Oxides (NOx) , applies to facilities that have the potential to emit 50 tons/year of nit rogen oxides or that meet specific size thresholds based on heat input capacity or other measure. Thi s rule expired in 2010 and was amended, renamed, renumbered, and readopted as Env-A 1300 Nitrogen Oxides (NOx) Reasonably Available Control Technology (RACT) , effective October 31, 2010. The readopted rule w as submitted to EPA as a SIP revision on March 31, 2011.

3.3 1-Hour Ozone Attainment Demonstration

Section 182(c) of the Clean Air Act required any st ate with a serious nonattainment area for ozone to submit by November 15, 1994, a SIP revision demo nstrating how the state would attain the 1- hour ozone standard. Notwithstanding significant e fforts by the states, in 1995 EPA recognized that many states in the eastern half of the United State s could not meet this deadline because of ozone transport related to NOx and VOC emissions in upwin d states. EPA subsequently allowed the states more time for study and planning. On June 30, 1998 , NHDES submitted an attainment demonstration (SIP revision), for New Hampshire’s 1 -hour ozone nonattainment area. In a final rule published on December 6, 2002 (67 FR 72574), E PA approved New Hampshire’s attainment

demonstration and its attainment-level motor vehicl e emissions budget for the New Hampshire portion of the Boston-Lawrence-Worcester, MA-NH ser ious ozone nonattainment area.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 17



### 3.4 Reasonable Further Progress Requirements

Section 182(c) also required any state with a serio us nonattainment area for ozone to prepare a plan for reasonable further progress (RFP) to reduce VOC emissions by at least 15 percent from 1990 base year levels by November 15, 1996, and to achie ve an additional 9 percent reduction in VOC emissions by November 15, 1999. NHDES submitted Ne w Hampshire’s 15% RFP plan to EPA on February 2, 1994 (subsequently revised May 10, 1994 ; October 11, 1994; and August 29, 1996), followed by New Hampshire’s 9% RFP plan on Septembe r 27, 1996. These plans were specific to

the Portsmouth-Dover-Rochester 1-hour ozone nonatta inment area and the New Hampshire portion

of the Boston-Lawrence-Worcester 1-hour ozone nonat tainment area. EPA published final rules approving SIP revisions for the 15% RFP plan on Dec ember 7, 1998 (63 FR 67405), and April 16, 2002 (67 FR 18493).

With respect to the 8-hour ozone standard, EPA’s cl ean data determination (see next paragraph) suspended the requirements for a reasonable further progress plan and other SIP elements for the southern New Hampshire area.

3.5 Clean Data Rule for 8-Hour Ozone Attainment

From an analysis of monitoring data for the period 2007-2009, EPA determined that the Southeast New Hampshire Nonattainment Area (moderate) had rea ched attainment of the 8-hour ozone NAAQS. A final rule published on March 18, 2011 (7 6 FR 14805), effective on April 18, 2011, suspended the requirements for this area to submit an attainment demonstration, an RFP plan, contingency measures, and other State Implementatio n Plan elements related to attainment of the 8- hour ozone NAAQS. This determination is consistent with EPA’s Clean Data Rule (40 CFR 51.918), which exempts the state from certain SIP r equirements if the area has three consecutive years of air quality data showing it meets the NAAQ S, for as long as the area continues to attain the

standard.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 18



### 4. PERMANENT AND ENFORCEABLE EMISSION REDUCTIONS

Recent air quality improvements in the Southeast Ne w Hampshire Nonattainment Area, evidenced by the decline in 8-hour ozone design values, are t he result of fewer emissions of NOx and VOC from a broad spectrum of sources: stationary point, area, and mobile. Most of the improvement

over 2000-2002 baseline values is attributable to i mplementation of federally mandated emission control programs – in particular, the NOx SIP Call and the Federal Motor Vehicle Emission Control Program (FMVCP). Various New Hampshire programs ha ve also reduced in-state emissions during the same period.

More than 90 percent of all pollutants responsible for the formation and presence of high concentrations of ground-level ozone in New Hampshi re’s nonattainment area originate from emission sources in upwind states. 3 

### However, the transported pollutants from upwind s tates have shown steady declines since the early 1990s as a re sult of federal emission control programs and control measures adopted into the SIPs of upwind st ates. Air quality improvements associated with the remaining 10 percent of pollutants (i.e., in-st ate emissions) can be attributed to permanent and enforceable emission reduction measures adopted by New Hampshire.

4.1 Emission Control Programs

Regional and state strategies to control ozone have focused on reducing emissions of NOx and VOC as the major photochemical precursors of ground-lev el ozone formation. In urban areas, the relatively high density of local emission sources c an lead to elevated concentrations of ozone. At the same time, ozone concentrations in both urban a nd rural areas are influenced by regional transport – the movement of ozone and its precursor s by the wind. Controlling both NOx and VOC emissions can be effective for reducing local ozone levels in urban locations, while controlling NOx is typically more effective for reducing regional i mpacts, especially in New Hampshire, where biogenic sources dominate VOC emissions. As a cons equence, ground-level ozone in New Hampshire may be addressed most successfully throug h a combination of regional programs focused on controlling NOx emissions and local prog rams controlling both ozone-precursor types.

Some emission control programs for NOx and VOC were implemented and began to yield demonstrable emission reductions within the region prior to the 2000-2002 baseline period. That is, these programs were already reducing ozone-causing emissions before the official designation of New Hampshire’s 8-hour ozone nonattainment area, bu t continued thereafter to provide real and permanent decreases in emissions from the affected source categories, especially where source turnover/replacement is an important element of rul e penetration (e.g., nonroad engines). On the other hand, some emission control measures implemen ted since 2000-2002 may not have had sufficient time yet to reach maximum rule penetrati on and full effectiveness. Thus, the downward

trend in emissions attributable to control measures already in place is expected to continue.

It should be emphasized that the decline in ozone c oncentrations from nonattainment to attainment levels in New Hampshire is due to implemented contr ol measures rather than special circumstances such as the shutdown of a major emission source. I n the future, New Hampshire intends to maintain existing emission control programs or replace them with equivalent or more stringent control measures as necessary to comply with all applicable laws and regulations.

3 New Hampshire Department of Environmental Services , “Air Pollution Transport and How It Affects New H ampshire,” May 2004.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 19



### Tables 4-1 and 4-2 list federal and state enforceab le emission control requirements that have contributed to the documented improvements in 8-hou r ozone levels in the nonattainment area.

Table 4-3 lists all NOx and VOC RACT orders for ind ividual sources issued by NHDES since 2001.

Table 4-1. Federal Emission Control Measures for N Ox and VOC in the Southeast New Hampshire Nonattainment Area

Federal Control Measure Citation NH SIP Revision

National VOC Emission Standards for Consumer and Co mmercial Products 40 CFR 59 --

Standards of Performance for New Stationary Sources 40 CFR 60 --

Acid Rain Nitrogen Oxides Emission Reduction Progra m 40 CFR 76 --

Control of Air Pollution from Mobile Sources 40 CFR 85 --

Control of Emissions from New and in-Use Highway Ve hicles and Engines 40 CFR 86 --

Control of Air Pollution from Aircraft and Aircraft Engines 40 CFR 87 --

Control of Emissions from New and in-Use Nonroad Co mpression-Ignition Engines 40 CFR 89 --

Control of Emissions from Nonroad Spark-Ignition En gines 40 CFR 90 --

Control of Emissions from Marine Spark-Ignition Eng ines 40 CFR 91 --

Control of Air Pollution from Locomotives and Locom otive Engines 40 CFR 92 --

Control of Air Pollution from Marine Compression-Ig nition Engines 40 CFR 94 --

NOx Budget Trading Program for State Implementation Plans 40 CFR 96 --

Reasonable Further Progress CAA Section 182(b)(1) and CAA Section 182(c)(2)(B) 63 FR 67405 and

67 FR 18493

VOC Reasonably Available Control Technology (RACT) CAA Section 182(b)(2) and CAA Section 182(c) 63 FR 11600 and

67 FR 48036

NOx Reasonably Available Control Technology (RACT) CAA Section 182(f) 62 FR 17092

Gasoline Vapor Recovery: Stage II Vapor Recovery CAA Section 182(b)(3) and CAA Section 182(c) 63 FR 67405

Motor Vehicle Inspection and Maintenance CAA Section 182(b)(4) and CAA Section 182(c) 67 FR 65710

Enhanced Vehicle Inspection and Maintenance (Altern ative Program) CAA Section 182(c)(3) 66 FR 1868

Attainment Demonstration: 1-Hour Ozone CAA Section 182(c)(2)(A) 67 FR 72574

Onboard Vapor Recovery (ORVR) CAA Section 202(a)(6) --

Emissions Control Diagnostics: Onboard Diagnostic ( OBD) Systems CAA Section 202(m) --

Reid Vapor Pressure Requirements CAA Section 211(h) --

Reformulated Gasoline for Conventional Vehicles CAA Section 211(k) --

Conformity CAA Section 176(c) 64 FR 44417

Motor Vehicle Emissions Budget (MVEB) CAA Section 182(c)(5) 74 FR 8863

Note: The above list is not necessarily inclusive of all federal measures to control NOx and VOC that contributed to air quality improvements in the Southeast New Hampshire Nonatta inment Area prior to the 2007-2009 attainment perio d.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 20



### Table 4-2. State Emission Control Regulations for NOx and VOC in the Southeast New Hampshire Nonattainment Area
(SIP-approved rules in black, other State rules in blue )

NH Administrative Rule Effective Date(s) Submitted for

EPA Approval EPA

Approval Description

Env-A 622 Additional Requirements in NonAttainment Areas and the New Hampshire Portion of the Northeast Ozone Transport Region 01-30-1999 07-02-99 07-27-2001
66 FR 39100

Env-A 618 (formerly 622) Additional Requirements in Non-Attainment Areas and the New Hampshire Portion of the Northeast Ozone Transport Region 10-28-2002 Not Submitted Provisions applicable to new major stationary sources and major modifications to existing

sources.

Env-A 623 Prevention of Significant Deterioration (PSD) of Air Quality Permit Requirements 07-27-2001 08-06-2001 10-28-2002
67 FR 65710

Env-619 (formerly 623) Prevention of Significant Deterioration (PSD) of Air Quality Permit Requirements 04-26-2003 Not Submitted Preconstruction review procedures for new major stationary sources and major modifications to existing sources in areas where existing air quality meets the NAAQS.

Env-A 1204 Stationary Sources of Volatile Organic Compounds (VOCs)

Env-A 1204.09 (Metal Cans)

Env-A 1204.10 (Paper, Fabrics, Film and Foil Substrates)
Env-A 1204.12 (Metal Furniture Coating)

Env-A 1204.13 (Magnetic Wire Insulation Coating)

Env-A 1204.14 (Coating of Metal Coils)

Env-A 1204.15 (Miscellaneous Metal Parts and Products)
Env-A 1204.17 (Coating of Wood Furniture, Burial Caskets, and Gunstock)
Env-A 1204.18 (Rotogravure and Flexographic Printing)
Env-A 1204.19 (Offset Lithographic Printing)

Env-A 1204.20 (Fixed Roof Tank VOL Storage)

Env-A 1204.21 (External Floating Roof Tanks)

Env-A 1204.22 (Bulk Gasoline Loading Terminals)

Env-A 1204.23 (Bulk Gasoline Plant)

Env-A 1204.25 (Cutback and Emulsified Asphalt)

Env-A 1204.26 (Solvent Metal Cleaning) 08-31-1995 06-28-96
10-24-96 03-10-98

63 FR 11600

Env-A 1204.27 (Misc. and Multicategory Station VOC Sources) 08-31-1995 06-28-96
10-24-96 07-23-2002

67 FR 48033

Env-A 1204 Stationary Sources of Volatile Organic Compounds (VOCs)

Env-A 1204.09 (Metal Cans)

Env-A 1204.10 (Paper, Fabrics, Film and Foil Substrates)
Env-A 1204.12 (Metal Furniture Coating)

Env-A 1204.13 (Magnetic Wire Insulation Coating)

Env-A 1204.14 (Coating of Metal Coils) 12-31-2002 03-17-2003 Approval not yet acquired Provisions for

implementation of reasonably available control technology (RACT) on certain VOC-emitting sources.

(Note: Env-A 1204 was readopted as Env-A 1200, effective 06-01-2011, and
submitted for SIP approval on 07-26- 2011.)Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 21

NH Administrative Rule Effective Date(s) Submitted for

EPA Approval EPA

Approval Description

Env-A 1204.15 (Miscellaneous Metal Parts and Products)
Env-A 1204.17 (Coating Plastic Components of Automotive Interiors)
Env-A 1204.18 (Coating Plastic Components of
Automotive Exteriors
Env-A 1204.19 (Specialty Coatings on Automotive Components)
Env-A 1204.25 (Coating of Wood Furniture, Burial Caskets and Gunstock)
Env-A 1204.36 (Rotogravure and Flexographic Printing)
Env-A 1204.37 (Offset Lithographic Printing)

Env-A 1204.38 (Fixed Roof Tank VOL Storage)

Env-A 1204.39 (External Floating Roof Tanks)

Env-A 1204.40 (Bulk Gasoline Loading Terminals

Env-A 1204.41 (Bulk Gasoline Plants)

Env-A 1204.42 (Cutback and Emulsified Asphalt

Env-A 1204.43 – 1204.47 (Solvent Metal Cleaning)

Env-A 1204.48 (Misc. And Muilticategory Stationary VOC Sources)

Env-A 1204 Stationary Sources of Volatile Organic Compounds (VOCs)

Env-A 1204.02 Scope

Env-A 1204.03 Definitions

Env-A 1204.43 (Solvent Metal Cleaning)

Env-A 1204.44 (Cold Cleaning) 02-26-2005 07-09-07 Approval not yet acquired

Env-A 1205 VOC: Gasoline Dispensing Facilities
and Gasoline Tank Trucks 08-17-1992 12-07-98
63 FR 67405
Env-Wm 1404 (formerly Env-A 1205) Gasoline Dispensing Facilities, Bulk Gasoline Plants, and Cargo Trucks 02-25-2004

08-21-2004 Not Submitted Requirements for underground storage tank facilites to prevent and
minimize the
contamination of the land
and water of the state.

Env-A 1211 Nitrogen Oxides (NOx)

Env-A 1211.03 (Utility Boilers)

Env-A 1211.05 (Industrial Boilers)

Env-A 1211.06 (Combustion Turbines)

Env-A 1211.07 (Stationary Internal Combustion Engines)
Env-A 1211.08 (Asphalt Plant Dryers)

Env-A 1211.09 (Incinerators)

Env-A 1211.10 (Wallboard Manufacturing)

Env-A 1211.11 (Emergency Generators)

Env-A 1211.12 (Auxilliary Boilers)

Env-A 1211.13 (Load Shaving Units)

Env-A 1211.14 (Miscellaneous Stationary Sources) 08-31-1995 04-09-1997
62 FR 17087 Provisions for

implementation of reasonably available control technology(RACT) on certain NOxemitting sources.

(Note: Env-A 1211 was readopted as Env-A 1300, effective 10-31-2010, and
submitted for SIP approval on 03-31-2011.)Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 22

NH Administrative Rule Effective Date(s) Submitted for

EPA Approval EPA

Approval Description

Env-A 1211 Nitrogen Oxides (NOx) 10-31-2002
12-22-2004 03-17-2003

07-09-07
Env-1211.03 (Utility Boilers)

Env-A 1211.05 (Industrial Boilers)

Env-A 1211.06 (Combustion Turbines)

Env-A 1211.07 (Stationary Internal Combustion Engines)
Env-A 1211.08 (Asphalt Plant Dryers)

Env-A 1211.09 (Incinerators)

Env-A 1211.10 (Wallboard Manufacturing)

Env-A 1211.11 (Emergency Generators)

Env-A 1211.12 (Auxilliary Boilers) 12-22-2004 07-09 -07

Env-A 1211.13 (Load Shaving Units)

Env-A 1211.14 (Miscellaneous Stationary Sources) Approval not yet acquired

Env-A 1500 Conformity 04-19-1996 08-16-1999

Env-A 1502 Conformity of General Federal Actions 04-25-1996 07-10-1996 08-16-1999
64 FR 44417

Env-A 1500 Conformity

Env-A 1501 Transformation Conformity 10-27-1995

8-27-1998
10-14-2003
06-22-2005 12-1-1998 Approval not yet acquired

Env-A 1502 Conformity of General Federal

Actions 10-14-2003
06-22-2005 Provisions related to the conformity of federal
actions to New Hampshire’s SIP.

Env-A 3200 NOx Budget Trading Program 07-27-1998 11-14-2000
65 FR 68078

Env-A 3200 NOx Budget Trading Program 08-25-1999

02-01-2000
05-24-2003

02-28-2004
08-25-2007

11-02-2007
02-21-2008 Not Submitted Provisions to implement New Hampshire’s NOx Budget Program to help
achieve attainment of the ozone NAAQS.

Saf-C 3200 Official Motor Vehicle Inspection Requirements

Saf-C 3221A Emissions Requirements 11-17-1998 01-10-2001
66 FR 1868

Saf-C 3200 Official Motor Vehicle Inspection Requirements

Saf-C 3220 Emissions Requirements 06-22-2007

Saf-C 3222 On-board Diagnostic System 07-26-2002

06-20-2008 Provisions related to
control of motor vehicles
emissions.

Saf-C 5800 Roadside Diesel Opacity Inspection 11-17-1998 01-10-2001
66 FR 1868

Saf-C 5800 Roadside Diesel Opacity Inspection 01-01-1999 Provisions implementing a roadside heavy-duty diesel emissions testing

program.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 23



### Table 4-3. NOx and VOC RACT Orders Issued in New H ampshire, 2001-Present

Order No. Company Name Pollutant Effective Date
96-001 Textile Tapes Corp. VOC 04-19-02, rev. 08-10 -07

99-001 Kalwall Corp. - Manchester VOC 11-20-01

00-001 Anheuser Busch, Inc. VOC 04-15-02

01-001 Waste Management of NH, Inc. - Turnkey NOx 0 8-26-02, rev. 08-11-11

01-002 Hutchinson Sealing Systems, Inc. VOC 08-08-0 2

02-001 Hitchiner Manufacturing Co., Inc. - Milford VOC 06-20-02

02-003 Newington Energy, LLC NOx 09-09-02

03-001* Parker Hannifin Corporation, Chomerics VOC 07-17-02

03-001* Sturm, Ruger & Company, Inc. VOC 10-13-03, rev. 12-01-03 & 03-02-10

03-002 Gates Mectrol Inc.** VOC 06-16-03

04-001 Newington Energy, LLC NOx 06-20-07

05-001* Anheuser Busch, Inc. NOx 05-09-05

05-001* Metal Works, Inc. VOC 12-22-04

06-001 PSNH Schiller Station - Unit #5 NOx 08-04-06

07-001 Webster Valve, Inc. VOC 04-20-07, rev. 04-20 -07

07-002 TFX Medical, Inc. VOC 08-07-07

07-003 Concord Litho Group, Inc. VOC 09-17-07

07-004 Polyonics, Inc. VOC 12-28-07

* duplicate numbers issued ** facility shut down; letter to cancel RACT order sent to EPA on 07-02-09



### 4.2 Upwind Emission Reductions

As mentioned above, a broad array of NOx and VOC em ission controls in upwind states has largely made possible the attainment of the 1997 8-hour ozo ne standard in the Southeast New Hampshire Nonattainment Area. The observed improvement in ai r quality would not have occurred without the concerted efforts of EPA and the Ozone Transport Co mmission (OTC) to reduce the emitted amounts of both pollutants across the region.

In September 1994, the OTC member states 4 

### adopted a memorandum of understanding to achieve regional NOx emission reductions. Phase I began wi th the installation of RACT, followed in Phases II and III by the development and implementation of regulations to achieve further reductions in ozone-season NOx emissions by 1999 and 2003, respec tively. The second and third phases were modeled on the cap-and-trade principle and resulted in the creation of the OTC NOx Budget Program. 5 

### This program established a de facto NOx emission rate of 0.15 lbs/MMBtu for

4 The OTC includes the states of Maine, New Hampshir e, Vermont, Massachusetts, Connecticut, Rhode Islan d, New York, New Jersey, Pennsylvania, Maryland, Delaware, and the District of Columbia.

5 The NOx Budget Program involves an allowance tradi ng system which harnesses free market forces to red uce pollution, similar to the U.S. EPA's Acid Rain Prog ram. Under this program, budget sources were alloc ated allowances by their state governments. Each allowance permits a source to emit one ton of NOx during the control period (May through September) for which it is allocated or any later control period. Allowances may be bought, s old, or banked. Any person may acquire allowances and participate i n the trading system. Each budget source must comp ly with the program by demonstrating at the end of each control period that actual emissions do not exceed the amo unt of allowances held for that period. However, regardle ss of the number of allowances a source holds, it c annot emit atRequest for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 24



### participating electric generating units and large i ndustrial boilers. Rules for New Hampshire’s participation in the OTC NOx Budget Program are cod ified at Chapter Env-A 3200.

In the midst of these efforts, in 1998, EPA issued a final rule aimed at reducing the regional transport of NOx and ozone. This rule, commonly kn own as the NOx SIP Call, required 22 eastern states and the District of Columbia (not including New Hampshire) to reduce ozone-season NOx emissions. Compliance with the NOx SIP call began on May 1, 2003, for the participating OTC

states 6 

### and on May 31, 2004, for states outside the Ozone Transport Region. Although the NOx SIP Call provided states with the flexibility to design their own programs to meet the NOx reduction requirements, all affected states chose to particip ate in a regional cap-and-trade program. 7



### The NOx SIP Call and the NOx Budget Trading Program (NBP) have had a major effect on reducing regional transport of this pollutant. EPA data presented in Figure 4-1 show that total

ozone-season NOx emissions from all NBP sources fel l from 1,256,000 tons in 2000 to 481,000

tons in 2008. 8



### Figure 4-1. Ozone-Season NOx Emissions from All NOx Budget Trading Program Sourc es

levels that would violate other federal or state li mits (e.g., NSPS, Title IV, NOx RACT).

6 The NOx SIP Call superseded Phase III of the OTC N Ox Budget Program. Maine, New Hampshire, and Vermo nt were not participating states.

7 The NOx Budget Trading Program established under t he NOx SIP Call is separate and distinct from the O TC NOx Budget Program.

8 USEPA, The NOx Budget Trading Program: 2008 Highli ghts, December 2008; available at http://www.epa.gov/airmarkt/progress/NBP_4.html

.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 25



### On March 10, 2005, EPA issued the Clean Air Interst ate Rule (CAIR) to further reduce air pollution

that moves across state boundaries. CAIR establish ed permanent emission caps for nitrogen oxides (and sulfur dioxide) emanating from major sources i n eastern states – representing a 60 percent cut in NOx emissions from 2003 levels. On July 6, 2011 , following a round of legal challenges to the original rule, EPA replaced CAIR with the Cross-Sta te Air Pollution Rule, which corrected certain deficiencies in the original. Although not fully i mplemented before its withdrawal, CAIR yielded significant reductions in NOx emissions and transpo rt; these realized air quality benefits will continue largely in effect under the replacement ru le.

At the same time it was addressing NOx emissions, E PA was developing programs to reduce VOC emissions on a broad scale. Since the 1990’s, EPA has mandated numerous mobile and area source controls for VOC (see Table 4-1), all of which have contributed to improved air quality in New Hampshire and the other downwind states.

As a complement to these federal efforts, the OTC d eveloped model rules to be implemented by the

individual member states for a number of VOC and NO x source categories. The OTC model rules were developed in three series: 2001/2002, 2006, an d 2009/2010. (Note: Some of the 2009/2010 model rules exist in draft form.) Adoption of thes e rules (or their equivalent) in a number of upwind states has helped to reduce the transport of ozone and its precursors into New Hampshire. 9



### As illustrated in Figure 4-2, both NOx and VOC emis sions in the eastern United States declined steadily between 1997 and 2004 for all major source categories.

Figure 4-2. Ozone-Season NOx and VOC Emissions in the Eastern United States

by Source Category: 1997, 2002 and 2004

4.3 In-State Emission Reductions

Aggregated reductions in NOx and VOC emissions from all sources in New Hampshire are partly responsible for New Hampshire’s attainment of the 8 -hour ozone standard. Table 4-4 summarizes statewide emissions by source category for the inve ntory years of 2002, 2005, and 2008.

9 Status reports on states’ adoption of the OTC mode l rules may be viewed by clicking on links to the m odel rule adoption matrices available at http://www.otcair.or g/interest.asp?Fview=stationary

.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 26



### Table 4-4. NOx and VOC Emissions in New Hampshire, 2002, 2005, and 2008 (tons/year)

2002 Emissions 2005 Emissions 2008 Emissions Source Category NOx VOC NOx VOC NOx VOC
Point 9,938 2,010 12,583 1,404 6,734 962
Area 10,681 56,054 11,482 59,263 4,678 19,510
Non-Road Mobile 9,108 22,099 8,746 21,485 8,877 18, 916
On-Road Mobile 30,755 16,895 26,874 14,151 21,450 9 ,431 Total 60,482 97,058 59,685 96,303 41,739 48,819

Note: A revised methodology (EPA's residential woo d combustion tool) was used in the 2008 inventory f or residential wood combustion; this resulted in subst antially lower estimates of NOx and VOC for area so urces.



### Ozone-season daily NOx and VOC emissions in New Ham pshire by source category are represented graphically in Figures 4-3 and 4-4.

Figure 4-3. Ozone-Season Daily NOx Emissions in Ne w Hampshire

by Source Category: 2002, 2005, and 2008

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000

Point Area Non-Road

Mobile On-Road

Mobile TotalNOx Emissions (pounds per day)

2002 2005 2008



### Figure 4-4. Ozone-Season Daily VOC Emissions in Ne w Hampshire

by Source Category: 2002, 2005, and 2008

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000

Point Area Non-Road

Mobile On-Road

Mobile TotalVOC Emissions (pounds per day)

2002 2005 2008Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 27



### 5. COMPLIANCE WITH SECTION 110 AND PART D OF THE CLEAN AIR ACT

Pursuant to Section 107(d)(3) of the Clean Air Act, state implementation plan submittals requesting redesignation of any area or portion thereof must m eet all requirements applicable to the area under Title 1, Part A, Section 110 – Implementation Plans , and Title 1, Part D – Plan Requirements for

Nonattainment Areas.

According to EPA's interpretation 10 

### , to qualify for redesignation, a state requesting redesignation to attainment must meet the relevant CAA requirements that come due prior to the submittal of a complete redesignation request. Applicable require ments of the CAA that come due subsequent to the area's submittal of a complete redesignation re quest remain applicable until a redesignation is approved, but are not required as a prerequisite to redesignation. The Section 110 and part D requirements which are linked with a particular are a's designation and classification are the relevant measures to evaluate in reviewing a redesignation r equest.

Part D, Sections 172-176 of the CAA set forth the b asic requirements for all nonattainment areas. General provisions for nonattainment plans appear i n Section 172(c). Section 182 establishes additional specific requirements depending on the a rea's nonattainment classification. Section 182(b) prescribes specific measures for a moderate nonattainment area such as the Southeast New Hampshire Nonattainment Area. Section 184 establis hes additional requirements applicable to the

area because of its location within the Ozone Trans port Region.

Previous EPA statements 11 

### indicate that conformity, new source review requir ements, and OTR requirements are not applicable to considerations o f redesignation as they are not directly linked with an area's designation and classification. In particular,

• 

### It is reasonable to interpret the conformity SIP re quirements as not applying for purposes of evaluating the redesignation request under Section 107(d) because state conformity rules are still required after redesignation and federal conf ormity rules apply where state rules have not been approved.

• 

### It is reasonable to interpret the Section 184 OTR r equirements, including New Source Review (NSR), as not being applicable for purposes of redesignation based on two factors. First, the requirement to submit SIP revisions for the Section 184 requirements continues to apply to areas in the OTR after redesignation to at tainment. Therefore, the state remains obligated to have New Source Review (as well as RAC T and Vehicle Inspection and Maintenance (I/M) programs) even after redesignatio n. Second, the Section 184 control measures are region-wide requirements and do not ap ply to the area by virtue of its designation and classification.

Once an area has been redesignated to attainment st atus, NSR requirements for nonattainment areas under Part D will be replaced by program requiremen ts for Prevention of Significant Deterioration (PSD) under Part C of Title I. NHDES submitted a N ew Source Review equivalency demonstration to EPA on January 3, 2006, detailing how New Hampsh ire’s current and proposed programs are at least as stringent as the federal NSR and PSD progr ams.

10 EPA memorandum from John Calcagni, Director, Air Q uality Management Division, “Procedures for Process ing Requests to Redesignate Areas to Attainment,” Septe mber 4, 1992.

11 EPA, Approval and Promulgation of Implementation P lans and Designation of Areas for Air Quality Plann ing Purposes; Maine; Redesignation of the Portland, ME and the Hancock, Knox, Lincoln and Waldo Counties, Maine
8-Hour Ozone Nonattainment Areas to Attainment for Ozone; Proposed Rule, October 17, 2006 (71FR 60937)

.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 28



### For redesignation, a major consideration is the ade quacy of maintenance provisions to assure continued attainment of the standard. In the prese nt redesignation request, the maintenance plan presented in 6. MAINTENANCE PLAN 

### meets the requirements set forth in Section 175A o f the CAA. The emissions inventory requirements of Secti on 172(c)(3) are satisfied by the inventory developed for the maintenance plan as described in 6.1 Attainment Inventory . The requirements of Section 172(c)(9) for contingency measures are fulf illed in 6.5 Contingency Plan

.

NHDES asserts that New Hampshire’s implementation p lan meets the requirements of Section 110 and Part D for the state, in general, and for the S outheast New Hampshire Nonattainment Area, in particular. The required rulemaking authority, pow ers of the Commissioner, provisions for permits and enforcement, and other provisions necessary to meet the state’s obligations under the Clean Air Act are established in New Hampshire’s Revised Stat utes Annotated (RSA), Chapter 125-C Air Pollution Control. Regulations implementing New Ha mpshire’s air program are established in the Rules Governing the Control of Air Pollution, New H ampshire Code of Administrative Rules Env-A 100 through 4800. (Note: Many New Hampshire air rules have received SIP approval; see relevant titles listed in Table 4-2). Additional r equirements for controlling mobile source emissions are found in rules issued by the Department of Safe ty at Saf-C 3200 and Saf-C 5800. Provisions for compliance with the specific elements of Section 11 0 are described in more detail below.

5.1 Requirements of Section 110(a)(2)

Section 110(a)(2) of the Clean Air Act and EPA regu lations at 40 CFR 51, Subparts K and L, require that New Hampshire’s state implementation p lan:

• 

### Provide for legally enforceable emission reporting and recordkeeping;

• 

### Provide for periodic testing and inspection of emis sion sources and for enforcement and investigation of complaints;

• 

### Include procedures for implementing transportation- related emission control measures;

• 

### Contain legally enforceable procedures to require s tationary sources to install, calibrate, maintain, and operate equipment for continuously mo nitoring and recording emissions;

• 

### Demonstrate that the state has legal authority to a dopt emission standards and limitations and any other measures necessary for attainment and maintenance of national standards;

• 

### Demonstrate that the state has the legal authority to enforce applicable laws, regulations, and standards and to seek injunctive relief;

• 

### Provide the state with the legal authority to abate pollutant emissions on an emergency basis to prevent substantial endangerment to the health o f persons;

• 

### Demonstrate that the state has the legal authority to prevent the construction, modification, or operation of a facility which directly or indire ctly results or may result in emissions of any air pollutant at any location that will prevent the attainment or maintenance of a national standard;

• 

### Demonstrate that the state has the legal authority to obtain information necessary to determine whether air pollution sources are in comp liance with applicable laws, regulations and standards and that the state has the legal auth ority to make inspections and conduct tests of air pollution sources.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 29



### New Hampshire meets these requirements by having ad opted and implemented the following state laws and regulations that are at least as stringent as the applicable federal requirements established for the protection of air quality:

5.1.1 Emission Reporting and Recordkeeping

Env-A 900 Owner or Operator Recordkeeping and Reporting Oblig ations requires that records be kept at sources that discharge air pollutants so th at the emissions of such pollutants can be readily calculated or estimated and reported to NHDES for t he purposes of demonstrating compliance, compiling emission inventories, and developing air- related strategic plans. The statutory authority for this regulation is provided in RSA 125-C:4, I.

5.1.2 Periodic Testing and Inspection

Env-A 800 Testing and Monitoring Procedures establishes minimum testing and monitoring procedures, calculation procedures, and standards f or any owner or operator of a stationary source, area source, or device, required to perform testing or monitoring to determine compliance with RSA 125-C, any permit issued by the division, or the re quirements of other provisions of Env-A 300 et seq. The statutory authority for this regulation i s contained in RSA 125-C:6, XI, XII. Statutory provisions for investigations and enforcement are e stablished in RSA 125-C:6 and RSA 125-C:15.

5.1.3 Transportation-Related Control Measures

Env-A 1501 Transportation Conformity implements Section 176 of the Clean Air Act and 40 CFR 93, Subpart A, with respect to transportation plans , programs, and projects developed, funded, or approved by the federal government or that are deem ed regionally significant. Conformity

determinations made under this rule ensure that the metropolitan planning organization (MPO) and state transportation plans, programs, and projects in the non-attainment areas adhere to New Hampshire’s SIP. The statutory authority for these regulations is provided in RSA 125-C:4. (See expanded description under 5.4 Transportation Conformity .) Additional regulations for controlling mobile source emissions are presented a t Saf-C 3200 Official Motor Vehicle Inspection Requirements and Saf-C 5800 Roadside Diesel Opacity Inspection

.

5.1.4 Continuous Monitoring and Recording of Emis sions

Env-A 808 Continuous Emission Monitoring requires the owner or operator of a stationary sou rce meeting certain conditions to install, operate, and maintain a CEM system and to perform quality assurance testing on that system. The statutory au thority for this regulation is provided in RSA 125- C:6, XI, XII.

5.1.5 Legal Authority and Emergency Powers

Legal authority to carry out New Hampshire’s implem entation plan is vested in the Commissioner of the New Hampshire Department of Environmental S ervices under New Hampshire statutes RSA

125-C:4 Rulemaking Authority; Subpoena Power and RSA 125C:6 Powers and Duties of the

Commissioner (see Attachment E). The Commissioner has delegated to the Director of the Air Resources Division major responsibilities for carry ing out New Hampshire’s air programs. (Note:Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 30



### Under RSA 125-C:8 Administration of Chapter; Delegation of Duties , the Commissioner cannot delegate rulemaking authority.)

Permit conditions, orders, or directives issued by the Commissioner may be enforced by NHDES or by the New Hampshire Attorney General. NHDES ma y resolve a violation through an administrative consent agreement, schedule and hold an enforcement hearing, or refer the violation to the Attorney General to initiate a civil or crim inal action.

The Governor has appointed the Director of the Air Resources Division, acting under the authority of the Commissioner, as his designee for requesting EPA’s approval of revisions to New Hampshire’s State Implementation Plan (see Attachme nt E).

The authority of the Commissioner to undertake spec ific actions is established in the following

sections of state law:

• 

### RSA 125-C:4 Rulemaking Authority; Subpoena Power provides the Commissioner with the legal authority to adopt emission standards and lim itations and any other measures necessary

for attainment and maintenance of national standard s.

• 

### RSA 125-C:6 Powers and Duties of the Commissioner provides the Commissioner with the legal authority to prevent the construction, modifi cation, or operation of a facility which directly or indirectly results or may result in emi ssions of any air pollutant at any location that will prevent the attainment or maintenance of a national standard; to obtain information necessary to determine whether air pollution source s are in compliance with applicable laws, regulations and standards; and to make inspections and conduct tests of air pollution sources.

• 

### RSA 125-C:9 Authority of the Commissioner in Cases of Emergency provides the Commissioner with the legal authority to abate poll utant emissions on an emergency basis to prevent substantial endangerment to the health of p ersons.

• 

### RSA 125-C:15 Enforcement provides the Commissioner with the legal authority to enforce applicable laws, regulations, and standards and to seek injunctive relief.

5.2 Continuance of Existing Control Requirements after Redesignation

New Hampshire’s implementation plan incorporates fe deral requirements for demonstrating that the ozone standard can be maintained in future years in the Southeast New Hampshire Nonattainment Area. Continued attainment of the standard is supp orted by adherence to anti-backsliding provisions established in Section 173(e) of the CAA and by mai ntenance provisions developed specifically for this area redesignation to meet the requirements of Section 175A (see 6. MAINTENANCE PLAN)



### . Note that, in compliance with federal anti-backslid ing requirements, existing NOx and VOC RACT control measures (as well as other control measures ) implemented within the ozone nonattainment area will remain in effect after redesignation to a ttainment.

Under EPA's anti-backsliding rules, areas designate d nonattainment for the 1-hour ozone standard at the time of the 8-hour ozone designations remained subject to certain control measures that applied by virtue of the area's classification for the 1-ho ur NAAQS (40 CFR 51.900 et seq .). 40 CFR 51.905(a)(1) prescribes the 1-hour NAAQS requiremen ts that continue to apply to former 1-hour

ozone nonattainment areas after revocation of the 1 -hour NAAQS: “The area remains subject to the obligation to adopt and implement the applicable re quirements as defined in section 51.900(f),... ”Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 31



### 40 CFR 51.900(f) reads: “Applicable requirements me ans... the following requirements to the extent such requirements apply or applied to the area for the area's classification under section 181(a)(1) o f the CAA for the 1-hour NAAQS at designation for the 8-hour NAAQS:...”

For New Hampshire’s former 1-hour marginal nonattainment area, the applicable requirements ar e as follows:

• 

### RACT;

• 

### I/M programs;

For New Hampshire’s former 1-hour serious nonattainment areas (Seacoast and Southern), the applicable requirements are as follows:

• 

### RACT;

• 

### I/M programs;

• 

### Major source applicability cut-offs for purposes of RACT;

• 

### ROP reductions;

• 

### Stage II vapor recovery;

• 

### Clean fuels fleet program under Section 182(c)(4) o f the CAA;

• 

### Enhanced (ambient) monitoring under Section 182(c)( 1) of the CAA;

• 

### Transportation controls under Section 182(c)(5) of the CAA;

• 

### NOx requirements under Section 182(f) of the CAA; a nd

• 

### Attainment demonstration or an alternative as provi ded under 40 CFR 51.905(a)(1)(ii).

New Hampshire asserts that all required control pro visions shall remain in place to prevent backsliding and assure maintenance of the 1997 8-ho ur ozone NAAQS after redesignation of the

area to attainment

. The 1-hour ozone attainment demonstration was submi tted and approved, as previously described in 3.3 1-Hour Ozone Attainment Demonstration . Provisions for NOx and

VOC RACT are as described in 3.2 Reasonably Available Control Technology Require ments . Rate of Progress (ROP) reductions are as described in 3.4 Rate-of-Progress Requirements

.

New Hampshire notes that it recently revoked the re quirement that new gasoline dispensing facilities shall be equipped with Stage II vapor re covery control equipment and simultaneously adopted a requirement that owners of existing gasol ine dispensing facilities equipped with Stage II controls shall decommission such equipment by Decem ber 22, 2015. This rulemaking was necessary to prevent a situation – forecast to occu r in the next few years – whereby the Stage II equipment, because of incompatibility with ORVR equ ipment, would cause more VOC emissions than it would prevent. New Hampshire is preparing a separate SIP submittal demonstrating that these rule changes will not violate the anti-backsl iding requirements of section 110(l) of the Clean

Air Act. The demonstration would have been include d with this SIP revision, but has been delayed as NHDES resolves discrepancies in motor vehicle em ission estimates after conversion to the new

MOVES model.

New Hampshire has a motor vehicle I/M program requi ring annual inspections of all motor vehicles. Pre-model year 1996 vehicles that are less than 20 years old undergo a visual anti-tampering inspection. Model year 1996 and newer gasoline and 1997 and newer diesel vehicles up to 8,500 pounds Gross Vehicle Weight Rating (GVWR) are subje ct to an annual onboard diagnostics (OBD) inspection as specified in 40 CFR Parts 51 and 85. In addition, heavy duty diesel vehicles (GVWR >10,000 lbs) are also subject to random roadside op acity testing (see NH statute RSA 266:59-b and New Hampshire Department of Safety Administrative R ules Saf-C 3200 and Saf-C 5800).Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 32



### NHDES operates two enhanced ambient air monitoring stations as required by Section 182(c)(1) of

the CAA for serious nonattainment areas for the 1-h our ozone standard. These Photochemical Assessment Monitoring Stations (PAMS) were original ly configured to track NOx and VOC emissions up- and downwind of the Portsmouth, New H ampshire, metropolitan area. With EPA approval, this network has since been modified to r eflect updated science and to track high- and low-elevation ozone precursor emissions entering th e state from the southwest. Because of the revocation of the 1-hour ozone standard, the PAMS m onitors operate in an 8-hour ozone nonattainment area currently classified as moderate

.

New Hampshire meets Section 182(c)(5) requirements through compliance with the transportation conformity requirements found at 40 CFR Part 93. U sing a consultative process set forth in Env-A 1500, New Hampshire ensures that transportation-rel ated emissions remain consistent with emission levels projected in the state’s attainment demonstr ation and established in the motor vehicle emissions budgets.

5.3 Permitting of Stationary Sources

Under Chapter Env-A 600 Statewide Permit System , all new, modified, and existing stationary emission sources of specified sizes and types are r equired to obtain permits; operate in compliance with applicable laws and regulations; maintain and test emission control equipment; and keep detailed records of emissions, fuel use, and relate d parameters. In addition, NHDES has the authority to conduct periodic inspections and surve illance of emission sources, to enter property at any reasonable time for such purposes, to require t he submission of detailed plans and other data from permit applicants, and to require the submissi on of information regarding actual or suspected

violations.

New Hampshire’s process for permit application and review includes consideration of air quality impact analysis (modeling), emission control techno logy, operational limitations, public participation, and other procedural requirements fo r both existing sources seeking operating permits (renewals) and new or modified sources seeking temp orary (initial construction) permits prior to operation. The permit process also includes consid eration of federal New Source Review requirements applicable to all major sources of NOx , VOC, and other regulated pollutants. State rules designed to protect air quality in existing a ttainment areas are found at Part Env-A 619 Prevention of Significant Deterioration (PSD) Air Q uality Permit Requirements . These rules meet requirements of the Clean Air Act pertaining to PSD and visibility protection as established in Section 110(a)(2) of Title I, Part A and Sections 1 60-169 of Title I, Part C. These rules also are at least as stringent as EPA requirements published at 40 CFR 51.166 and 40 CFR 52.21.

All information submitted to NHDES in permit applic ations is available for public disclosure. Any exceptions to this general statement are determined by the provisions of RSA 125-C:6, VII, and

Env-A 103 Claims of Confidentiality

.

5.4 Monitoring of Stationary Sources

NHDES requires qualifying facilities to install, ma intain, and use emission monitoring devices and to make periodic submittals to NHDES on the nature and quantity of emissions. Air program rules at Chapter Env-A 800 Testing and Monitoring Procedures establish minimum testing and monitoring procedures, calculation methods, standar ds, and other requirements to determine compliance with applicable state/federal laws and r ules. Part Env-A 808 Continuous EmissionRequest for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 33



### Monitoring establishes the requirements for CEMs at major emi ssion sources. Chapter Env-A 900 Owner or Operator Recordkeeping and Reporting Oblig ations identifies requirements for keeping records of and reporting actual emissions to NHDES and EPA. All permitted emission sources are required to file annual emission statements by Apri l 15 for the previous calendar year. NHDES is required to make all information on emissions avail able for public inspection, including any reports correlating source emission data with applicable em ission standards and limitations.

5.5 Transportation Conformity

In addition to requirements for the control of NOx and VOC emissions, the 1990 Clean Air Act Amendments established specific provisions regardin g the conformity of transportation actions. Transportation conformity ("conformity"), as establ ished in Section 176(c)(4) of the Act, is a way to ensure that Federal funding and approval goes to th ose transportation activities that are consistent with air quality goals as outlined in a SIP. Confo rmity applies to transportation plans, transportati on improvement programs (TIPs), and projects funded or approved by the Federal Highway Administration (FHWA) or the Federal Transit Admini stration (FTA) in areas that do not meet or previously have not met air quality standards for o zone, carbon monoxide, particulate matter, or nitrogen dioxide. These areas are known as "nonatt ainment areas" or "maintenance areas," respectively. Regulations governing transportation conformity are found in 40 CFR Parts 51 and 93.

EPA regulations for transportation conformity (40 C FR Parts 51 and 93) require MPOs and the U.S. Department of Transportation (US DOT) to make confo rmity determinations on metropolitan transportation plans and TIPs before they are adopt ed, approved or accepted. In addition, highway or transit projects which are funded or approved by the Federal Highway Administration or the

Federal Transit Administration must also receive a conformity determination before they can be approved or funded by US DOT or an MPO. Regionally significant projects, regardless of their funding source, must also undergo a conformity find ing. The federal rule applies in all nonattainment areas, or areas with maintenance plan s for ozone, carbon monoxide, nitrogen oxides or particulate matter.

EPA’s transportation conformity regulations, first promulgated November 24, 1993, have been amended several times, including on July 1, 2004, w hen EPA issued a final rule to implement conformity for the 8-hour ozone NAAQS, and on May 6 , 2005, March 10, 2006 , and January 24,

2008.

Conformity determinations are made by demonstrating consistency with adequate or EPA-approved motor vehicle emissions budgets (MVEBs) established by rate-of-progress plans, attainment demonstrations, or other control strategy implement ation plans. Section 176(c)(2)(A) specifically requires conformity demonstrations to show that emi ssions from transportation plans and TIPs are

consistent with estimates of emissions from motor v ehicles and necessary emission reductions as established by reasonable further progress, attainm ent demonstrations, and maintenance

demonstrations contained in the SIP. MVEBs are the explicit or implicit identification of the motorvehicle-related portions of the projection inventor y used to demonstrate reasonable further progress milestones, attainment, or maintenance for a partic ular year identified in the SIP. The MVEBs establish a cap on emissions which cannot be exceed ed by predicted highway and transit vehicle

emissions.

On July 28, 2008, EPA deemed adequate for purposes of conformity New Hampshire's SIP revision establishing MVEBs for the Southeast New Hampshire Nonattainment Area. On February 27, 2009, EPA proposed final approval of the budgets, effecti ve April 29, 2009. NHDES developed theseRequest for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 34



### budgets using the MOBILE6.2 modeling platform. Sub sequently, NHDES prepared new MVEBs using EPA’s MOVES2010a model (or, in the case of fu ture-year VOC emissions, MOVES2010b) to be consistent with the agency’s latest policy on model ing emissions from mobile sources. As part of this redesignation request, NHDES is requesting that EPA withdraw the approved MOBILE6.2 2009 MVEBs and replace them with the new MOVES 2008 MVEB s (summarized in Table 5-1). Electronic input/output files for MOVES are provide d as Attachment F.

Simultaneously, NHDES is submitting 2022 MVEBs for NOx and VOC for use in determining transportation conformity (see Table 5-1 and Attach ment F). NHDES used MOVES to calculate onroad emissions of NOx and VOC for the 52 cities and towns in Hillsborough, Merrimack, Rockingham, and Strafford Counties comprising the S outheast New Hampshire Nonattainment Area. In this submittal, New Hampshire is proposin g MVEBs for the last year of the 8-hour ozone maintenance planning period (2022) at 8.9 tons per summer day (tpsd) of VOC and 11.8 tpsd of NOx. These on-road mobile source emissions, when a dded to emissions from all other inventory sources – stationary, area, and other mobile source s (i.e., non-road, marine vessels, airplanes, and locomotives) – result in a year 2022 emissions inve ntory lower than the year 2008 attainment inventory (see NOx and VOC emissions summary in Tab le 6-1). These emissions budgets, once approved or deemed adequate by EPA, must be used fo r future transportation conformity

determinations.

Table 5-1. 2008 and 2022 Motor Vehicle Emission Bu dgets for the Southeast New Hampshire Nonattainment Area (tons per summer day)

2008 2022 Category NOx VOC NOx VOC

Onroad 37.2 17.8 11.8 9.2

5.6 Vapor Recovery: Stage II and Onboard Refuelin g

EPA established the federal Stage II vapor recovery program, a VOC emissions reduction control measure, in Section 182(b)(3) of the CAA. This sec tion of the CAA directs state or local air pollutio n control agencies with moderate or worse ozone nonat tainment areas to require Stage II vapor recovery systems (VRS) at gasoline dispensing facil ities (GDF). However, Section 202(a)(6) of the CAA, states that the Section 182(b)(3) Stage II req uirement shall not apply in moderate areas after new motor vehicle onboard refueling vapor recovery (ORVR) requirements are promulgated.

For the Ozone Transport Region, there is an additio nal requirement, in Section 184(b)(2) of the CAA, for 1) EPA to “complete a study identifying control measures capable of achieving emission reductions comparable to those achievable through v ehicle refueling controls contained in section 7511a (b)(3) of this title, and such measures or su ch vehicle refueling controls shall be implemented in accordance with the provisions of this section” (referred to as comparable measures); and 2) OTR states to revise their state implementation plans t o require Stage II controls or comparable measures in OTR areas (statewide in New Hampshire). 12 

### This requirement is not affected by EPA’s promulgation of ORVR rules, or by any future widesp read use determination under CAA Section 202(a)(6).

12 See U.S. EPA, Stage II Comparability Study for the Northeast Ozon e Transport Region , EPA Publication No. EPA452/R-94-011, January 1995.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 35



### Portions of New Hampshire’s four-county nonattainme nt area (the Southern and Seacoast Serious areas) were assigned a higher than moderate classif ication for the 1997 ozone NAAQS, and the entire state is located in the OTR. Therefore, NHD ES has required Stage II controls as an element of the state’s federally enforceable implementation plan in the four-county nonattainment area since 1992. The Stage II requirements were codified in N ew Hampshire rule Env-A 1205 Volatile Organic Compounds (VOC): Gasoline Dispensing Facili ties and Gasoline Tank Trucks and subsequently approved into the SIP. 13 

### (Note that New Hampshire identified comparable me asures to avoid the OTR statewide Stage II requirement.)

The CAA required EPA to develop standards for ORVR controls on new light-duty vehicles, which were phased in between 1998 and 2002. However, the re is a technology mismatch: vacuum assist Stage II control systems are not fully compatible w ith ORVR-equipped vehicles. ORVR diminishes the effectiveness of the vacuum assist Stage II vap or recovery systems, resulting in an increase in emissions compared to the levels expected during re fueling of non-ORVR-equipped vehicles. Consistent with these findings, NHDES has determine d that Stage II vapor recovery controls are providing a diminished emissions reduction benefit due to the predominance of ORVR-equipped vehicles in the New Hampshire fleet. This benefit will disappear altogether over the next several years as more ORVR-equipped vehicles enter the flee t.

Because of the conflicting technology and its poten tial to increase refueling emissions as ORVR achieves “widespread use,” 14 

### NHDES, with guidance from EPA, is removing the Sta ge II requirement for existing and future gasoline dispen sing facilities. Note, however, that NHDES is not submitting the phase-out of Stage II as a forma l component of this SIP revision to redesignate the 1997 8-hour ozone nonattainment area, but will submit a separate request to remove Stage II requirements from the SIP in the near future

.

5.7 Resource Commitments

Section 110(a)(2)(E) of the CAA requires assurances that the state will have adequate personnel, funding, and authority under state law to carry out the State Implementation Plan. Funding for New Hampshire’s air programs is appropriated by the New Hampshire General Court on a biannual budget cycle. EPA provides significant financial s upport for the administration of federal programs in New Hampshire. The majority of funding is deriv ed through the Air Resource Division’s permit fee structure. NHDES is committed to providing con tinued funding and staffing levels adequate to maintain New Hampshire’s implementation plan.

5.8 Future Revisions to the Plan

NHDES will revise the maintenance plan for the rede signated area, as necessary, to meet revisions to the NAAQS for ozone, to fulfill other requiremen ts of the Clean Air Act, or take advantage of improved methods for maintaining the standard. Mor e specifically, in compliance with Section 175A of the Act, NHDES will revise the maintenance plan eight years after redesignation of the area, or at any such time that EPA deems the mainte nance plan inadequate to meet the NAAQS.

13 See 63 FR 67405, December 7, 1998, at http://www.e pa.gov/region1/topics/air/sips/sips_nh.html

. 14 See U. S. EPA, Stage II Vapor Recovery Systems Issues Paper

, Office of Air Quality Planning and Standards (D243- 02), August 12, 2004, at http://www.epa.gov/ttn/naaqs/oz one/ozonetech/stage2/isspaper081204.pdf

.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 36



### 6. MAINTENANCE PLAN

Section 175A of the Clean Air Act sets forth the el ements of a maintenance plan for areas seeking redesignation from nonattainment to attainment. Th e plan must demonstrate continued attainment of the applicable NAAQS for 10 years after the area is redesignated. Section 175A(b) requires that, eight years after formal redesignation, the state s ubmit a SIP revision for maintenance of the standard for an additional 10 years following the f irst 10-year period. To provide for appropriate response to the possibility of future NAAQS violati ons, the maintenance plan must contain contingency measures adequate to assure prompt corr ection of any air quality problems, including a schedule for implementation.

EPA guidance 15 

### recommends that states seeking redesignation of a nonattainment area consider the following provisions to ensure maintenance of the N AAQS:

• 

### An attainment emissions inventory to identify the l evel of emissions in the area that is sufficient to attain the NAAQS.

• 

### A maintenance demonstration showing that future emi ssions of a pollutant or its precursors

will not exceed the level of the attainment invento ry over the 10-year period following redesignation.

• 

### Continued operation of an appropriate air quality m onitoring network to verify the area's

attainment status.

• 

### Verification of continued attainment and evidence t hat the state has the legal authority to implement and enforce all measures necessary to att ain and maintain the NAAQS.

• 

### Available contingency measures to promptly correct any NAAQS violation, including a schedule for implementation.

6.1 Attainment Inventory

The attainment emissions inventory should identify the level of emissions sufficient to achieve the NAAQS. This inventory should be consistent with EP A's most recent guidance on emission

inventories for nonattainment areas available at th e time and should include emissions during the time period associated with the monitoring data sho wing attainment of the ozone NAAQS. Where the state has made an adequate demonstration that a ir quality has improved as a result of the SIP, the attainment inventory will generally be the actual i nventory during the time period the area attained the standard. The inventory must be based on "typi cal summer day" emissions of VOCs and NOx during the attainment year.

NHDES has developed an attainment inventory for 200 8, representing the three-year period (2007- 2009) in which New Hampshire’s ozone monitoring dat a showed attainment of the 8-hour ozone standard. (Note that the monitoring data have met this standard since the 2002-2004 monitoring period). The 2008 attainment inventory and project ed future inventories (see 6.2.1 Projected 2012

and 2022 Emissions Inventories ) are subdivided into the following general emissio ns categories:

• 

### Point Sources , which represent discrete facilities. These sourc es usually must meet certain emission criteria to be included as point sources a nd generally represent larger facilities.

• 

### Area Sources , which represent facilities and activities too num erous and widespread to be inventoried individually but which collectively may account for significant emissions.

15 See footnote 10.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 37

• 

### Non-Road Mobile Sources , including aircraft, locomotives, commercial marin e vessels, construction vehicles, lawn & garden equipment, and other mobile vehicles and equipment that are not meant to be operated on roadways.

• 

### On-Road Mobile Sources , including cars, trucks, buses, motorcycles, and o ther vehicles that operate on public roadways.

The 2008 attainment inventory and the projected 201 2 interim-year and 2022 maintenance inventories represent all NOx and VOC emissions ori ginating within the specific cities and towns of the 8-hour ozone nonattainment area (see Table 1-1 for list). These inventories were developed in accordance with EPA guidance. Because the 2008 emi ssions inventory serves as the attainment inventory for this redesignation request, it is bei ng formally adopted into the New Hampshire SIP. The 2008 emissions inventory is also being submitte d to EPA for inclusion in the 2008 National Emissions Inventory. Detailed documentation for Ne w Hampshire's 2008 emissions inventory is presented for SIP approval as Attachment G. The me thodologies used in preparing the 2008 emissions estimates are summarized in the following paragraphs.

For point sources, affected facilities in New Hamps hire are required to report their emissions on an annual basis. The reporting requirements for these facilities are provided under New Hampshire’s air regulations, its state air permitting program, and the CERR. Data submitted by these facilities a re extensively cross-checked and quality assured by NH DES staff before eventual submittal to EPA. The point source data contained in New Hampshire’s 2008 attainment inventory originated from the quality-assured 2008 data from all reporting point sources in the 8-hour nonattainment area.

The methodologies used to estimate emissions for ar ea source categories come primarily from EPA’s Emissions Inventory Improvement Program (EIIP). Ca lculations for many area source categories are based on variables such as population, employment, and fuel consumption data. Descriptions of the methodologies for specific area source categories c an be found in EIIP Volume 3, Area Sources

, which is available at EPA’s Clearinghouse for Inven tories and Emissions Factors website at http://www.epa.gov/ttn/chief/eiip/techreport/volume 03/index.html

.

For the non-road mobile category, NHDES used EPA’s NONROAD2008a model to estimate 2008 emissions for those equipment types that are includ ed in the model. For commercial aircraft and airport ground service equipment, NHDES used the Fe deral Aviation Agency’s (FAA’s) Emissions & Dispersion Modeling System (EDMS). Standardized methodologies and references were employed for equipment types not included in the ED MS or NONROAD models, e.g., locomotives

and commercial marine vessels.

For on-road mobile sources, NHDES used MOVES2010a w ith VMT and other road related data provided by the relevant MPOs within the state’s no nattainment area. Results represent emissions originating in cities and towns in the non-attainme nt area only, not whole counties as had been reported previously.

Estimated emissions for the 2008 attainment invento ry are shown in Table 6-1.

6.2 Maintenance Demonstration

EPA guidance on redesignation provides for demonstr ating maintenance of the NAAQS through the use of either an emissions inventory approach (wher e a state demonstrates that future emissions of a pollutant or its precursors will not exceed the lev el of the attainment inventory), or by air quality modeling to show that future emission rates from al l sources will not cause a violation of the NAAQS.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 38



### The maintenance demonstration should be for a perio d of 10 years following the redesignation and should consider future growth, including population and industry, be consistent with the attainment inventory, and provide documentation of data inputs and assumptions. All elements of the

demonstration should be consistent with current EPA guidance. Enforceability through regulations

must also be demonstrated.

Any assumptions concerning emission rates must refl ect permanent, enforceable measures. A state generally cannot take credit for reductions unless there are regulations in place requiring those

reductions or the reductions are otherwise shown to be permanent. Therefore, the state is expected to maintain its implemented control strategy despit e redesignation to attainment, unless such measures are shown to be unnecessary for maintenanc e or are replaced with measures that achieve equivalent reductions. Emission reductions from so urce shutdowns can be considered permanent

and enforceable to the extent that those shutdowns have been reflected in the State Implementation Plan and all applicable permits have been modified accordingly.

6.2.1 Projected 2012 and 2022 Emissions Inventori es

New Hampshire has chosen to utilize the emissions i nventory approach to demonstrate that its future emissions of ozone precursors will not excee d the level of the 2008 attainment inventory, and has projected emissions for 2012 and 2022. 16 

### Table 6-1 shows that future emissions of NOx and VOC will remain below the level of New Hampshire’s 2008 attainment inventory through the 10- year planning period following redesignation – the result of a continuing decline in total emissions. The projected emissions reflect the expected summer time emissions based on enforceable emission limits and typical production rates. The methodolo gies used to estimate projected 2012 and 2022 emissions are discussed in the following paragraphs

.

Table 6-1. 2008 vs. 2012 and 2022 NOx and VOC Emis sions in the Southeast New Hampshire Nonattainment Area (pounds per summer day)

NOx VOC Source Category 2008 2012 2022 2008 2012 2022 Point 24,289 21,655 22,742 5,762 5,288 6,605 Area 6,528 6,243 6,432 55,871 57,885 70,195 Non-Road Mobile 31,364 26,121 17,670 33,512 26,863 19,152 On-Road Mobile 74,352 51,204 23,558 35,666 28,470 1 8,410 Total 136,533 105,223 70,402 130,811 118,506 114,36 2

Except as noted below, New Hampshire used EPA's Eco nomic Growth Analysis System (EGAS) Version 5.0 to develop the applicable growth factor s for estimating projected 2012 and 2022 emissions. Growth factors were matched to the appr opriate point, area, and mobile source categories using Source Classification Codes (SCC). With respect to area sources, New Hampshire has adopted or is evaluating various control measur es for a number of VOC source categories such as solvent cleaning, architectural surface coating, et c. For those measures that are not yet SIPapproved, the attendant emission reductions benefit s are omitted from the 2012 and 2022 inventories. As a consequence of this conservative approach, it is anticipated that actual future-yea r emissions will be lower than the projected emission s presented in Table 6-1.

16 The maintenance plan must show that emissions 10 y ears after the date on which EPA approves the redes ignation request (expected to be in 2012) will be lower than they were in the base year (2008) of the maintenan ce plan.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 39



### Because analysis year is an inherent input into the NONROAD model, projected 2012 and 2022 non-road mobile emissions were estimated directly f or those non-road equipment categories that are
included in the model. For other non-road mobile c ategories 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 app lied to the specific activities (e.g., aircraft landing and takeoff operations); and the growth-adj usted values were then input into the EDMS model. (Note: The EDMS model uses the analysis yea r to select the appropriate emission factors.)

For on-road mobile sources, VMT data were provided by the relevant Metropolitan Planning Organizations (MPOs) via their transportation deman d models that use population, employment and other economic factors as inputs to growth-adjust t o 2012 and 2022. These values were subsequently used as inputs to the MOVES model. Vehicle population data were adjusted for subsequen t years using the growth factors from Table 3-14 of MOVES20 10 Highway Vehicle Population and Activity Data, EPA-420-R-10-026, November 2010. Fo r 2012 and 2022, the MOVES model was run with Stage II controls turned off to reflect th e fact that New Hampshire’s Stage II vapor recovery program is no longer providing emissions reductions as of January 1, 2012. The 2012 and 2022 onroad mobile VOC estimates were generated using the MOVES2010b model. All other on-road
mobile emissions estimates shown in Table 6-1 were produced with MOVES2010a.

In addition to growth factors and future control me asures, another consideration in making emission projections is that sources in New Hampshire hold a certain quantity of banked emissions under the state’s open market trading program. As of 2011, t hese sources held 68 tons of ozone-season Discrete Emissions Reductions (DERs) and 254 tons p er season of ozone-season Emissions Reductions Credits (ERCs) for VOC. Similarly, New Hampshire sources held 1,882 tons of ozoneseason DERs and 198 tons of ozone-season ERCs for N Ox. It is expected that these credits will remain banked and not be used. However, it was con servatively assumed that all available emissions credits would be used. Therefore, they h ave been included in the project point source
emissions estimates shown in Table 6-1.

All of the technical data files related to the proj ected 2012 and 2022 emissions inventories are
enclosed on CD-ROM as Attachment H.

6.2.2 Air Quality Modeling

Although EPA’s redesignation guidance does not requ ire air quality modeling for ozone nonattainment areas seeking redesignation, extensiv e modeling has been performed to determine the effect of national and regional emission control st rategies on ozone air quality in New Hampshire and throughout the eastern United States. These mo deling analyses have demonstrated that the Southeast New Hampshire Nonattainment Area is signi ficantly impacted by transported ozone and ozone precursors and that regional NOx reductions w ill provide significant ozone air quality improvements in this area.

6.2.2.1 EPA Modeling Analysis for the Nonroad Land- Based Diesel Engines Standards

In 2003, EPA conducted modeling to support the rule making for the Nonroad Land-based Diesel Engines Standards. 17 

### In its analysis, EPA used the Comprehensive Air Q uality Model with Extensions (CAMx) to evaluate the impacts of the pr oposed emission reductions on future air quality levels. Three meteorological episodes (Jun e 12-24, 1995; July 5-15, 1995; and August 7-21,

17 “Technical Support Document for the Nonroad Land-b ased Diesel Engines Standards Air Quality Modeling Analyses”, U.S. EPA Office of Air Quality Planning and Standards, April 2003.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 40

 

### 2001 Base Year  

### 2010 Base Case

 

### 2010 CAIR Controls  

### 2015 Base Case

 

### 2015 CAIR Controls

 

### 2015 CAIR + BART

 

### 2015 BART Only 

### 1995) were used for the modeling simulations. Ambi ent monitoring showed that ozone
concentrations over the eastern United States were relatively elevated during these time periods. Using the relative reduction factor method, EPA app lied CAMx to predict ozone values under several emissions scenarios: the 1996 base year, th e 2021 baseline case, the 2021 control case, the 2030 baseline case, and the 2030 control case. Res ults of this modeling show that under both the base case (without new rules on nonroad land-based diesel engines) and under the control scenario (with these new rules), there would be no counties in New Hampshire with predicted future design values that exceed (or come within 10 percent of) t he 8-hour ozone standard.

6.2.2.2 EPA Modeling Analysis for the CAIR Rulemaki ng

More recently, EPA conducted a similar modeling ana lysis as part of the Clean Air Interstate Rule (CAIR) rulemaking 18 

### . In this analysis, EPA used CAMx version 3.10 to model the 1995 ozone episode meteorology described above (i.e., June 12-24, July 5-15, and August 7-21, 1995). The analysis years and emissions scenarios that were assessed in cluded:

The 2010 and 2015 base cases reflect expected econo mic growth and the anticipated benefits associated with existing emissions control programs

.

As with the modeling done for the non-road diesel r ulemaking, the CAMx model predictions for the CAIR analysis were used in a relative manner. Weig hted-average 1999-2003 design values were
used as the basis of the observed 8-hour ozone conc entrations. EPA then estimated maximum 8- hour ozone design values for each future-year scena rio for each county in the modeling domain with
an ozone monitor. Table 6-2 shows the maximum esti mated future 8-hour design values for New Hampshire. These results show that, even without t he emissions benefits associated with CAIR, all New Hampshire counties were predicted to be in atta inment for 8-hour ozone for the 2010 and 2015 analysis years.

Table 6-2. Summary of CAIR Modeling Results for Oz one Levels in New Hampshire (ppb)

Estimated Maximum 8-hour Future Design Values County 1999-2003

Average Design

Value 2010 Base 2010 CAIR 2015 Base 2015 CAIR

Belknap 78.0 68.5 68.2 65.8 65.0

Carroll 66.5 60.3 60.0 58.6 58.0

Cheshire 73.7 65.2 64.9 63.1 62.0
Hillsborough 85.0 76.7 76.6 74.1 73.9

Merrimack 73.0 64.8 64.6 62.3 61.8
Rockingham 82.7 75.2 75.1 73.3 72.9

Strafford 77.3 69.2 69.1 66.8 66.5

Note: Data taken from Appendix E of EPA’s Technical Support Document for the Final Clean Air Interstate Rule, Air Quality Modeling, March 2005.

18 “Technical Support Document for the Final Clean Ai r Interstate Rule, Air Quality Modeling”, U.S. EPA Office of Air Quality Planning and Standards, March 2005.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 41



### 6.3 Air Quality Monitoring Network

Once an area has been redesignated, the state must continue to operate an appropriate air quality monitoring network in accordance with 40 CFR Part 5 8, to verify the area's attainment status. In cases where measured mobile source parameters (for example, vehicle miles traveled) have changed over time, the state may also need to perform a sat uration monitoring study to determine the need for and location of additional permanent monitors. NHDES is committed to the continued operation and maintenance of an appropriate air quality monit oring network for the Southeast New Hampshire Nonattainment Area, contingent on future EPA fundin g sufficient to sustain the network at the required operational levels.

6.4 Verification of Continued Attainment

Verification of continued attainment can be accompl ished through the acquisition of air quality data and source emission data. Air quality data will di rectly show whether the ozone NAAQS is being met in real time and over specified averaging perio ds. The gathering of source emission data enables the construction of periodic updates to emi ssions inventories for tracking progress in emission control measures or supplying inputs for r evised air quality modeling projections. Emission inventory updates could be based, in part, on the annual update of EPA’s national emissions inventory (NEI) database and could indica te new source growth and other changes from the attainment inventory (such as changes in vehicl e miles traveled or in traffic patterns).

New Hampshire will track the progress of attainment maintenance by making periodic updates to the state emissions inventory. NHDES ordinarily re vises the emissions inventory on a 3-year cycle; the latest one, the 2008 inventory, was completed i n 2010. Subsequent updates will be prepared for 2011 and 2014. NHDES will report the results of th is tracking program to EPA on the same 3-year cycle, when the emissions inventory data become ava ilable.

6.5 Contingency Plan

Section 175A(d) of the Clean Air Act requires that a maintenance plan include contingency provisions to promptly correct any violation of the NAAQS that occurs after redesignation of a

nonattainment area to attainment status. As an enf orceable part of the SIP, the contingency plan should be implemented expediently if and when the n eed arises. According to EPA guidance 19 

### , the contingency plan should clearly identify the measur es to be adopted, a schedule and procedure for adoption and implementation, and a specific time li mit for action by the state. The plan should also identify specific indicators, or triggers, that the state will use to determine when the contingency measures are needed. Action-level indicators might be based on ambient ozone concentrations (e.g., monitored violations of the NAAQS) or on updated em ission inventory values (e.g., tonnages of specific ozone-precursor pollutants).

EPA points out that air quality levels above the NA AQS will not automatically necessitate a revision of the SIP where implementation of conting ency measures is adequate to address the cause

of the violation. The need for a SIP revision is s ubject to the EPA Administrator’s discretion. EPA states in its guidance that the agency will review what constitutes a contingency plan on a case-bycase basis. At a minimum, it is required that the state implement all measures contained in the SIP for the nonattainment area prior to its redesignati on to attainment.

19 See footnote 10.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 42



### Despite New Hampshire’s best efforts to maintain co mpliance with air quality standards, the possibility exists that ambient ozone concentration s might at some future date exceed the NAAQS. Therefore, in accordance with the requirements of S ection 175A(d), New Hampshire has identified various contingency measures that could be taken fo llowing an ozone “trigger” event and is committed to 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 redesigna ted planning area is above or below the 1997 8-hour ozone standard (the “trigger”). The de sign value, in the case of this standard, is defined as the average of the annual 4 th 

### highest daily maximum 8-hour average concentration for the preceding 3-year period.

2. If the design value is above the standard for any o zone monitor, NHDES will investigate the

cause and determine whether the exceedance is due t o:

• 

### an increase in emissions from local, in-state sourc es;

• 

### an increase in emissions from upwind, out-of-state sources; or

• 

### exceptional event as defined in 40 CFR 50.1.

3. If an increase in in-state emissions is determined to be a contributing factor to the exceedance, NHDES will evaluate the projected in-st ate emissions for the next ozone season. If the projected in-state emissions are no t expected to decrease enough in the next ozone season to mitigate the violation, New Hampshi re will implement one or more of the contingency measures listed below or will substitut e other VOC or NOx control measures as necessary to achieve additional in-state emission r eductions.

4. The contingency measures(s) will be selected by the Governor or the Governor’s designee

within six months of the end of the ozone season fo r which contingency measures have been determined to be needed. New Hampshire will then i nitiate a course of action to implement enforceable control measure(s) to rectify the probl em. New rulemaking can typically be adopted and implemented within a 12-month timeframe

. NHDES will update the maintenance plan as necessary and develop and imple ment required regulations as soon as practicable within the guidelines established in th e New Hampshire Administrative Procedures Act, but no later than 18 months after selection of the appropriate measure.

New Hampshire is studying an array of possible cont ingency measures that would achieve further reductions in NOx and VOC emissions, including the following emission controls previously proposed by the Northeast states:

• 

### NOx controls for industrial, commercial, and institutional (ICI) boi lers;

• 

### VOC controls for emulsified and cutback asphalt paving ; and

• 

### VOC controls for consumer products

.

These contingency measures are among several OTC co ntrol measures 20 

### exceeding current on-thebooks/on-the-way (OTB/OTW) emission controls and se rving 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 P rojections for 2009, 2012 and 2018 for NonEGU Point, Area and Nonroad Source in the MANE-V U Region,” Final Report, February 2007.

20 MACTEC Federal Programs, “Identification and Evalu ation of Candidate Control Measures,” Final Technic al Support Document, Ozone Transport Commission, February 28, 2007.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 43



### Estimated emission reductions for New Hampshire fro m the three named control measures are given

in Table 6-3.

Table 6-3. Estimated Emission Reductions from Thre e 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 (OTC guidelines) VOC 4.4

Consumer Products (OTC 2006 Model Rule) VOC 0.3

Source: MACTEC, 2007



### These potential contingency measures are further de scribed in subparts 6.5.1 through 6.5.3, below.

6.5.1 ICI Boilers (at Major Point Sources)

In 2006, the OTC commissioners recommended that the OTC member states pursue “as necessary and appropriate” state-specific rulemakings to establish required em ission reduction percentages, emission rate performance standards, or control tec hnologies 

### to reduce emissions from industrial, commercial, and institutional boilers (OTC Resoluti on 06-02). The approximately 2-ton-per-day reduction in NOx emissions from ICI boilers reporte d in Table 6.3 was based on implementation of

OTC’s recommended control levels on boilers of 25-2 50 MMBtu/hr heat input capacity at major point sources in New Hampshire.

6.5.2 Emulsified Asphalt Paving

NHDES is currently evaluating the proposed continge ncy measure for emulsified asphalt paving. OTC’s guideline would limit the VOC content of emul sified asphalt to 2 percent or less. The VOC content of emulsified asphalt in New Hampshire is a ssumed to be 2.5 percent at present. Thus, the

estimated VOC emission reduction from this source c ategory would be approximately 20 percent during the ozone season.

6.5.3 Consumer Products

The contingency measure for consumer products inclu ded in Table 6-3 would replace the OTC 2001 VOC model rules with the OTC 2006 model rules, whic h provide amendments adopted by the California Air Resources Board (CARB) in July 2005. The amendments revise the existing VOC

limit for contact adhesives and create VOC limits f or nine new source categories (adhesive removers, electrical cleaner, electronic cleaner, f abric refresher, footwear or leather care, graffiti remover, hairstyling products, toilet care, and woo d cleaner). Based on estimates developed by CARB for 2009, these amendments would reduce VOC em issions by about 2 percent.

6.5.4 Additional Controls on Boilers

New Hampshire and the other OTC states have continu ed to investigate the possibility of additional controls on ICI boilers and utility boilers as stat ionary 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 r eport for non-EGU point sources and area sources in New Hampshire. More specifically, recen t OTC proposals being considered by NHDES would provide additional NOx controls on the follow ing boiler categories:Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 44

• 

### Oil- and gas-fired boilers serving EGUs (OTC 2010 M odel Rule) : This proposed rule would impose the following NOx emission limitations on oi l- and gas-fired utility boilers with a nameplate capacity of 25 MW or greater: for gas onl y, 0.08 lb/MMBtu; for oil or oil/gas,

0.15 lb/MMBtu.

• 

### New small natural-gas-fired boilers and water heate rs (OTC 2010 Model Rule) : This proposed

rule would establish NOx emission standards for var ious devices ranging in size from 75,000 to 5,000,000 Btu/hr.

• 

### ICI boilers : Stricter NOx emission standards would be extende d 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 economi c feasibility of enhanced emission controls on ICI

boilers of all sizes. 21 

### A NESCAUM study 22 

### from the same time period examined a variety of technologies available to reduce NOx emissions from ICI boilers with heat input ratings from as low as 10 MMBtu/hr to as high as 1,000 MMBtu/hr. It wa s 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 l arger 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 l ack NOx controls. These units – most of them burning fuel oil – account for more than half of al l NOx emissions from ICI 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 al l of these facts, NHDES anticipates that any reasonable control program for ICI boilers in New H ampshire would be capable of reducing overall NOx emissions from this sector by 25 percent or mor e.

Ongoing state and regional initiatives to control b oiler emissions are overlain by EPA’s proposed or final rules pertaining to National Emission Standar ds for Hazardous Air Pollutants (NESHAP) for industrial, commercial, and institutional (ICI) boi lers 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 subj ect to mandatory new emission limits and/or periodic bo iler tune-ups that would yield direct emission reductions or indirect co-benefits with respect to NOx and VOC control.

6.5.5 Other Contingency Measures

NHDES is evaluating other potential NOx and VOC con trol measures that could be applied, if necessary, to further reduce ozone levels in the ma intenance area. These control measures are listed in Table 6-4 along with the previously mentioned co ntingency measures for boilers, asphalt paving, and consumer products.

21 OTC and LADCO, “Evaluation of Control Options for I ndustrial, Commercial and Institutional (ICI) Boile rs,” Technical Support Document, Final, May 14, 2010.

22 NESCAUM, Applicability and Feasibility of NOx, SO 2 , and PM Emission Control Technologies for Industri al, Commercial, and Institutional (ICI) Boilers , November 2008.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 45



### Table 6-4. Potential Contingency Measures for Redu cing Ozone Levels

Control Measure Source Category

NOx Control Measures

Oil and Gas Boilers Serving EGUs (OTC 2010 Model Ru le) Major Point

New Small Natural-Gas-Fired Boilers and Water Heate rs (OTC 2010 Model Rule) Area*

ICI Boilers Area or 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

VOC Control Measures

Large above-Ground Storage Tanks (OTC 2010 Model Ru le) Major Point

Emulsified and Cutback Asphalt Paving (OTC guidelin es) Area

Adhesives and Sealants Application (OTC 2006 Model Rule) Area

Architectural and Industrial Maintenance Coatings ( OTC 2009 Model Rule) Area

Solvent Cleaning (OTC 2009 Model Rule) Area

Consumer Products (OTC 2006 Model Rule) Area

Consumer Products (OTC 2010 Model Rule) Area

Motor Vehicle and Mobile Equipment Non-Assembly Lin e Coatings Operations (OTC 2009 Model Rule) Area

*Area sources include minor emission sources, typic ally large in number and widely distributed.



### 7. ADMINISTRATIVE DOCUMENTS

In accordance with the requirements for SIP submiss ions established in 40 CFR 51.103, the following documentation is herewith provided as integral to t his redesignation request:

• 

### A formal letter of submittal from the Governor or h is designee, requesting EPA approval of this SIP revision;

• 

### Evidence that NHDES has the necessary legal authori ty under state law to adopt and implement the plan.

• 

### Evidence that public notice was given of the propos ed change consistent with procedures approved by EPA, including the date of publication of such notice.

• 

### Certification that public hearing(s) were held in a ccordance with the information provided in the public notice and the state's laws and constitu tion, if applicable and consistent with the public hearing requirements in 40 CFR 51.102.

• 

### Compilation of public comments and the state's resp onse thereto.

Documentation of legal authority, public notice, ce rtification of the public process, and public comments and responses are provided in Attachment E

.Request for Redesignation of the Boston-Manchester- Portsmouth (SE), NH Nonattainment Area Page 46



### 8. SUMMARY AND CONCLUSIONS

NHDES is requesting redesignation of the Southeast New Hampshire Nonattainment Area from
moderate nonattainment to attainment for the 1997 N ational Ambient Air Quality Standard for 8- hour ozone. Section 107(d)(3)(E) of the Clean Air Act establishes the requirements that an area must meet in order to be considered for redesignati on. The following summarizes how the
nonattainment area meets the essential criteria for redesignation:

• 

### The area has attained the 8-hour ozone standard. All four ozone monitoring sites within the nonattainment area have had ozone design values bel ow the 1997 8-hour ozone standard for each year since 2006 (see Figure 2-4 and Attachment B). In addition, all other ozone monitoring sites throughout the state have shown le vels below this standard.

• 

### The state has an approved/approvable State Implemen tation Plan under CAA Section 110(k). New Hampshire’s approved SIP is published in the Co de of Federal Regulations at 40 CFR 52 Subpart EE. The implementation plan includes re visions to demonstrate attainment of the former 1-hour ozone NAAQS (67 FR 72574, Decembe r 6, 2002) and to meet reasonable further progress requirements for the former standa rd (3 FR 67405, December 7, 1998, and 67 FR 18493, April 16, 2002). Consistent with EPA’ s Clean Data Rule, certain SIP
elements related to attainment of the 8-hour ozone NAAQS, including an attainment demonstration, a reasonable further progress plan, contingency measures, and other plan elements, have been suspended (73 FR 14387, March 1 8, 2008). The approved SIP incorporates rules implementing NOx and VOC RACT re quirements (see Table 4-2).

• 

### The improvement in air quality is due to permanent and enforceable emission reductions resulting from implementation of the SIP and other federal requirements. The vast majority of ozone-causing air pollutants in New Hampshire or iginate from sources in upwind states. Federally mandated programs such as the NOx SIP Cal l have made it possible for groundlevel ozone concentrations in the nonattainment are a to reach attainment levels. Also contributing to local air quality improvements are New Hampshire regulations to control
NOx and VOC emissions from diverse sources. Tables 4-1, 4-2, and 4-3 identify permanent
and enforceable emission control measures that have resulted in statewide attainment for
ozone. Table 4-4 shows the substantial decline in both NOx and VOC emissions from instate sources between 2002 and 2008.

• 

### The state has prepared an approved/approvable maint enance plan under Section 175A. NHDES has prepared the requisite attainment invento ry, maintenance demonstration, and contingency plan, and will continue to operate an a ppropriate air quality monitoring network to assure that the area stays in attainment of the 8-hour ozone standard after redesignation (see 6. MAINTENANCE PLAN 

### ). A comparison of NOx and VOC emission inventorie s for 2008, 2012, and 2022 (Table 6-1) indicates continui ng, substantial emission reductions for both types of ozone precursors in the next decade.

• 

### The state has met all Title I, Part A, Section 110, and Part D requirements for the area

. New Hampshire has satisfied the requirements of Sec tion 110 related to emission reporting and recordkeeping, periodic testing and inspection of emission sources, transportationrelated emission control measures, continuous monit oring and recording, and legal authority and emergency powers. The state has also met Part D requirements for nonattainment areas, providing assurance of future attainment through co ntinued implementation of appropriate emission control and monitoring measures and attent ion to anti-backsliding requirements. (See 5. COMPLIANCE WITH SECTION 110 AND PART D OF THE CLEAN AIR ACT 

### .)

### ATTACHMENT A

Technical Support Document

for

Redesignation of the Boston-Manchester-Portsmouth ( SE), NH 8-Hour Ozone (1997 Standard) Nonattainment Area

### This page intentionally left blank.

# Technical Support Document

for



# Redesignation of the Boston-Manchester-Portsmouth ( SE), NH 8-Hour Ozone (1997 Standard) Nonattainment Area

September 2010



# Air Resources DivisionTSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page i



### Table of Contents

1. INTRODUCTION..................................

................................................... ...................................1

2. NATURE OF OZONE AIR QUALITY PROBLEM IN THE NOR THEAST............................2

2.1 OZONE PRODUCTION .............................

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

2.2 AIR POLLUTION TRANSPORT MECHANISMS........... .................................................2
2.2.1 High-Elevation Transport ...................

................................................... .....................5

2.2.1.1 Aircraft Measurements....................

................................................... ................5
2.2.1.2 Mt. Washington, New Hampshire ............

................................................... ......7

2.2.1.3 Pack Monadnock Mountain – Miller State Pa rk, New Hampshire....................9
2.2.2 Mid-Elevation Transport....................

................................................... ......................9
2.2.3 Low-Elevation Transport ....................

................................................... ................... 10

2.2.3.1 Sea Breeze...............................

................................................... ...................... 10
2.2.3.2 Offshore Transport.......................

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

2.3 THE DEVELOPMENT OF AN OZONE EPISODE.......... ............................................... 12

2.4 NOx vs. VOC CONTROL STRATEGIES EFFECTIVENESS . ....................................... 14

3. ATTAINMENT MODELING ...........................

................................................... ..................... 15

3.1 MODELING METHODOLOGY .........................

................................................... .......... 15

3.1.1 Identification of Models and Domain Used...

................................................... ........ 15
3.1.2 Emissions Processing Methodology ...........

................................................... ........... 17
3.1.3 Meteorology Processing Methodology .........

................................................... ......... 21
3.1.4 Model Testing ..............................

................................................... .......................... 23
3.1.5 Establishing Estimates of Future Design Val ues ................................................ ...... 25

3.2 CMAQ AND CALGRID MODELING RESULTS............ ............................................... 25

3.3 EPA’s CAIR MODELING ..........................

................................................... ................... 28TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page i i



### List of Figures

Figure 2-1 Major Transport Regimes in the Northeast

................................................... ..............3
Figure 2-2 Typical Day/Night Ozone Cycle at Ground Level and Aloft .................................... ..4
Figure 2-3 Number of 8-Hour Ozone Events Exceeding 85 ppb............................................. .....4
Figure 2-4 How Upper-Level Transport Works.........

................................................... ................5
Figure 2-5 Observed Vertical Ozone Profile Measure d Above Poughkeepsie, NY .....................6
Figure 2-6 Aircraft Ozone Observations in the North east ............................................... .............7
Figure 2-7 Comparison of Average and Hourly Summer Ozone Concentrations.........................8
Figure 2-8 Computer Model Illustration of the Low-L evel Jet in the Northeast .......................... 9
Figure 2-9 How the Sea Breeze Works................

................................................... .................... 10
Figure 2-10 Offshore Ozone Measurements from the Sc otia Prince ........................................ .... 12
Figure 2-11 Bermuda High Synoptic Scale Transport ..

................................................... ............. 13
Figure 3-1 Map of the CMAQ/CALGRID Modeling Domain . .................................................. 1 6
Figure 3-2 Map of the RPO National Domain ..........

................................................... ............... 17
Figure 3-3 QA/QC Plot of Surface Source CO Emission s .................................................. ....... 19
Figure 3-4 QA/QC Plot of Surface Source VOC Emissio ns................................................. ...... 19
Figure 3-5 QA/QC Plot of Point Source NOx Emissions

................................................... ........ 20
Figure 3-6 QA/QC Plot of Point Source SO2 Emissions

................................................... ......... 20
Figure 3-7 QA/QC Plot of Humidity Data.............

................................................... .................. 21
Figure 3-8 QA/QC Plot of Temperature Data..........

................................................... ................ 22
Figure 3-9 QA/QC Plot of Rainfall Data .............

................................................... .................... 22
Figure 3-10 Relative Bias between Maximum 8-Hour Oz one Concentrations Predicted

with CALGRID and Observed Values ...................

................................................... 24
Figure 3-11 Comparison of Modeled Maximum 8-Hour Oz one Concentrations ......................... 24
Figure 3-12 CMAQ SIP-Quality Modeling Results for 2 009 OTB/OTW vs. 2002

Design Values......................................

................................................... ................... 27
Figure 3-13 Plot of 2009 Estimated Design Values fo r the OTC 2009 OTB/OTW Strategy....... 27
Figure 3-14 Plot of Differences in Predicted Maximu m 8-Hour Ozone Concentrations

between 2002 Base Case and the OTC 2009 OTB/OTW Str ategy ........................... 28

List of Tables

Table 2-1 Night and Daytime Patterns of Ozone at Mt . Washington....................................... ...8
Table 3-1 Modeling Emissions Inventory: State-by-St ate Anthropogenic NOx ....................... 18
Table 3-2 CMAQ Maximum Modeling Statistics for 2002 Base and 2009 OTB/OTW........... 25
Table 3-3 CALGRID Maximum Modeling Statistics for 2 002 Base, 2009 OTB/OTW,

and 2009 Sensitivity Runs..........................

................................................... ............ 26
Table 3-4 Modeling Summary for New Hampshire Monito rs................................................. .. 26
Table 3-5 CAIR Modeling Results for New Hampshire f or 8-hour Ozone (ppb) ..................... 29TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 1



### 1. INTRODUCTION

This document is provided in support of New Hampshi re’s request to EPA to redesignate the Boston-Manchester-Portsmouth (SE), NH nonattainment area (hereinafter referred to as the Southeast New Hampshire Nonattainment Area) to atta inment status. On June 15, 2004, EPA officially classified this portion of New Hampshire as a moderate nonattainment area for the 1997 8-hour ozone Ambient Air Quality Standard (NAAQS) o f 0.08 parts per million (ppm) ( Federal Register , 69 FR 223857). For several years since this clas sification was made, the Southeast New Hampshire Nonattainment Area has been monitoring at tainment for the 8-hour ozone standard under EPA’s Clean Data Policy. ∗ 

### This nonattainment area is therefore eligible for redesignation to attainment in accordance with the provisions of the Clean Air Act (CAA).

The information presented in this report is present ed in two parts. The following section provides a conceptual description of the formation and transpo rt of ozone in the Northeast. This information is useful in setting the context for New Hampshire's o zone redesignation request. Section 3 discusses a photochemical air quality modeling assessment tha t was undertaken in 2007 by New Hampshire and other Ozone Transport Region states. This mode ling effort was performed in support of states' attainment demonstrations and for other SIP plannin g purposes, and is therefore not a specific component of this redesignation request. Neverthel ess, it is presented here because it supports the conclusion that the improvement in New Hampshire's air quality is due to permanent, enforceable emissions control measures and is not simply an ano maly (due to cooler weather conditions, for example).

∗ Using monitoring data for the period 2002-2007, EP A determined that the Southeast New Hampshire 8-hou r Ozone Nonattainment Area (moderate) had reached attainmen t of the 8-hour ozone NAAQS. A final rule publishe d on March 18, 2008 (73 FR 14387), effective on that date, su spended the requirements for this area to submit an attainment demonstration, a reasonable further progress plan, contingency measures, and other State Implementatio n Plan elements related to attainment of the 8-hour ozone NAAQS. T his determination is consistent with EPA’s Clean Da ta Policy, which exempts the state from certain SIP requirements if the area has three consecutive years of air quality data showing it meets the NAAQS, for as long as the area continues to attain the standard.TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 2



### 2. NATURE OF OZONE AIR QUALITY PROBLEM IN THE NOR THEAST

In order to form an effective ozone reduction plan for the State of New Hampshire, an understanding of ozone formation, source areas, win d patterns, and transport is necessary. The formation and transport of ground level ozone is a complex phenomenon affected by several
variables.

2.1 Ozone Production

Ozone is formed in the atmosphere when NOx combines with VOCs in the presence of sunlight. Consequently, solar energy, mixing conditions, and relative NOx and VOC concentrations within an air mass are paramount to ozone formation.

Typically, high pressure systems cause an air mass to flow downward, a phenomenon which increases ground level ozone concentrations in at l east four ways: 1) the sinking motion of the air mass under high pressures stabilizes the air mass, reducing cloud formation and resulting in an increase in solar energy, thus increasing photochem ical activity; 2) the sinking motion tends to keep locally produced precursor emissions nearer to the surface, thus limiting upward movement and dilution of the air mass; 3) ozone and its precurso rs, present at higher elevations (500 to 1500 meters) as a result of transport, are pushed down t oward the ground; and 4) the sinking air raises the ground level pressure, generating more heat at grou nd level. The result is a greater supply of ozone and precursors at or near ground level, more reacti on energy in the form of heat and sunlight, and relatively limited dilution in the air mass. Addit ionally, the clockwise airflow pattern around a hig h pressure system transports pollutants northward and then eastward from the industrial Midwest or along the Northeast Urban Corridor to New England. These meteorological conditions are typical when New Hampshire monitors elevated levels of grou nd level ozone.

2.2 Air Pollution Transport Mechanisms

The predominant transport patterns in the Northeast were observed and documented in a study conducted by the North American Research Strategy f or Tropospheric Ozone - Northeast (NARSTO/NE) entitled "Initial Results on Transport and Mixing Based on NARSTO-Northeast Data," and dated January 28, 1997. This study iden tified three basic flow regimes: synoptic, channeled, and near surface (Figure 2-1).

• 

### The S ynoptic flow is the pattern of airflow at higher elevations (ab ove 2600 feet). Synoptic flows are unaffected by large-scale frictional grou nd-level objects such as mountains, valleys, and lakes.

• 

### Channeled flows occur at lower elevations (650 to 2600 feet) where synoptic flow patterns are interrupted by large objects such as mountains, hills, and valleys but are not affected by lower, smaller objects such as trees and buildings.

• 

### Low-level jets occur nocturnally along the eastern edge of the Ap palachians. Although they somewhat resemble channeled flow, low-level jets ar e compact, relatively high-speed airflows that occur just above ground level. The s peed of flow is made possible by the compression of converging airflows and the friction less surface caused by the nocturnal thermal inversion, which the jet rides on.

• 

### Near-surface flows (below 650 feet) are affected by nearly all surfac e frictional objects, including trees and buildings.TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 3



### Synoptic flows are generally from west to east, tra nsporting pollution from the Midwest to the Northeast, while channeled flows generally follow t he Appalachian Mountains from southwest to northeast, transporting pollution from the Northeas t urban corridor toward northern New England.

Figure 2-1 - Major Transport Regimes in the Northea st

Absent transport, ground-level ozone concentrations increase during sunlight hours as a result of photochemical production and decrease substantially at night when ozone removal exceeds production (this is also known as diurnal variation or fluctuations within the daily cycle). However, in areas such as New Hampshire, which are downwind of large urban regions, ozone concentrations often rise through the evening and/or early morning hours and peak between 6:00 p.m. and 6:00 a.m. due to transport from upwind sources. At high er elevations, concentrations of ozone and ozone precursors may remain high at night, since there is minimal downward mixing of the atmospheric transport layers at night. During daylight hours w hen solar energy heats the ground, the resulting warm air near the ground begins to rise. Rising ai r creates an unstable atmospheric situation resulting in the upward and downward mixing of air masses (including ozone transport layers). Thus, ground level ozone concentrations typically r ise for several hours immediately after sunrise (Figure 2-2).

**Long-range (synoptic scale) transport occurs from w est to east across the Appalachian**  **Mountains. Regional scale transport in channeled f lows also occurs from west to east through**  **gaps in the Appalachian Mountains and in nocturnal low level jets from southwest to northeast**  **over the Northeast Corridor. Daytime sea breezes c an affect local coastal areas by bringing in**  **air pollution originally transported near the surfa ce across water parallel to the coast (e.g.,**  **along the Maine coastline). Figure from NARSTO, 20 00, citing Blumenthal**  **et al. , 1997.** TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 4

-73.0 -72.0 -71.0 -73.0 -72.0 -71.0

42.0 43.0 44.0 45.0

42.0 43.0 44.0 45.0

LongitudeLatitude 

### for Each Ground-Level Wind Direction (1995 - 2002)

5 6

8

8 13

38 13

41 25

26 Claremont

Keene Laconia

Concord

Manchester

Nashua Rochester Kittery

Portsmouth

Rye - Monitor Meets the 8-Hour Ozone Standard for Health.

- Monitor Does NOT Meet the 8-Hour
Ozone Standard for Health.

Haverhill
0 Conway

1

Miller S.P. Brentwood 7 13

Note: Brentwood starts 1999
Rochester starts 1996 Miller S.P. (elev = 2288') starts 8/2002 **Wind directions at the time unhealthy ozone levels were**  **measured in New Hampshire**
**between 1995 and 2002: There is an overwhelming trend of winds**  **coming into the state from the southwest, with the exception of** 
**the seacoast area which also**
**suffers from a sea breeze that brings pollution from the Boston** 
**metro area to coastline communities. (Numbers indicate**  **the number of unhealthy days.)**

**Source: NHDES** 

### Figure 2-2 - Typical Day/Night Ozone Cycle at Groun d Level and Aloft

NHDES investigated weather conditions that lead to poor air days in the state. Generally, the majority of the ozone transported into the state co mes from the Northeast corridor (Washington, DC, Baltimore, Philadelphia, New York, and Boston r egions) (see Figure 2-3). On certain days, the Boston area provides the greatest amount of ozone a long the immediate New Hampshire seacoast. The non-New England portion of the corridor provide s the majority of the ozone for the remainder of New Hampshire. Air pollution contributions from the Midwest are significant and on some days provide the vast majority of pollution reaching New Hampshire. New Hampshire has its worst air pollution days when low-elevation winds come from t he cities to our southwest (Northeast Corridor) and mid-elevation winds come from the Mid west. The smoggiest days occur when there
is a slow airflow from the Midwest.

Figure 2-3 - Number of 8-Hour Ozone Events Exceedin g 85 ppb and Corresponding Wind Direction (1995-2002) **Solar ultraviolet energy helps to create ozone which is present in high quantities late in the day** 

**. At night, there is no ultraviolet sunlight to creat**  **e ozone and ground level objects and gases act to**  **remove ozone, resulting in the curve in blue, which represents ozone at ground level. Ozone at**  **higher elevations, conversely, is often not depleted at night and may remain at elevated**  **concentrations throughout the day (red curve).**TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 5



### 2.2.1 High-Elevation Transport

Pollution transport should not be thought of only a s a horizontal phenomenon. Pollutants can move upwards in the air and then travel downward in sink ing air currents after being transported over great distances at elevations above 2,500 feet (Fig ure 2-4).

Figure 2-4 - How Upper-Level Transport Works

2.2.1.1 Aircraft Measurements

Measurements several thousand feet above the ground may record much higher ozone overnight than that measured at ground level. For example, ozone aloft concentrations above Poughkeepsie, NY and New Haven, CT approached levels of 120 ppb or great er on the night of July 14 (Zhang & Rao, 1999). Figure 2-5 displays the aircraft measurements above Poughkeepsie, NY around 4 a.m. EST.

Aircraft measurements by the NARSTO-NE during the J uly 1995 ozone episode also demonstrate the existence of significant transport into and wit hin the region, contributing to exceedances of the ozone standard in Maine (Blumenthal et al., 1997). Several "spiral" flights a few thousand feet above Poughkeepsie, NY, Gettysburg, PA, and Shenand oah, VA, recorded ozone levels of 100 ppb or greater in the early morning (4 AM) on two days. One aircraft actually recorded an ozone concentration well above 120 ppb at an elevation of approximately 2600 feet above Poughkeepsie on July 14, 1995, when ground level ozone measured about 30 ppb. Another flight during the early morning of July 14, 1995, from Virginia to Maine re corded ozone levels in the range of 70 to 100 ppb at an elevation of 1600 feet throughout the Nor theast corridor.

These elevated ozone concentrations measured in the early morning at high elevations suggest that the ozone and its precursors originated during the active times of the previous day (or days) and traveled up and away from the source locations. Sp iral flights in the afternoon over the same three New Hampshire NOx
VOC SO 2
PM

Hg



### Pollution

Sources During the heating of the day, pollutants mix upward. Air pollutants get picked up and carried by the

upper level winds Pollutants can

mix down the same way they

came up 

## OVER

UP DOWNTSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 6



### cities, measured uniform ozone levels from ground l evel to 2600 feet, showing that the air had become well mixed during the day and had thus broug ht transported ozone aloft down to the surface. A second flight along the length of the e ntire corridor showed that ozone levels at 1600 fee t had risen well above 120 ppb in the Baltimore-Washi ngton and New York metropolitan areas. Being well above the ground, this ozone was presuma bly destined to be transported further downwind overnight.

Figure 2-5 - Observed Vertical Ozone Profile Measur ed Above Poughkeepsie, NY

at about 4 AM EST on July 14, 1995

On behalf of the Mid-Atlantic Northeast Visibility Union (MANE-VU), additional aircraft measurements were taken to track a regional haze ev ent in the Northeast in August of 2002 (Figure 2-6). The aircraft measured light scattering from particles as well as ozone. Like the earlier NARSTO-NE measurements, the MANE-VU study found hig h levels of ozone aloft which were blowing toward the northeastern states. In most ca ses, the ozone measured aloft exceeded measurements collected at ground level, indicating that the ground-level ozone was not all created locally. It is also noteworthy that the preliminar y measurements collected above Baltimore, MD were already rich in ozone, suggesting that a large amount of the pollutant was blowing into the region from upwind areas. It should be noted that ozone aloft is depleted much more slowly than ozone at ground level, which comes into contact wit h various surfaces and obstructions. This means that, once ozone is present at high elevations, it becomes more likely to travel long distances downwind without breaking down.TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 7



### Figure 2-6 - Aircraft Ozone Observations in the Nor theast

Other aircraft measurements reinforce these observa tions. Clarke and Ching (1983) during the

summer of 1979 recorded aloft ozone concentrations of about 90 ppb transported overnight from eastern Ohio and entering into the Northeast Corrid or over a region stretching from the lower Hudson River Valley north of New York City down acr oss eastern Pennsylvania and into Maryland just west of Baltimore. The measurements also obse rved NOx aloft during the overnight hours that

could contribute to additional ozone formation in t he Ozone Transport Region as it mixed down to the surface in the morning.

The presence of high levels of ozone and precursors aloft across a large spatial region gives rise to the concept of an “ozone reservoir” existing at nig ht just above the nocturnal inversion boundary. The pollutants in this reservoir are not subject to destruction at the surface and can be transported long distances in the wind flows created by the syn optic scale weather patterns conducive to ozone formation and transport.

2.2.1.2 Mt. Washington, New Hampshire

Mt. Washington in Pinkham Notch, New Hampshire, is tall enough (elev. 6288 feet) to reach well up into the upper ozone transport layers with minim al obstruction by other terrain features. Ozone

levels recorded at the summit mirror NARSTO-NE find ings, showing consistently elevated levels of ozone with little diurnal variation during most epi sodes – clear evidence of long range transport. As further evidence of long range transport, Camp Dodg e (elev. 2400 feet), located at the base of Mt. Washington, usually records lower ozone concentrati ons than those seen contemporaneously at the

summit.TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 8

**Comparison of mountaintop (elev. 6288 ft) ozone with**  **mountain base (elev. 2000± ft) hourly ozone: Often the ozone**  **is higher in concentration at the summit due to pollution**  **transport from distant sources. Many times the ozone at the**  **base is driven by downward mixing from the upper transport**  **layers during the day.**

**Source: NHDES (Data: AMC)** 

### Both monitors have no major NOx sources within 75 m iles and no major sources upwind in the direction of prevailing winds for approximately 150 miles. Transport from more distant upwind sources is the primary source of ozone monitored at these sites. Since the summit of Mt. Washington is high enough to be exposed to high ele vation transport (synoptic flows), downward mixing is not a factor in creating the peak ozone v alues it experiences. In fact, transport time from upwind source areas appears to be the single larges t factor in determining the time at which the maximum ozone level occurs at the summit. Daily ma ximum ozone levels at Camp Dodge are dependent on inversion breakup caused by downward m ixing from upper transport elevations, and thus are typically recorded during the afternoon ho urs. On the contrary, maximum ozone levels at the summit occur most often during the overnight ho urs, when no ozone is produced locally. The percent of daily one-hour ozone maxima which occur during the daylight heating hours and during the overnight hours on the summit of Mt. Washington and at Camp Dodge are listed in Table 2-1.

Table 2-1 - Night and Daytime Patterns of Ozone at Mt. Washington

Mt. Washington

Monitor Location Percent of Hourly Maxima During Daylight Hours (9 a.m. to 5 p.m.) Percent of Hourly Maxima During Overnight Hours (6 p.m. to 8 a.m.)



### Summit 18% 82%

Base (Camp Dodge) 80% 20%

Note: Daylight heating hours are hours of the day w hen solar energy drives vertical mixing of transport layers



### The difference in ozone concentrations at the summi t and base can also be seen when looking at plots of maximum ozone levels at each site. The gr aph in Figure 2-7 is typical of summertime ozone at Mount Washington.

Figure 2-7 - Comparison of Average and Hourly Summe r Ozone Concentrations

at the Base and Summit of Mt. WashingtonTSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 9



### 2.2.1.3 Pack Monadnock Mountain – Miller State Pa rk, New Hampshire

A similar mountaintop air pollution monitor was est ablished in 2002 in Miller State Park at the summit of Pack Monadnock Mountain in Peterborough, NH (elevation 2288 feet). The mountain is located in the south-central portion of New Hampshi re in an ideal location to track air pollution transport into the state. The monitor is only a sh ort distance from the heavily visited and hiked Mt. Monadnock. The early findings from this monitor ar e similar to those of Mt. Washington in that
when an ozone or PM 2.5 

### episode begins to build into the region, it is dete cted at higher elevations first where the stronger transport currents are loc ated. The new Miller State Park monitor has been useful in tracking air pollution events entering th e populated Merrimack Valley area (Nashua, Manchester, and Concord).

2.2.2 Mid-Elevation Transport

Mid-elevation transport is usually dominated by the effects of large topographical features, such as mountains, which redirect airflows and cause a chan neling of the wind. In the Northeast, channeled airflows may occur on either side (east or west) of the Appalachian Mountain range and also between the subranges that comprise the Appalachian chain. Unhealthy air quality can be present on one side of a mountain while just a few miles aw ay on the other side, the air quality is substantially cleaner. This mid-layer is generally heavily influenced by the airshed layers above and below that mix polluted, or clean air into it. Pol lutants can also be injected directly into this lay er by some of the very tall smoke stacks (around 1000 fee t tall) commonly found in the Midwest.

Mid-level transport is often affected by a phenomen on known as the low-level jet (LLJ). It is called
“low-level” because it is lower relative to the wel l known Jet Stream, a high elevation airflow that drives the movement of weather systems around the w orld. Recent advances in remote sensing instruments (i.e., radar profilers) have allowed th e LLJ phenomena to be observed. During the overnight and early morning hours, a LLJ frequently forms just east of the Appalachian Mountains. Once formed, the LLJ is a strong west to southwest wind flow that develops at low altitudes just above the nocturnal boundary layer. These winds ty pically reach speeds of 40-50 mph and are located at approximately 1,000-2,000 feet above the ground. Figure 2-8 depicts the LLJ observed during an August 2002 ozone event.

Figure 2-8 - Computer Model Illustration of the Low -Level Jet in the Northeast

9:00 PM 11:00 PM 01:00 AM

03:00 AM 05:00 AM 07:00 AM **The low level jet (shown in red, orange,**  **and yellow) normally sets up along the** 
**eastern side of the Appalachian Mountains** 
**and flows from**
**southwest to northeast.**

**Source: University of Maryland** TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 1 0



### 2.2.3 Low-Elevation Transport

A number of one-day and multi-day transport mechani sms have been observed along the northeastern coastal plain. Blumenthal et al., (19 97) described several transport mechanisms, including near-surface flows that act within a thou sand feet of the ground and are capable of transporting ozone and its precursors along the urb an corridor as far as 160 miles during the daylight hours. Near surface flows are especially useful in explaining the transport and presence of the
elevated ozone concentrations monitored aboard the MS Scotia Prince in the Gulf of Maine (Portland, Maine ferry to Yarmouth, Nova Scotia, Ca nada).

Other transport mechanisms, including boundary laye r synoptic (upper level) flows and channeled (mid-level) nighttime flows are capable of transpor ting ozone and precursors as far as 600 km in a 24-hour period and are responsible for longer range transport from the south and west (Blumenthal et al., 1997).

Residence time (or the time a pollutant stays in th e air) analysis (Wishinski and Poirot, 1995) is a technique whereby the spatial characteristics of lo ng-term trajectory climatology can be analyzed by keeping track of the residence time (in hours) for selected back trajectories. This was done for several New England sites during the summers from 1 989 through 1995. Back trajectories from Port Clyde, Maine show that for days on which Maine exceeds the ozone national ambient air quality standard (NAAQS), the wind is invariably fr om the south and west. These trajectories also show that the Northeastern Corridor is principally responsible for nonattainment in New Hampshire and Maine, with areas to the south and west of the Corridor having lesser, but still significant impac ts.

2.2.3.1 Sea Breeze

The Atlantic Ocean produces changes in wind directi ons and wind speeds along the shoreline, especially in New England. While most inland areas experience regional wind patterns with only
small variations due to terrain features and other frictional effects, coastal locations are far more variable. Sea breezes develop during the heating o f the day when the ground heats up, warming the onshore air mass. This air mass then rises, causin g cooler air near the surface to flow in from over the ocean (Figure 2-9). Sea breezes are actually a subset of the NARSTO-NE near-surface flows that are driven by temperature differences between land and water, which also affects changes in mixing heights. Daytime sea breezes flow from the relatively cool waters of the ocean towards the coast, and diminish over a short distance due to mi xing with regional wind patterns persisting further inland and with diurnal mixing.

Figure 2-9 - How the Sea Breeze Works

**The sea breeze is developed through the temperature** 
**differences between the ground and the water. As the**  **sun warms the ground, it begins a cycle by causing the** 
**air to rise. This air cools as it moves over the water, sinks** 
**and then blows back towards**
**the shore.**TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 1 1



### Onshore breezes are the primary reason that high oz one concentrations occur along the New Hampshire coast, while substantially lower concentr ations are recorded just a few miles farther
inland. The afternoon sea breeze shifts the wind d irection to the south and east, bringing ozone from over the ocean onshore. As documented by the NHDES and the Maine Department of Environmental Protection, these sea breezes develop suddenly and can drive ozone concentrations sharply upward. The offshore ozone blown in by sea breezes appears to originate from precursors emitted in the metropolitan Boston area.

2.2.3.2 Offshore Transport

Offshore, just beyond the strongest coastal sea bre ezes, larger scale wind fields develop that may differ in direction from the inland regional wind p attern. Lower mixing heights, differing temperature gradients, and lower frictional effects cause this differential. Off the New Hampshire and Maine coasts (Figure 2-10), it is not uncommon for the over-water wind field to come from the south, while the inland regional wind field is more from the southwest. This pattern allows transport of the ozone plume from the metropolitan Boston are a to travel over the Gulf of Maine to the New Hampshire coast, even when inland wind observations suggest this should not be happening.

The North Atlantic Regional Experiment (NARE) measu red surface level ozone and precursor
concentrations at both coastal and offshore locatio ns in the Gulf of Maine during August and September of 1993 (Ray et al., 1996). The research ers observed ozone plumes in the Gulf of Maine ranging in width from 55 to 93 km and extending the entire length of the New Hampshire and Maine coastlines. The timing of the observed peak ozone concentrations, the presence of elevated ozone levels only along the coast, and low NOx conc entrations all suggest that urban plumes transported over the Gulf of Maine are brought inla nd by sea breezes to the coastal regions, and that regional control strategies will be needed to reduc e ozone concentrations along the coast.

Recent photochemical modeling utilizing the Califor nia Photochemical Grid Model (CALGRID) model (Earth Tech, 2006) serves to confirm the pres ence of an urban plume moving northeastward over the Gulf of Maine, where it is then carried by afternoon sea breezes to the coast.

Along the New Hampshire and Maine coastlines, ozone levels have not been observed to exceed the NAAQS unless there is at least a moderate westerly to southwesterly wind at the surface. Typical ozone episodes are characterized by the concentrati on of transported ozone and precursors in the Gulf of Maine during the morning and mid-day hours, with afternoon sea breezes bringing high
concentrations of ozone ashore in the afternoon and evening. Monitored ozone concentration data
and measured wind vectors show ozone exceedances in Maine and New Hampshire to be the direct result of a large mass of both ozone and unreacted precursors being transported into the Gulf of Maine from areas to the south and west. Here, prec ursors react and are then transported ashore, a conclusion supported by data collected by monitors on both the MS Scotia Prince (see Figure 2-10)
in the Gulf of Maine and on land-based monitors tha t show significantly decreased levels of ozone at inland sites (AIRS).

Ozone air quality monitors within Maine and New Ham pshire also confirm the presence and significance of transported ozone and its precursor s. The ozone monitoring network in Maine extends along the coast from the photochemical asse ssment monitoring station (PAMS) located in Kittery, Maine (operated by the State of New Hampsh ire Department of Environmental Services) to
as far north as Bar Harbor. Maximum ozone concentr ations along the Maine coast almost always follow a sequential pattern, with the most southerl y sites monitoring daily ozone maximums in theTSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 1 2



### mid to late afternoon, and downwind sites experienc ing maximum readings later in the day and into the evening hours.

Figure 2-10 - Offshore Ozone Measurements from the Scotia Prince

SCOTIA PRINCE FERRY (86ppb)

KENNEBUNKPORT (67 ppb)

KITTERY (72 ppb) PORT CLYDE (78ppb)

CAPE ELIZABETH (57 ppb) REID STATE PARK (78 ppb) MCFARLAND HILL (47 ppb)

CADILLAC MTN (46 ppb)

GARDINER (39 ppb)

WEST BUXTON (37 ppb) NORTH LOVELL 35 ppb) RCIP (MM) HOLDEN (43 ppb)



## 49 70 98 102 87 90 87 82 75 73

JULY 9, 2002 CASTINE (42ppb)

BUOY 44013

WD 220-250 WS 3-5m/s BUOY IOSN3

WD 230-260 WS 3-11 m/s BUOY 44005

Wind Direction 220-240

Wind Speed 3-7 m/s 850mb270 deg @ 35 kts 925mb 250 deg @ 25 kts



### HOURLY OZONE CONCENTRATIONS ON THE

SCOTIA PRINCE FERRY (Maximum 8-hr Ozone Level)



### 2.3 The Development of an Ozone Episode

Since the late 1970s, a wealth of information has b een collected concerning the regional nature of the Northeast’s ground-level ozone air quality prob lem. Scientific studies have uncovered a rich complexity in the interaction of meteorology and to pography with ozone formation and transport. The evolution of severe ozone episodes in the easte rn U.S. often begins with the passage of a large high pressure area from the Midwest to the middle o r southern Atlantic states, where it assimilates into and becomes an extension of the Atlantic (Berm uda) high pressure system (see example in Figure 2-11). During its passage east, the air mas s accumulates air pollutants emitted by large coalfired power plants and other sources located outsid e the region. These expansive weather systems favor the formation of ozone by creating a vast are a of clear skies and high temperatures. These two prerequisites for abundant ozone formation are furt her compounded by a circulation pattern favorable for pollution transport over large distan ces. In the worst cases, the high pressure systems stall over the eastern United States for days, crea ting ozone episodes of strong intensity and long
duration. **The Scotia Prince ferry is a scheduled passenger an d vehicle ferry that runs between Portland, Maine,**  **and Yarmouth, Nova Scotia, Canada. This ferry has an o**  **zone monitor that tracks air pollution levels durin g its**  **journey between ports. The ferry often identifies distinct air pollution areas or plumes offshore ove**  **r the Gulf**
**of Maine. Source: MEDEP** TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 1 3



### Figure 2-11 - Bermuda High Synoptic Scale Transport

With the knowledge of the different transport scale s into and within the region, a conceptual picture of bad ozone days emerges. After sunset, the groun d cools faster than the air above it, creating a nocturnal temperature inversion. This stable bound ary layer extends from the ground to only a few hundred meters in altitude. Above this layer, a no cturnal low level jet can form with higher velocity winds relative to the surrounding air. It forms fr om the fairly abrupt removal of frictional forces induced by the ground that would otherwise slow the wind. Absent this friction, winds at this height are free to accelerate, forming the nocturnal low l evel jet. Ozone above the stable nocturnal inversion layer is likewise cut off from the ground , and thus it is not subject to removal on surfaces
or chemical destruction from low level emissions. Ozone in high concentrations can be entrained in the nocturnal low level jet and transported several hundred kilometers downwind overnight. The next morning as the sun heats the Earth’s surface, the nocturnal boundary layer begins to break up, and the ozone transported overnight mixes down to t he surface where concentrations rise rapidly, partly from mixing and partly from ozone generated locally. By the afternoon, abundant sunshine combined with warm temperatures promotes additional photochemical production of ozone from local emissions. As a result, ozone concentrations reach their maximum levels through the combined effects of local and transported pollution

.

Ozone moving over water is, like ozone aloft, isola ted from destructive forces. When ozone gets transported into coastal regions by bay, lake, and sea breezes arising from afternoon temperature contrasts between the land and water, it can arrive highly concentrated.



# HTSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 1 4



### During severe ozone episodes associated with high p ressure systems, these multiple transport features are embedded within a large ozone reservoi r arriving from source regions to the south and west of the OTR. Thus a severe ozone episode can c ontain elements of long range air pollution transport from outside the Northeast, regional scal e transport within the OTR from channeled flows in nocturnal low level jets, and local transport al ong coastal shores due to bay, lake, and sea breeze s.

The recognition that ground-level ozone in the east ern United States is a regional problem requiring a regional solution marks one of the greatest advan ces in air quality management in the United States. During the 1990s, air quality planners beg an developing and implementing coordinated regional and local control strategies for NOx and V OC emissions that went beyond the previous emphasis on urban-only measures. These measures ha ve resulted in significant improvements in air quality across the OTR. Measured NOx emissions and ambient concentrations have dropped between 1997 and 2005, and the frequency and magnit ude of ozone exceedances have declined

within the OTR.

2.4 NOx vs. VOC Control Strategies Effectiveness

The effectiveness of a NOx-focused or VOC-focused c ontrol strategy to reduce ozone is not constant by location; rather, it is a changing chem ical characteristic of an air parcel affecting a particular location. As a result, the effectivenes s of a NOx or VOC-focused control strategy can vary within an air parcel as it dynamically evolves over time with transport, dispersion, and photochemical aging (NARSTO, 2000).

On a regional basis, OTAG (Ozone Transport Assessme nt Group), Clean Air Interstate Rule (CAIR), and other modeling studies have consistentl y shown that NOx reductions have the greatest impact on regional ozone concentrations, while VOC reductions have more local impacts. This is largely a result of significant naturally occurring VOC emissions (especially isoprene) in large forested regions of the eastern U.S. Real-world res ults from regional NOx reductions at power plants (i.e., the NOx SIP Call) are now indicating that significant ozone reductions are occurring on a regional basis as a result of regional NOx strate gies.

As a general rule, VOC reductions may be effective at reducing urban-scale ozone pollution in lieu of or in combination with local NOx reductions, whi le regional NOx controls are most effective at reducing regional ozone. While a general approach can be outlined in evaluating the potential

effectiveness of NOx and VOC-focused control strate gies, the optimal strategy for a specific location will depend on the particular circumstance s of that location. Exceptions to a VOC-only strategy for an urban area can occur when the urban area has large natural VOC emissions, ozone is transported from upwind, or there is recirculation of aged local pollution (e.g., sea breeze effect).

Furthermore, because the conditions causing individ ual ozone episodes can vary, a given urban area may change in sensitivity between a NOx and VOC-foc used strategy depending on a particular episode’s conditions (NARSTO, 2000). Therefore, th e appropriate combination of NOx and VOC controls at the local level depends on local circum stances with the realization that a single approach focusing on NOx- or VOC-only controls is not necess arily effective for all episode types. It is clear

, however, that regional NOx reductions provide regio nal ozone reductions, and this will influence ozone levels being transported into local urban are as. Thus, the most effective controls for New Hampshire are NOx based regional controls with loca l NOx and VOC based controls.TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 1 5



### 3. ATTAINMENT MODELING

Air quality modeling to demonstrate New Hampshire’s attainment of the 8-hour ozone standard uses a regional photochemical modeling platform capable of estimating the distribution and magnitude of air pollutant concentrations within a reasonable ra nge of error. Base-year and projected future year emissions inventories are used as input into the ai r quality model. Emission reduction strategies are applied as needed. The results of the air quality modeling are applied in a relative sense by calculating the percent ratio of the future year mo deling results (which reflect the emissions reduction strategies) to the base-year modeling res ults. This ratio is then applied to the observed base year design value to obtain a corresponding es timated future year design value. Known as the relative reduction factor (RRF) technique, this met hod follows EPA guidance; for further description see Section 3.1.5.

3.1 Modeling Methodology

For the 8-hour ozone analyses, New Hampshire relied on the regional photochemical air quality modeling that was conducted by the New York State D epartment of Environmental Conservation (NYSDEC) and other modeling centers on the Communit y Multiscale Air Quality (CMAQ) modeling platform. In addition, New Hampshire and other states used the California Photochemical Grid Model (CALGRID) screening-level modeling platf orm to evaluate additional emissions control scenarios and perform sensitivity runs. The genera l methodologies that were used in running both of these modeling platforms for the evaluation of 8 -hour ozone are described in the sections below.

3.1.1 Identification of Models and Domain Used

The SIP-quality modeling that was done for the 8-ho ur ozone analyses was performed on the CMAQ modeling platform. Additional modeling was do ne on the CALGRID screening-level platform. The CMAQ and CALGRID platforms were run on the same modeling domain using a common set of model inputs. Specifically, the OTC ozone modeling domain was set up on a Lambert Conic Conformal projection and covers the e astern United States and parts of Canada. The southwest corner of the domain was set at 264 km, - 888 km and the northeast corner was set to 2328 km, 1176 km. A 12-km grid cell resolution was used with 172 grid cells in the east-west direction and 172 grid cells in the north-south direction. F or the vertical grid definition, 22 layers were use d in the CMAQ simulations. For CALGRID, processing p rograms were used to reformat the boundary conditions, meteorology, and emissions; th ese mapped the 22 layers used for CMAQ to a total of nine vertical layers for the CALGRID model ing. The OTC CMAQ/CALGRID modeling domain is shown in Figure 3-1. The OTC 12-km ozone modeling domain is a subset of the 36-km national domain which was used by the Regional Plan ning Organizations (RPOs) for regional haze analysis. The 36-km national grid is shown in Figu re 3-2.

For the CMAQ modeling, boundary conditions were der ived from GEOS-Chem (Goddard Earth Observing System) global atmospheric simulations by running CMAQ on the 36-km continental grid. For the CALGRID platform, initial conditions , side boundary conditions, and top layer concentrations were derived from the CMAQ boundary conditions files by means of a processing program. This program mapped the 22 vertical layer s used in the CMAQ simulations to the nine layers used with CALGRID. It produced the necessar y side boundary file and top layer concentration file for each modeled episode day. I t also produced an initial conditions file for each episode day processed; these files could be retaine d so that the CALGRID user could begin aTSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 1 6



### simulation on any desired episode day. It should b e noted that the default option of using 2002 boundary conditions was employed for all of the bas e case and future year CMAQ and CALGRID

simulations.

Further details regarding the technical options use d in the CMAQ simulations are available in NYSDEC’s technical support document TSD-1d, 8hr Ozone Modeling using the SMOKE/CMAQ

system , February 1, 2006. Additional information on the CALGRID modeling platform can be

found in NHDES’ Modeling Protocol for the OTC CALGRID Screening-Lev el Modeling Platform for the Evaluation of Ozone , May 23, 2007.

Figure 3-1 - Map of the CMAQ/CALGRID Modeling Domai n



## 0 20 40 60 80 100 120 140 160 0 20 40 60 80 100 120 140 160TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 1 7



### Figure 3-2 - Map of the RPO National Domain

3.1.2 Emissions Processing Methodology

The base year and future year emissions inventories that were used in the regional photochemical air quality modeling for the 8-hour ozone analyses were prepared by the RPOs and their contractors. These inventories were processed for input into the CMAQ air quality model using the Sparse Matrix Operator Kernel Emissions (SMOKE) model. Th e SMOKE modeling was performed by NYSDEC and other modeling centers, including NESCAU M and the Virginia Department of Environmental Quality (VADEQ). Emissions processin g was done for the 2002 Base Year and 2009 On The Books/On The Way (OTB/OTW) modeling sce nario. The OTB/OTW scenario

accounted for those emissions control measures that were either on the books or reasonably anticipated to occur. The 2002 Base Year and 2009 OTB/OTW emissions are summarized by state in Table 3-1. Further details on the SMOKE process ing that was done in support of the 8-hour ozone analyses are provided in NYSDEC’s technical s upport document TSD-1c, Emission Processing for the Revised 2002 OTC Regional and Ur ban 12 km Base Case Simulations

, September 19, 2006.TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 1 8



### Table 3-1 - Modeling Emissions Inventory: State-by- State Anthropogenic NOx

State 2002

Baseline (tons/day) 2009

OTW/OTB (tons/day) Percent Reduction

from 2002 Baseline

Connecticut 232.16 149.41 35.64%

Delaware 101.20 91.53 9.56%

D.C. 29.13 18.30 37.18%

Maine 170.64 109.75 35.68% Maryland 548.58 312.77 42.99%

Massachusetts 483.18 312.68 35.29% New Hampshire 131.02 84.22 35.72% New Jersey 625.68 397.32 36.50%

New York 1199.32 831.85 30.64%
Pennsylvania 1614.24 1020.05 36.81%

Rhode Island 89.78 57.60 35.84%

Vermont 54.44 34.62 36.41% Virginia 975.74 673.39 30.99%

Alabama 732.86 492.41 32.81%

Arkansas 519.30 268.22 48.35% Georgia 1153.90 874.75 24.19% Kentucky 1043.23 641.29 38.53%

Illinois 1797.25 1067.17 40.62%

Indiana 1329.23 926.42 30.30% Michigan 902.07 812.06 9.98% Mississippi 356.48 271.04 23.97%

Missouri 733.00 438.76 40.14%

North Carolina 1141.21 744.30 34.78%

Ohio 1379.28 848.93 38.45%

South Carolina 660.35 481.35 27.11%

Tennessee 1045.52 710.79 32.02% West Virginia 902.95 432.65 52.08%

Wisconsin 667.49 447.50 32.96%



### For the CALGRID modeling effort, the pre-merged SMO KE emissions files were obtained from the modeling centers and re-formatted for input into EM SPROC, the emissions pre-processor for the CALGRID modeling system. EMSPROC allows the CALGRI D user to adjust emissions temporally, geographically, and by emissions catego ry for control strategy analysis. The pre-merged SMOKE files that were obtained from the modeling ce nters were broken down into the biogenic, point, area, non-road, and on-road emissions catego ries. These files by component were then converted for use with EMSPROC, thus giving CALGRID users the flexibility to analyze a wide variety of emissions control strategies. QA/QC plo ts were generated during the re-formatting of the emissions data to ensure that an accurate modeling inventory was generated for the CALGRID platform. Example emissions QA/QC plots are shown in Figures 3-3 through 3-6.TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 1 9



### Figure 3-3 - QA/QC Plot of Surface Source CO Emissi ons

Figure 3-4 - QA/QC Plot of Surface Source VOC Emiss ionsTSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 2 0



### Figure 3-5 - QA/QC Plot of Point Source NOx Emissio ns

Figure 3-6 - QA/QC Plot of Point Source SO 2 

### EmissionsTSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 2 1



### 3.1.3 Meteorology Processing Methodology

The meteorological modeling that was done for the C MAQ platform was performed by the University of Maryland (UMD) in conjunction with st aff at NYSDEC. UMD used the Penn State/National Center for Atmospheric Research (NCA R) 5 th 

### Generation Mesoscale Model (MM5) Version 3.6 to generate year 2002 meteorological in puts. The MM5 modeling domain was set up on a two-way nested grid that followed the RPO nationa l domain. The 36-km coarse mesh grid consisted of 149 grid cells in the east-west direct ion and 129 grid cells in the north-south direction

. The 12-km fine mesh grid consisted of 175 grid cell s in both the east-west and north-south directions. A total of 29 vertical layers were use d in the MM5 simulations. An extensive analysis was undertaken to compare the MM5 predictions with observations for the period of May through September 2002. An assessment was made to compare MM5 outputs with surface observations from the National Weather Service and CASTNet, wind -profiler measurements from the Cooperative Agency Profilers (CAP) network, satelli te cloud image data from the UMD Department of Atmospheric and Oceanic Science, and precipitati on data from the Earth Observing Laboratory at NCAR. Technical details regarding the 2002 MM5 sim ulations and the assessment to compare

them with observations are described in NYSDEC’s Te chnical Support Document TSD-1a, Meteorological Modeling Using Penn State/NCAR 5 th 

### Generation Mesoscale Model (MM5), February 1, 2006.

For the CALGRID modeling platform, a processing pro gram was used to interpolate the MM5 outputs to the CALGRID modeling grid and map them t o CALGRID’s vertical layer structure. QA/QC plots were generated during the processing to ensure the accuracy of the interpolated data. Figures 3-7 through 3-9 show example QA/QC plots fr om the re-formatting of the meteorological data for use with the CALGRID modeling platform.

Figure 3-7 - QA/QC Plot of Humidity Data

August 6, 2002 Hour 12 Humidity Layer 1

CALGRID 2.45 Modeling Domain

Humidity (ppm)

NHDES
7/18/06

400 600 800 1000 1200 1400 1600 1800 2000 2200

LCC Easting (km) -800 -600 -400 -200 0 200 400 600 800 1000LCC Northing (km)

0 2000 4000 6000 8000 10000 12000 14000 16000 18000 20000 22000 24000 26000 28000 30000TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 2 2



### Figure 3-8 - QA/QC Plot of Temperature Data

August 6, 2002 Hour 18 Temperature Layer 1

CALGRID 2.45 Modeling Domain

Temp (K)

NHDES
7/23/06

400 600 800 1000 1200 1400 1600 1800 2000 2200

LCC Easting (km) -800 -600 -400 -200 0 200 400 600 800 1000LCC Northing (km)

0 280 282 284 286 290 292 294 296 298 300 302 304 306 308 310



### Figure 3-9 - QA/QC Plot of Rainfall Data

August 12, 2002 Hour 17

Rain

CALGRID 2.45 Modeling Domain

Rain (inches)

NHDES
7/17/06

400 600 800 1000 1200 1400 1600 1800 2000 2200

LCC Easting (km) -800 -600 -400 -200 0 200 400 600 800 1000LCC Northing (km)

0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0 1.1 1.2 1.3 1.4 1.5TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 2 3



### 3.1.4 Model Testing

NYSDEC did an extensive quantitative analysis to ev aluate predicted concentrations of ozone, as well as other gaseous and aerosol pollutants, again st 2002 observations. This work is described in their technical support document TSD-1e, CMAQ Model Performance and Assessment, 8-Hr OTC Ozone Modeling , February 23, 2006. The authors used a wide varie ty of statistical metrics to assess the correlation of model predictions and observatio ns, including:

• 

### Correlation coefficient

• 

### Normalized mean error

• 

### Root mean square error

• 

### Fractional error

• 

### Mean absolute gross error

• 

### Mean normalized gross error

• 

### Mean bias

• 

### Mean normalized bias

• 

### Mean fractionalized bias

• 

### Normalized mean bias

NYSDEC also evaluated the diurnal patterns for thos e pollutant species that are reported hourly. With respect to 8-hour ozone, NYSDEC’s model perfor mance evaluation showed that the CMAQ model performed reasonably and that it adequately r eproduced the pattern of observations, especially in urban areas and along the northeast c orridor. Their analysis showed some model under-prediction during the mid-August period. The ir analysis also showed that the diurnal predictions for ozone tracked fairly well with obse rvations. Detailed tables and figures illustrating the CMAQ modeling platform’s performance evaluation are shown in NYSDEC’s technical support

document TSD-1e.

NHDES performed a qualitative and quantitative asse ssment of the CALGRID screening platform’s ability to reproduce observed ozone concentrations. To assess its performance, the CALGRID screening platform was run for the 2002 Base Case f or the July 31 to August 16, 2002 modeling episode. Predicted maximum 8-hour ozone concentrat ions at monitor locations were compared against observations for 2002. Figure 3-10 shows t he relative bias between maximum 8-hour ozone observations and predicted CALGRID 8-hour ozone con centrations for the 2002 Base Case for the episode from July 30 through August 12. Figure 3-1 1 shows a plot of predicted 2002 Base Case ozone concentrations against 2002 observations for an example episode day. Although the CALGRID model has a tendency to over-predict, espec ially in the urban core areas of northern Virginia, Maryland, southeastern Pennsylvania, New York City and Boston, it does a reasonable job of reproducing the pattern of the 2002 maximum ozon e observations.TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 2 4



### Figure 3-10 - Relative Bias between Maximum 8-Hour Ozone Concentrations Predicted with

CALGRID and Observed Values



## Relative Bias (CALGRID minus Observed)

-20 to -15

-15 to -10

-10 to -5

-5 to -2

-2 to 2

2 to 5

5 to 10

10 to 15

15 to 20

20 to 50 Based on Model Data for July 30 - August 12, 2002 2002 Base Case Emissions versus Observed Data

Green Circles are where CALGRID Underpredicts

Red Triangles are where CALGRID Overpredicts

NHDES 11/21/06



### Figure 3-11 - Comparison of Modeled Maximum 8-Hour Ozone Concentrations for August 13, 2002

Maximum 8-Hour Ozone Concentrations
CALGRID - 2002 Base Case
OTC Modeling Domain - August 13, 2002

Ozone
Concentrations (PPB)

NHDES
11/27/06 0 to 40

40 to 50

50 to 60

60 to 70

70 to 80

80 to 90

90 to 100

100 to 150TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 2 5



### 3.1.5 Establishing Estimates of Future Design Val ues

In accordance with EPA guidance, future design valu es for regional modeling were estimated using the relative reduction factor (RRF) technique. Thi s technique uses a statistically valid number of before-and-after modeling results for each monitori ng location to calculate the RRF. Briefly, RRFs were calculated from the average strategy model pre dicted concentration divided by the average base model predicted concentration for the same gri d cell location. This calculation was performed for the full ozone season (for CMAQ). A shorter, b ut representative period of time was used in some CALGRID modeling cases after proving to provid e valid estimates based on comparisons to similar modeling for the full ozone period. In mos t cases, the RRF is less than 1.0, indicating that the emission control strategy lowers the future des ign value. In order to relate model predictions to monitored values, the grid cells and actual monitor geographic locations must be paired. This was performed according to EPA guidance by using the ma ximum value of the block of the nearest 9 grid cells to each monitor location as it is overla id on the modeling grid. The resulting RRF is then multiplied by the corresponding base 3-cycle (2000- 2002, 2001-2003, 2002-2004) average design

value for each monitor to calculate an estimated fu ture year design value for comparison to the NAAQS.



### 3.2 CMAQ and CALGRID Modeling Results

Statistical summaries of peak 8-hour ozone concentr ation for each CMAQ and CALGRID model run are provided below in Tables 3-2 and 3-3. Thes e results reflect the July 31 to August 16, 2002, modeling episode (the model was run for July 30 to August 16, but July 30 is considered to be a model warm-up day). Included in the summary tables are peak modeled ozone concentrations for five New Hampshire monitoring locations that routin ely record elevated ozone levels (Keene, Manchester, Nashua, Portsmouth and Rye) and a more general statistic, “Grid Cell Hours” (Table 3-3), providing a dynamic domain-wide response to e mission reductions. Model predicted ozone concentrations at the five New Hampshire locations are averages of a 9-grid cell area surrounding each of the monitor locations (note that these are the absolute model-predicted concentrations and not the RRF-processed estimated future year design values used to determine future attainment – these values can be found in Table 3-4 below).

In all, there are 29,584 grid cells in the modeling domain (172 x 172). “Grid Cell Hours” is a count of the number of grid cells exceeding the indicated thresholds (80 ppb, 100 ppb, and 120 ppb) in a given hour. This value is presented in order to sh ow the depth of ozone exposure and how it improves under various emission reduction strategie s. The maximum grid cell hour count possible is 710,016 for the full domain over a 24-hour day ( 172 x 172 x 24), although due to nighttime hours and geographically distinct areas within the domain , maximum expected Grid Cell Hour counts is about 400,000.

Table 3-2 - CMAQ Maximum Modeling Statistics for 20 02 Base and 2009 OTB/OTW

Peak 8-Hour Ozone Concentration (ppb) CMAQ Run Keene Manchester Nashua Portsmouth Rye

2002 Base Case 85 79 87 133 133

2009 OTW/OTB 73 68 74 114 114TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 2 6



### Table 3-3 - CALGRID Maximum Modeling Statistics for 2002 Base, 2009 OTB/OTW, and 2009 Sensitivity Runs

Peak 8-Hour Ozone Concentration (ppb) Grid Cell Hou rs CALGRID Run Keene Manchester Nashua Portsmouth Rye >70ppb >85pp b >100ppb



### 2002 Base Case 89 100 102 130 130 86,751 30,576 8,2 66

2009 OTW/OTB 79 92 93 124 124 56,234 15,444 3,447

2009 NH Zero-Out 77 85 95 119 119 55,686 15,307 3,4 41

2009 90% NOx

Reduction 42 49 47 62 62 40 0 0

2009 90% VOC

Reduction 79 93 94 120 120 55,643 15,540 3,325

Note: Grid cell hours are based on the full modelin g domain.



### Table 3-4 summarizes the modeling results for New H ampshire by listing current design values and 2009 modeled design values for all monitors in the state.

Table 3-4 - Modeling Summary for New Hampshire Moni tors

8-hour Ozone Design Values (ppb)

Predicted Design Value (DVF)

AIRS ID Name Current Design Value (DVC) 2009

OTB/OTW (CMAQ) 2009

OTB/OTW (CALGRID)

330012004 Laconia 76.5 nc 66

330031002 Conway 67 nc 61

330050007 Keene 74.3 64 68

330090008 Haverhill 70.3 nc 64

330110020 Manchester 75.5 na 70

330111010 Nashua 86 74 80
330115001 Peterborough 84 73 73

330130007 Concord 74.7 nc 66
330150012 Rye 83.5 72 78

330150013 Brentwood 80 68 72

330150015 Portsmouth 68 59 63

330173002 Rochester 78.5 67 73

330190003 Claremont 74.3 nc 67

Notes:
1. “nc” indicates that a future design value was n ot calculated because of the limitation of the relative reduction factor (RRF) methodology.

2. The Manchester monitor was not included in the CMAQ results; this is indicated by “na” in

the table.TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 2 7



### The figures below show the geographical distributio n of 8-hour ozone design values for the 2002

Base Case and 2009 OTB/OTW scenario for ozone monit or locations in the Ozone Transport Region. Figure 3-12 displays the CMAQ-predicted 20 09 design values versus the actual 2002 design values. For comparison, Figure 3-13 shows C ALGRID-predicted design values for the 2009

OTB/OTW scenario.

Figure 3-12 - CMAQ SIP-Quality Modeling Results for 2009 OTB/OTW vs. 2002 Design Values

Figure 3-13 - Plot of 2009 Estimated Design Values for the OTC 2009 OTB/OTW Strategy

EPISODES July 7 - 23, 2002 July 31 - August 16, 2002

DESIGN VALUES (Revised 2/23/07) Average of 2000-2002, 2001-2003, 2002-2004

RRF THRESHOLDS 85 PPB, 70 PPB

EMISSIONS BASE
2002 Base

NHDES 2/23/07 OTR State Summary

Range # of Population (ppb) Monitors Exposed

< 75

75 - 84.9

85 - 94.9

>= 95 31

64

73

19 6,035,113

19,106,873

28,772,373

7,668,413 CALGRID 172x172 Modeling Domain 

### OTR Domain 2002 Design Values 2009 Design ValuesTSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 2 8



### Figure 3-14 shows the CALGRID-modeled differences ( improvements) in the maximum 8-hour

ozone concentration between the 2009 OTB/OTW scenar io and the 2002 base case.

Figure 3-14 - Plot of Differences in Predicted Maxi mum 8-Hour Ozone Concentrations

between 2002 Base Case and the OTC 2009 OTB/OTW Str ategy

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

0 10 20 30 40 50 60 70 80 90 100110 120 130 140 150160170 -30 -20 -10 -5 -1 1 3 5 10 15 20 25 30 40 Ozone
Concentrations (PPB)

NHDES 5/29/07

CALGRID 2.45 Modeling Domain



### After completion of the model runs, NHDES discovere d that the 2009 on-road emission estimates for New Hampshire that were inputs to the modeling had been understated (by about 10% for VOC and 15% for NOx). To evaluate the uncertainty introduced by this sit uation, NHDES performed sensitivity modeling with CALGRID in which all New Hampshire on-road OTW/OTB NOx and VOC emission inputs were boosted by 25% for the Jul y 31 to August 16, 2002, high ozone event. The results of this analysis showed that the adjust ed inputs would have negligible effect on the modeled 8-hour design ozone values.

3.3 EPA’s CAIR Modeling

On May 12, 2005, EPA promulgated the Clean Air Inte rstate Rule (CAIR). Under CAIR, 28 states

across the eastern United States and the District o f Columbia are expected to make reductions in

NOx and SO 2 

### emissions. EPA performed technical analyses in su pport of CAIR, including air quality modeling to evaluate ambient levels of ozon e and PM 2.5 

### . The CAIR modeling is described

in EPA’s Technical Support Document for the Final Clean Air Interstate Rule, Air Quality Modeling , March 2005. The air quality modeling for ozone w as performed with the Comprehensive Air Quality Model with Extensions (CAMx) version 3. 10 on a modeling domain covering much of
the eastern United States. Three summer 1995 meteo rological episodes were used in the modeling. The analysis years and emissions scenarios that wer e assessed included:

• 

### 2001 Base Year

• 

### 2010 Base Case

• 

### 2015 Base Case • 

### 2010 CAIR Controls

• 

### 2015 CAIR Controls

• 

### 2015 CAIR + BART • 

### 2015 BART Only **Note:**

**A positive**
**number**
**denotes a**
**decrease in**

**ozone conc.**TSD for Redesignation of the Boston-Manchester-Port smouth (SE), NH Nonattainment Area Page 2 9



### The 2010 and 2015 Base Cases reflect expected econo mic growth and the anticipated benefits associated with existing emissions control programs

.

The CAMx model predictions were used in a relative manner. Weighted-average 1999-2003 design values were applied as the basis of the observed 8- hour ozone concentrations. Using this methodology, EPA estimated maximum 8-hour ozone des ign values for each future-year scenario for each county in the modeling domain with an ozon e monitor. Table 3-5 lists the maximum estimated future 8-hour design values for New Hamps hire. These results show that, even without the emissions benefits associated with CAIR, all Ne w Hampshire counties were predicted to be in

attainment for 8-hour ozone for the 2010 and 2015 a nalysis years.

Table 3-5 - CAIR Modeling Results for New Hampshire for 8-hour Ozone (ppb)

Estimated Maximum 8-hour Future Design Value County 1999 -2003 Average

Design Value 2010 Base 2010 CAIR 2015 Base 2015 CAIR
Belknap 78.0 68.5 68.2 65.8 65.0

Carroll 66.5 60.3 60.0 58.6 58.0

Cheshire 73.7 65.2 64.9 63.1 62.0 Hillsborough 85.0 76.7 76.6 74.1 73.9

Merrimack 73.0 64.8 64.6 62.3 61.8 Rockingham 82.7 75.2 75.1 73.3 72.9

Strafford 77.3 69.2 69.1 66.8 66.5

Note: Data taken from Appendix E of EPA’s Technical Support Document for the Final Clean Air Interstate Rule, Air Quality Modeling , March 2005.



### References

1. Blumenthal, D.L., F. Lurmann, N. Kumar., T. Dye, S. Ray, M. Korc, R. Londergan, and G.

Moore. Transport and mixing phenomena related to ozone exc eedances in the northeast U.S. EPRI Report TR-109523, Electric Power Research Inst itute, Palo Alto, CA, 1997.

2. Clarke, J.F., and J.K.S. Ching. “Aircraft observati ons of regional transport of ozone in the

northeastern United States.” Atmos. Envt. 17 , 1703-1712, 1983.

3. Earth Tech, Inc. Calgrid User Instructions. November 2006.

4. NARSTO. An Assessment of Tropospheric Ozone Pollution . NARSTO, July 2000.

5. Ray, J., R. Heavner, M. Flores, and C. Michaelson. “Surface Level Measurements of Ozone and

Precursors at Coastal and Offshore Locations in the Gulf of Maine.” J. Geophys. Res. 101 (D22) , 29005-29011, 1996.

6. Wishinski, P. and R. Poirot. Air Trajectory Residence Time Analysis Investigatio n of Ozone Transport Pathways: 1989-95. 1995.

7. Zhang J. and S.T. Rao. “The role of vertical mixing in the temporal evolution of groundlevel

ozone concentrations.” J. Applied Meteor. 38 , 1674-1691, 1999.

### ATTACHMENT B

8-Hour Ozone Data

### This page intentionally left blank.

### 8-Hour Ozone Data

The following presents the 8-hour ozone 4 th 

### highest values from monitored ozone data as well a s design value calculations for all sites in the Sout heast New Hampshire Nonattainment Area. All data

and calculations meet the criteria for data handlin g contained in EPA’s “Guideline on Data Handling Conventions for the 8-Hour Ozone NAAQS,” D ecember 1998. For this analysis, the most significant of these data handling conventions are:

• 

### A valid ozone monitoring day consists of “at least 18 out of 24 possible 8-hour averaging periods” unless “the daily maximum 8-hour average c oncentration for the day is greater than 0.08 ppm.”

• 

### “A valid year must have valid 8-hour daily maximum ozone concentrations for at least 75% of the required monitoring days in the ozone season ” unless the 4 th 

### high value is greater than 0.08 ppm.

• 

### For purposes of determining attainment status, “all three years must average at least 90% data completeness.” In the event that the 3-year a verage of the 4 th 

### highest values exceeds 0.08 ppm, then years with less than 75% data recove ry are included in the calculations.

Design values are calculated by taking the average of three consecutive years’ annual 4 th 

### highest values (which meet the data handling conventions li sted above). The year cited for the design value is the final year of the 3-year average. Table B-1 contains data for the current Southeast New Hampshire Nonattainment Area since 1983. The data include the 4 th 

### highest value for each year, data capture rates for both individual years and ea ch 3-year period, and the valid design values for

each site.

Table B-1 also includes the 2012 threshold value fo r each site that has monitored ozone from 2009-

2011. The threshold value is defined as the 4 th 

### highest value needed in a given year to cause the design value for that year to exceed the ozone NAAQ S. To determine the threshold for exceeding, rather than just meeting, the 1997 8-hour ozone sta ndard, the 2012 threshold value was calculated as

the 4 th 

### highest value in 2012 that would make the mean of the 2010-2012 annual 4 th 

### highest values equal to 86 ppb.

Threshold values help to determine the likelihood t hat a given site/area will exceed the ozone NAAQS in the following ozone season. The data in T able B-1 show that annual 4 th 

### highest values in the Southeast New Hampshire Nonattainment Area’s have not come close to the calculated 2012 thresholds in recent history. (Note: Annual 4 th 

### highest values and design values that exceed the 1997 8-hour ozone NAAQS are colored red in the table.)Table B-1. Annual 4thHighest 8-Hour Values, Design Values, and Data Capture Ratesfor Each Ozone Monitor Site in the Southeast New Hampshire Nonattainment AreaBrentwood Manchester Manchester Manchester ManchesterSouth Road Spring St. Hartnett Park N. CommercialSt. Pearl St.Year4thHigh1-Yr%3-Yr%DesignValue4thHigh1-Yr%3-Yr%DesignValue4thHigh1-Yr%3-Yr%DesignValue4thHigh1-Yr%3-Yr%DesignValue4thHigh1-Yr% 3-Yr%DesignValue19836454% N/A N/A19849181% N/A N/A19858791% N/A N/A198676 93%88% N/A198776 96% 93% 7919889898% 96% 83198968 97% 97% 80199075 97% 97% 8019918597% 97% 76199278 97% 97% 79199383 99% 98% 82199478 98% 98% 79199577 93% 97% 79199684 94% 95% 79199782 99% 95% 811998 67 96% N/A N/A63 96% 96% 761999 79 97% N/A N/A50 75% 90% 65 67 80% N/A N/A2000 61 94% 96% 6963 91% N/A N/A20018898% 96% 767463% N/A N/A20029193% 95% 808599% N/A N/A200370 94%85% N/A200471 99% 97% 75200571 97% 97% 70200668 98% 98% 70200774 98% 98% 71200864 100% 99% 68200960 95% 98% 66201063 99% 98% 6220112012ThresholdTable B-1 (Continued)Nashua Nashua Nashua RochesterMulberry St. Spit Brook Rd. Gilson Rd. Rochester Hill Rd.Year4thHigh1-Yr%3-Yr%DesignValue4thHigh1-Yr% 3-Yr%DesignValue4thHigh1-Yr%3-Yr%DesignValue4thHigh1-Yr% 3-Yr%DesignValue19838699% N/A N/A 6020% N/A N/A1984 4569% N/A N/A8997% N/A N/A19858888%68% N/A19869094% 93%89198784 95% 92%87198810796% 95%93198971 99% 97%8719908599% 98%8719919294% 97% 8219929099% 97%8919938699% 97%89199483 94% 97%8619958895% 96%85199681 100% 96% 8476 92% N/A N/A19979498% 98%8780 99% N/A N/A199884 98% 99%8679 93% 95% 7819998992% 96%8984 98% 97% 81200070 89% 93% 8165 98% 96% 7620019194% 92% 8378 99% 98% 7520029499% 94%8590100% 99% 77200378 99% 97%875849% N/A N/A 72 100% 100% 80200480 82% N/A N/A200582 95%75% N/A200673 97% 91% 78200781 96% 96% 78200867 95% 96% 73200966 97% 96% 71201067 99% 97% 66201165 96% 97% 662012Threshold123Table B-1 (Continued)Rye Rye Portsmouth Portsmouth PortsmouthRye Harbor State Park Seacoast Science Center Vaughan St. Port Authority Pierce IslandYear4thHigh1-Yr% 3-Yr%DesignValue4thHigh1-Yr%3-Yr%DesignValue4thHigh1-Yr% 3-Yr%DesignValue4thHigh1-Yr%3-Yr%DesignValue4thHigh1-Yr% 3-Yr%DesignValue19839097% N/A N/A198454 91% N/A N/A19858798% 95% 7719869599% 96% 7819879788% N/A N/A79 100% 99%87198811389% N/A N/A11096% 98%941989103100% 92%10480 100% 99%891990 84 97% 95%10078 97% 98%89199110791% 96%989496% 98% 8419928775%88%928698% 97%8619939588%85%9682 97% 97%8719949793%85%938697% 97% 8419959894% 92%968598% 97% 8419968797% 95%9479 98% 98% 83199710298% 96%958998% 98% 8419988598% 98%9184 97% 98% 841999 84 97% 98%908996% 97%872000 68 97% 97% 7967 98% 97% 8020019398% 97% 8159 90% N/A N/A20028999% 98% 839096% N/A N/A2003 71 98% 98% 84 66 90% N/A N/A55 95% 94% 68 73 77% N/A N/A200474 97% N/A N/A76 95% N/A N/A200575 92% 93% 7175 92%88% N/A200676 95% 95% 7573 97% 95% 7420078698% 95% 7978 95% 95% 75200875 98% 97% 7969 100% 97% 73200968 98% 98% 7670 100% 97% 72201066 99% 98% 6966 99% 99% 6820116699% 98% 6664 98% 98% 662012Threshold123125

### ATTACHMENT C

Chemical Analyses

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### Chemical Analyses

Photochemical assessment monitoring station (PAMS) sites monitor ozone, chemicals associated with ozone formation, and meteorological data. The data from sites in Maine and Massachusetts have been analyzed by NHDES staff. Sites in these states wer e included because they are downwind and upwind of New Hampshire, respectively. The meteorological portion of the analysis is presented in Attachment D.

Background Information

The Clean Air Act Amendments of 1990 required EPA t o promulgate regulations for the “enhanced” monitoring of ozone and its precursors for ozone no nattainment areas classified as serious, severe or extreme. Both Congress and EPA recognized the need for an improved understanding of the ozone problem, and better feedback mechanisms for evaluat ing the effectiveness of ozone control strategies. In 1993, EPA published the final rule detailing the minimum requirements for PAMS, which includes measurements of nitrogen oxides (NOx), speciated vo latile organic compounds (VOCs), and meteorological parameters. These monitoring regula tions provide for the collection of an “enhanced” ambient air quality database which can be used to b etter characterize the nature and extent of the ozo ne problem, aid in tracking NOx and VOC emission inven tory reductions, assess air quality trends, make attainment/nonattainment decisions, and evaluate ph otochemical grid-model performance.

There are four different types of PAMS sites, each serving a specific monitoring purpose: a Type 1 is upwind of the urban area and represents background concentrations coming into the area; a Type 2 is on the downwind fringe of the urban area and represent s maximum precursor concentrations from the area; a Type 3 is located in an area with maximum ozone c oncentrations; and a Type 4 is at extreme downwind location to represent long-range transport from the area. Therefore, PAMS sites required for an area will not necessarily all be located within the boundaries of the non-attainment area.

New Hampshire currently operates two PAMS sites: Na shua (Type 1) and Peterborough (Type 3). The Nashua site is located in a populated area near the southern border of the state, and is part of the Boston--Worcester--Lawrence Consolidated Metropolit an Statistical Area (CMSA). The site in Peterborough is in Miller State Park on the summit of Pack Monadnock at an elevation of 2288 feet above sea level. Both sites are important for capt uring the transport of ozone and its precursors int o New Hampshire.

The distinguishing features that make PAMS sites tr uly “enhanced” ozone monitoring stations is that they collect meteorological, ozone and its precurso rs (oxides of nitrogen and VOCs) data simultaneously. Gaining a better understanding of how these variables interact with each other in rea lworld instances is necessary in order to effectivel y address ozone levels in New Hampshire and the res t
of the nation.

Description of Analyses

Analysis of PAMS data focused on nitrogen oxides, P AMS target compounds (PAMHC), and total nonmethane organic carbons (TNMOC) in New Hampshire an d the surrounding states of Maine and Massachusetts. Data were acquired through AQS for 1998 to 2010. Only hourly data were considered. In addition, some data were removed if they did not meet the following criteria:

• 

### POC# was equal to 1.

• 

### Data capture of at least 60% (1757 hours) occurred during the period June-September.• 

### To provide a consistent base of comparison in the c harts of PAMHC and TNMOC, data for

these parameters from a given year were available f or both parameters. NOx data were treated separately.

Due to a high number of monitoring sites in Massach usetts, a few with long-term datasets were selected to illustrate NOx trends. After accounting for the above, data from the following sites were incorporated into the charts shown below:

New Hampshire

• 

### Nashua, Gilson Road (33-011-1011)

• 

### Peterborough, Pack Monadnock Summit in Miller State Park (33-011-5001)

• 

### Portsmouth, Pierce Island (33-015-0014)

• 

### Brentwood, South Road (33-015-0013)

Maine

• 

### Cape Elizabeth, Two Lights State Park (33-005-2003)

• 

### Portland, Marginal Way (23-005-0027) and State Stre et (23-005-0029)

• 

### Kittery, Frisbee School (23-031-3002) – operated by NHDES

• 

### Bar Harbor, Cadillac Mountain Summit, Acadia Nation al Park (23-009-0102)

Massachusetts

• 

### Boston, Kenmore Square (25-025-0002)

• 

### Springfield, Liberty P-Lot (25-013-0016)

• 

### Worcester, Central Street (25-027-0020) and Summer Street (25-027-0023)

• 

### Lynn, Parkland (25-009-2006)

• 

### Newbury, Sunset Blvd (25-009-4004)

• 

### Milton, Top of Blue Hill (25-021-3003)

• 

### Chicopee, Anderson Rd (25-013-0008)

• 

### Ware, Quabbin Summit (25-015-4002)Average TNMOC and PAMHC (June-September) New Hampshire, Maine, Massachusetts

0 5 10 15 20 25 30 35 40 45 50

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 201 0Concentration (PPBC)

TNMOC

PAMHC

TNMOC and PAMHC Seasonal Averages

Gilson Road, Nashua

0 5 10 15 20 25 30 35

2006 2007 2008 2009 2010Concentration (PPBC)

TNMOC

PAMHC

TNMOC and PAMHC Seasonal Averages Pack Monadnock Summit, Peterborough

0 10 20 30 40 50 60

2006 2007 2008 2009 2010Concentration (PPBC)

TNMOC

PAMHC

### ATTACHMENT D

Meteorological Analyses

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### Meteorological Analyses

Meteorology is a major factor in the formation and transport of ozone and its precursors. High ozone concentrations in southern New Hampshire occur most often when low pressure systems approach from the Great Lakes or southern Canada while high press ure is situated just off the eastern seaboard. Whe n such a scenario is in place, it provides warm tempe ratures, clear skies, and southwesterly winds to al low the transport of precursors into the Northeast.

Following the NOx SIP call, which went into effect in 2003, and other emission control programs, NOx and VOC emissions have been reduced throughout the region. Ozone exceedances in recent years have been fewer in large part because of these emissions reductions. To confirm that lower ozone levels in New Hampshire are not simply a result of anomalous weather conditions, such as lower summer temperatures or changing wind patterns, the followi ng analyses were performed:

• 

### Temperature versus ozone graphs

• 

### Graphs of wind frequency data

Temperature vs. Ozone Graphs

Since ozone exceedances are typically associated wi th hot sunny summer days, NHDES staff compared maximum daily temperatures to numbers of ozone exce edance days in New Hampshire. Concord Airport temperature data were downloaded from the N ational Weather Service’s website for the months of April through September and the years 1985 to 20 11. Concord Airport was chosen as a representative site because it has historical data for the full period and is located in a central par t of southern New Hampshire.

Formulas were then written to count the number of d ays during each year’s ozone season that the maximum daily temperature rose above 85 F. These c ounts, as well as the number of days in which one or more New Hampshire sites exceeded the 1997 NAAQS , were tabulated for each year 1985-2011. Next, the data were sorted in ascending order by th e number of days with a maximum temperature over 85 F, and the sorted data were used to create the b ar-line chart displayed in the figure below. This depiction creates an upward-sloping trend line for temperature and exceedance days. To emphasize the period 2003-2011, the data points for these years w ere circled and labeled.

Number of Days with Maximum Temperatures above 85 F and Number of Days with

Ozone Exceedances in New Hampshire, 1985-2011

0 10 20 30 40 50 60 70

199 6 19 8 6 200 9 2 00 8 1992 200 0 2 00 4

1 99 7 2006 198 9

1 98 5 1987 199 8 2 00 3 1999 199 4 19 8 8 1993 199 0 20 0 7 20 1 1 2001 200 2 19 9 1 200 5

1 99 5 20 1 0Number of Days Max Temperature >85 F

Ozone Exceedances

Linear (Ozone Exceedances)

2006 2003 2007 2005

2004 2009 Notes: Temperatures are National
Weather Service data from Concord Airport.

Data are sorted by number of days with maximum temperature >85 F (therefore, years are not in chronological order). 2008 2010

2011

### Wind Direction Frequency Charts

NHDES staff explored historical wind direction freq uencies in New Hampshire. Again, National Weather Service data were used to provide a consist ent, long-term dataset. Wind directions and wind speeds were downloaded from the National Weather Se rvice’s website for the months of April through September to provide ozone season wind data for the years 1995-2010. Data were gathered for two sites, centrally located Concord Airport and the co astal site at Pease International Airport in

Portsmouth.

The downloaded data were consolidated to produce on ce-hourly lists of wind direction and wind speed

observations. Because the number of observations e ach hour varied in the raw dataset, extraneous observations outside the regular measurement interv al were removed to provide greater consistency for the final calculations. Also, to avoid bias from t he inclusion of wind directions during calm conditi ons, wind observations were excluded if the correspondin g wind speed was less than 3 mph.

All raw wind direction data were measured in interv als of 10 degrees. Formulas were written to calculate the percentage of total hours for which t he wind direction was recorded at each 10-degree interval. This was done separately for two time pe riods, 1995-2002 and 2003-2010. The resulting percentages were then incorporated into wind roses to illustrate typical wind direction frequencies at each site, as shown here.

New Hampshire Wind Direction Frequencies in the Mon ths of

April through September, 1995-2010

Wind Direction Frequencies at Concord Airport

National Weather Service Data

1995-2010

1995-2002

2003-2010 N

E W

S Wind Direction Frequencies at Pease Airport, Portsm outh
National Weather Service Data

1995-2010

1995-2002

2003-2010 N

E W

S

### ATTACHMENT E

Administrative Documents:

 Evidence of Legal Authority

 Certification of Public Process

 Copy of Public Notice

 Public Comments and State’s Response

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### This page intentionally left blank.STATE OF NEW HAMPSHIRE DEPARTMENT OF ENVIRONMENTAL SERVICES AIR RESOURCES

DIVISION CONCORD, NEW HAMPSHIRE NOTICE OF PUBLIC CO MMENT PERIOD AND PUBLIC HEARINGS In accordance with New Hampshire Administr ative Rule Env-A 204.01(b) and Title 40 of the Code of Federal Regulations (CFR) Section 51.102, notice is hereby given that the New Hampshire Department of Environmental Services, Air Resources Division (the Department) has prepared, and intends to submit to the U.S. Environmental Protection Agency (EPA) for approval, a request for redesignation of the Boston-Manchester-Portsmouth (SE), New Hampshire 8-hour ozone (1997 standard) nonattai nment area, including a maintenance plan for that area, hereinafter referred to as "Req uest for Redesignation (including MP I)," pursuant to section 110(a) of the federal Clean Air Act. This request, if approved by EPA, will revise New Hampshire's State Implementation Plan (S IP). In addition, the Department has prepared and intends to submit to EPA for approval as a SIP revision a maintenance plan, hereinafter referred to as "MP II," for the area of the state that was formerly designated nonattainment for the 1-hour ozone standard, but wh ich was classified as unclassifiable/attainment for the 8-hour ozone stan dard. The Boston-Manchester-Portsmouth (SE), New Hampshire 8-hour ozone (1997 standard) no nattainment area consists of 52 cities and towns in the southern and/or eastern parts of H illsborough, Merrimack, Rockingham, and Strafford Counties. Ground-level ozone monitoring d ata for the most recent 3-year monitoring period of 2008-2010 show that air quality in the no nattainment area has met the 1997 National Ambient Air Quality Standard for 8-hour oz one. For EPA to approve the Request for Redesignation, the Department must submit maintenan ce plan MP I as part of this request, detailing how the state will insure that the area w ill not fall back into nonattainment once it is redesignated as attainment. MP I must demonstrate t hat the area will remain in compliance for a period of 10 years from the date of redesignation . The former nonattainment area for the 1-
hour ozone standard that was classified as unclassi fiable/attainment for the 8-hour ozone standard on June 15, 2004, consists of 79 cities an d towns in Cheshire County and the northern and/or western parts of Hillsborough, Merr imack, Rockingham, and Strafford Counties. The maintenance plan for this area, MP II , must demonstrate that the area will remain in compliance with the 8-hour ozone standard for the 10-year period from June 15, 2004 to June 15, 2014. The Department hereby solici ts comments and has scheduled public hearings on the Request for Redesignation (includin g MP I) and MP II. A public hearing on the Request for Redesignation (including MP I) has been scheduled for 10:30 a.m., Tuesday, January 24, 2012, at the Department offices in Room s 110 and 111 at 29 Hazen Drive, Concord, NH 03301. A public hearing on MP II has be en scheduled to start at the conclusion of the first hearing. Comments may be presented orally and/or in writing at the public hearings. Written comments may also be submitted by postal de livery, email, or fax to Charles Martone, Air Resources Division, NH Department of Environmen tal Services, P.O. Box 95, Concord, NH 03302-0095; email Charles.Martone@des.nh.gov; fax ( 603)271-1381. Please specify which plan each comment addresses. All written comments o n the Request for Redesignation (including MP I) and all written comments on MP II must be received by 4:00 p.m. on Tuesday, January 24, 2012, to be entered into the record. Th e Request for Redesignation (including MP I) and MP II are available for public inspection at the Department's offices at 29 Hazen Drive, Concord, NH, during regular working hours from 8:00 a.m. to 4:00 p.m., Monday through Friday. The main text of both documents may be down loaded from the Department's website at http://des.nh.gov/ . Questions regarding the Request for Redesignation (including MP I) and MP II may be directed to Charles Martone at (603) 271- 1089. Robert R. Scott Director, Air Resources Division NH Department of Environmental S ervices Dated: December 23, 2011

Appeared in: The Union Leader on Friday, 12/23/2011

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## Responses to Comments on New Hampshire's Proposed Redesignation Request

On January 24, 2012, the New Hampshire Department o f Environmental Services (NHDES)

received comments from the U.S. Environmental Prote ction Agency (EPA) on New Hampshire’s proposed redesignation request for the Boston-Manch ester-Portsmouth (SE), NH 8-hour ozone (1997 standard) Nonattainment Area. No other publi c comments were received. The following are NHDES’s responses to EPA’s comments. Comments are written in regular font and responses

are written in italics

.

Ozone Data

1. Table 2-1 on Page 8 should identify that the ozo ne concentrations are presented in units of parts per billion (ppb).

Response: The requested clarification has been added.

2. In Table 2-1 on Page 8, the 2012 threshold value s should be 123, 125, and 123 ppb for Nashua, Portsmouth, and Rye, respectively. Therefore, NH D ES should adjust the “most recent year at or above the threshold” column correspondingly. In ad dition, it should be noted that in the current version of the table, it appears that 1-hour values , rather than 8-hour values, were used when determining the most recent year at or above the th reshold.

Response: The 2012 threshold values and the most recent years at or above threshold have been

corrected in the table.

Motor Vehicle Emission Budgets

3. In Section 5.5, including in Table 5-1, NH DES s hould express the year 2008 and year 2022 NOx and VOC motor vehicle emission budgets for the Bost on-Manchester-Portsmouth (SE), NH area in units of tons per summer day for use as future tran sportation conformity budgets.

Response: The requested edit has been made to Table 5-1.

2008 Inventory and Projections to 2012 and 2022

4. New Hampshire selected its 2008 emissions invent ory to use as the base year inventory for the maintenance plan developed to support redesignation of former 8-hour nonattainment areas in the state. The 2008 inventory should be submitted to E PA in conjunction with submittal of the final redesignation request, as EPA will need to approve the 2008 inventory into the SIP.

Response: The 2008 emissions inventory is being submitted t o EPA as Attachment G to the redesignation request. Because of the volume of te chnical data associated with the emissions inventory, a data CD-ROM is being submitted which i ncludes the inventory documentation, data tables (as Microsoft Excel spreadsheets), and other supporting technical data.Page 2 of 5



### 5. The write-up for New Hampshire's 2008 emissions inventory should describe how the partial county emission estimates for the 8-hour ozone nona ttainment area were derived. It appears that the town by town population data within the tabbed shee t labeled “3 - 17 Population,” within the spreadsheet with file name “NH 2008 PEI Section 3 T ables.xls” was used to apportion the county

level area and nonroad emission estimates to the to wn level. This enabled New Hampshire to then sum up nonroad and area source emissions by town to match the sub-county geography of the 8- hour nonattainment area. This methodology, along w ith an indication of how on-road mobile emission estimates at the sub county level were der ived, should be included in the 8-hour ozone inventory documentation.

Response: As EPA notes, population data was used to apporti on many of the area and non-road emissions source categories to the sub-county geography of the 8-hour nonattainment area. Onroad mobile emissions estimates were derived using VMT data that was provided by the relevant metropolitan planning organizations (MPOs). Since the MPOs comprise the 8-hour nonattainment area, the VMT data and resulting emissions estimate s were specific to that geography. Appropriate wording to describe these methodologies has been ad ded to Sections 1.2 and Section 4 of the 2008 emissions inventory documentation.

6. New Hampshire should extract a table from the sp readsheet labeled, “ISTEPS_2008_POINT_EMISSIONS_SORT.xls” that identif ies the NOx and VOC stationary sources whose emissions were summed to produce the 24,289 lbs/day NOx and 5,762 lbs/day VOC point source emission totals, and place this table within the write-up for the 2008 inventory.

Response: The requested tables were added to Section 2 of t he 2008 emissions inventory

documentation.

7. Section 6.2.1 of the proposed redesignation requ est for New Hampshire's 8-hour nonattainment area mentions that growth factors from the Economic Growth and Analysis System (EGAS) were used to project point and area source emissions to 2012 and 2014. The final submittal should include the specific point and area source growth f actors that were used to make these projections. Additionally, a review should be made of the growth factors used to project NOx point sources from 2008 to 2012, as the nearly 50% increase shown seem s quite high. New Hampshire may want to consider to instead use 2011 actual emissions, grow n (or diminished) a minor amount to reflect

2012 conditions.

Response: All of the supporting technical files for the pro jected 2012 and 2022 emissions inventories relevant to the redesignation request a re being provided to EPA on CD-ROM as Attachment H. These files include the EGAS factors that were used to do the projections.

Final quality-assured actual emissions data for cal endar year 2011 is not yet available. However, in response to this comment, New Hampshire used 201 0 actual emissions data and the applicable growth factors to develop revised point source emis sions estimates for 2012 and 2022. Table 6-1 of the redesignation request has been revised accordin gly.

8. In several locations within the write-up of 2008 area source emission estimates, the phrase, “adjustments to account for New Hampshire's 15% ROP plan” is used. This is a somewhat vague reference, and should be replaced with something mo re descriptive such as “adjustments to account for the regulations New Hampshire adopted to meet i ts 15% ROP plan for the 1-hour ozonePage 3 of 5



### standard, as some of those rules contained lower ap plicability thresholds and thus required

reductions at area sources.”

Response: The requested edits were made to the 2008 emissio ns inventory documentation.

9. The area source inventory documentation indicate s that for some source categories, County

Business Pattern data for 2008 was not available an d so data for 2007 was used. 2008 data from

this resource should now be available.

Response: Per EPA's request, 2008 County Business Patterns data was obtained and incorporated

into the relevant area source emissions calculation s. Further, 2008 Energy Information Administration fuel consumption estimates were not available at the time when work on the 2008 inventory commenced, so 2007 data was used. New Ha mpshire has now obtained the 2008 fuel consumption estimates and incorporated them into th e calculations for the applicable area source categories. These changes have resulted in edits t o the 2008 emissions inventory documentation and Table 6-1 of the redesignation request.

10. For the redesignation request, it is important to note that the ten year maintenance plan is keyed to when EPA takes final action. Therefore, in orde r for the 2022 emission inventory to remain relevant, it is critical for New Hampshire to submi t the final redesignation request to EPA as soon as possible (i.e., at a minimum, within the next coupl e of months). Otherwise, EPA may not have enough time to complete its action by December 31, 2012.

Response: The time limitation is duly noted.

Contingency Measures

11. On page 42, in Section 6.5, NH DES cites one re ason to investigate an ozone season exceedance as “an anomaly in the ozone-season meteorology.” S ince weather anomalies alone do not exempt NH DES from contingency measures, EPA recommends re placing this bullet with reference to “exceptional events,” as shown below:

“2. If the design value is above the standard for a ny ozone monitor, NHDES will investigate

the cause and determine whether the exceedance is d ue to: • an increase in emissions from local, in-state sou rces; • an increase in emissions from upwind, out-of stat e sources; or • an anomaly in the ozone season meteorology an exceptional event as defined in

40 CFR 50.1. ”

Response: The requested rewording has been made.

12. On page 42, EPA recommends that NH DES delete t he word “significant” from the third step for the protocol, as shown below, since all factors contributing to ozone exceedances should be

evaluated:

“3. If an increase in in-state emissions is determi ned to be a significant contributing factor to the exceedance, NHDES will evaluate the projected i n-slate emissions for the next ozone

season.”Page 4 of 5



### Response: The word “significant” has been removed.

13. On page 42, the 4th step of the protocol states :

“The contingency measures(s) will be selected by th e Governor or the Governor's designee

within six months of/he end a/the ozone season/or w hich contingency measures have been determined to be needed. New Hampshire will then i nitiate a course of action to implement enforceable control measurers) to rectify the probl em. New rulemaking, when required, can typically be adopted and implemented within a 12-mo nth timeframe, assuming that no new legislation is required.”

In the final submittal, NH DES should clarify the t imeframe to implement contingency measures.

Response: The end of the quoted paragraph has been revised to read as follows: “New rulemaking can typically be adopted and implemented within a 1 2-month timeframe. NHDES will update the maintenance plan as necessary and develop and imple ment required regulations as soon as practicable within the guidelines established in th e New Hampshire Administrative Procedures Act, but no later than 18 months after selection of the appropriate measure.”

Stage II Vapor Recovery

14. As stated on page 35, NH DES is not submitting the phase-out of Stage II as a formal component of this SIP revision to redesignate the 1 997 8-hour ozone nonattainment area. However, we acknowledge that New Hampshire has rece ntly adopted revisions to its Env-Wm 1404.17 regulation, “Applicability of Stage II Requ irements.” The adopted amendments to EnvWm 1404.17 eliminate the requirements, as of Januar y I, 2012, for Stage II vapor recovery systems at gasoline dispensing facilities. We have reviewe d the MOVES modeling inputs associated with the proposed redesignation request, and note that t he emissions projections for 2012 and later years appropriately reflect that the NH Stage II vapor re covery program is no longer providing emission reductions after January 1, 2012.

It is, therefore, acceptable that the Stage II phas e-out be submitted to EPA as a SIP revision subsequent to the redesignation request. The Stage II phase-out supporting documentation and calculations, which should be based on MOVES, need to be proposed and adopted, and then submitted, along with the recently adopted amendmen ts to New Hampshire's Env-Wm 1404.17 rule, to EPA as a SIP revision. Furthermore, EPA encoura ges NH DES to provide draft versions of this documentation and relevant MOVES modeling files to EPA for review prior to the formal proposal

of this information.

Response: NHDES acknowledges that Stage II vapor recovery m ay be addressed as a separate item. Accordingly, NHDES intends to submit a SIP r evision for the phase-out of Stage II after submission of this redesignation request. Draft ve rsions of supporting documentation and modeling files will be provided to EPA in advance of any for mal submission of the Stage II proposal.

15. In Section 5.2, on page 31, a list of the appli cable requirements of New Hampshire's former 1- hour serious nonattainment areas is presented. One of the measures listed is Stage II vapor recovery. The first paragraph following this list states:Page 5 of 5



### “New Hampshire asserts that all required control pr ovisions shall remain in place to prevent backsliding and assure maintenance of the 1997 8-ho ur ozone NAAQS after redesignation of

the area to attainment.”

This statement does not hold true for Stage II, sin ce New Hampshire has adopted revisions to its Env-Wm 1404.17 rule to eliminate the Stage II requi rements. New Hampshire should clarify this

discussion in the final submittal of the ozone rede signation request.

Response: The following paragraph has been added to Section 5.2 after the indicated passage:

“New Hampshire notes that it recently revoked the r equirement that new gasoline dispensing facilities shall be equipped with Stage II vapor re covery control equipment and simultaneously adopted a requirement that owners of existing gasol ine dispensing facilities equipped with Stage II controls shall decommission such equipment by Decem ber 22, 2015. This rulemaking was necessary to prevent a situation – forecast to occu r in the next few years – whereby the Stage II equipment, because of incompatability with ORVR equ ipment, would cause more VOC emissions in New Hampshire than it would prevent. New Hampshire is preparing a separate SIP submittal demonstrating that these rule changes will not viol ate the anti-backsliding requirements of section 110(l) of the Clean Air Act . The demonstration wo uld have been included with this SIP revision, but has been delayed as NHDES resolves discrepancie s in motor vehicle emission estimates after

conversion to the new MOVES model.”

Attachment G – CD Files (Note: This attachment has been renamed as Attachme nt F)

16. The MOVES modeling inputs associated with the r edesignation request should be consistent with previous SIP-approved inputs. Once a mobile s ource modeling input is approved into the SIP, all subsequent SIP submittals should reflect the sa me program characteristics as the SIP-approved version of the program inputs. For example, the At tachment G MOVES modeling inputs relating to New Hampshire's motor vehicle inspection and mainte nance program utilize I/M compliance figures

that were “modified to actual NH data.” The curren t New Hampshire I/M SIP, as well as a NH I/M SIP revision recently submitted to EPA on November 17, 2011, both utilize an I/M compliance rate of 96%. Therefore, all modeling of New Hampshire's I/M program should be conducted using this 96% compliance rate. However, for other parameters that are not included in NH's SIP as part of a formal control measure, or air emissions reduction program, for example “fuel formulation,” EPA encourages the use of recent/accurate state-specifi c data as much as possible over the use of national

defaults in the MOVES model.

Response: The MOVES runs were redone using a compliance rat e of 96%. Tables 5-1 and 6-1 were revised accordingly.

17. The MOVES run spec file “rrpc_2008.mrs” appears to have left out the associated input database “rrpc_2008_in,” and thus generated emissio n figures strictly based on the MOVES default database for the 2008 analysis of the Rockingham an d Strafford Regional Planning Commission non-attainment towns. Therefore, the 2008 onroad m obile source emission estimates are not accurate. Since NH DES has proposed replacing its 2009 MOBILE6 motor vehicle emission budgets with 2008 MOVES2010 budgets, this issue mus t be corrected in the final SIP submittal. EPA would be unable to make a positive adequacy det ermination on the proposed 2008 VOC and NOx onroad motor vehicle emission budgets if the MO VES2010 runs contain errors.

Response: The identified error was corrected and Tables 5-1 and 6-1 were revised accordingly.

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### ATTACHMENT F

MOVES Input/Output Files for 2008 and 2022 Motor Vehicle Emissions Budgets

(Files available on accompanying CD.)

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### ATTACHMENT G

Documentation for 2008 Emissions Inventory

(Supporting data files available on accompanying CD .)

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## New Hampshire 2008 Periodic Emissions Inventory for Ozone Precursors

1. INTRODUCTION

This document and attached spreadsheet tables serve as New Hampshire's State Implementation Plan (SIP) submittal of its 2008 Periodic Emissions Inve ntory (PEI) for ozone precursors. Calendar year 2008 emissions estimates for New Hampshire have als o been submitted via EPA's new Emissions Inventory System (EIS) for inclusion in the 2008 Na tional Emissions Inventory (NEI). Together, these submissions fulfill New Hampshire's emissions repor ting obligations as required in its SIP and under the Consolidated Emissions Reporting Rule (CERR) at 40 CFR Part 51. The sections immediately following provide an overview and summary of New Ha mpshire's 2008 PEI, including pollutants of concern, general methodologies, and geographic cove rage. Subsequent sections describe in more detail the methodologies and assumptions used in th e estimates for the various emissions categories. The emissions categories included in this submittal are as follows:

• Point Sources ( Section 2 ) are discrete facilities which generally report th eir emissions directly via the Air Emissions Inventory and Reporting progr am at the New Hampshire Department of Environmental Services (NHDES). Point sources usua lly represent larger facilities.

• Area Sources ( Section 3 ) comprise a wide range of anthropogenic activities that generate emissions. These activities are generally too wide spread and numerous to be inventoried individually; therefore, estimates for these catego ries are made using available state-wide data such as population, employment, and fuel consumptio n. Also included in Section 3 are NonRoad Mobile Sources . Non-road mobile sources include a variety of veh icles and equipment which do not operate on roadways, including constru ction vehicles, lawn and garden equipment, and recreational vehicles. For the purp oses of New Hampshire's PEI, aircraft, locomotives, and commercial marine vessels are also included in the non-road mobile category.

• On-Road Mobile Sources ( Section 4 ) are vehicles that are principally intended to be operated on roadways. This category includes cars, trucks, buses, and motorcycles.

• Biogenic Emissions are naturally-occurring emissions due to vegetatio n and other nonanthropogenic sources. EPA and other parties will be calculating biogenic emissions to support ozone SIP-related activities such as photochemical air quality modeling. NHDES will accept these estimates. In the Air Emissions Reporting Re quirements (AERR) Final Rule, EPA is proposing to remove the requirement that state, loc al, and tribal agencies report biogenic emissions. Therefore, biogenic emissions are not a ddressed further in this submittal.

1.1 Pollutants of Concern

The 2008 PEI was prepared in support of New Hampshi re's SIP for attaining and maintaining the 1997 national ambient air quality standard for ozone. T herefore, the focus of this documentation is the tw o principal precursors of ozone, volatile organic com pounds (VOC) and oxides of nitrogen (NOx). However, because New Hampshire made a submittal to the NEI, emissions estimates were also made for the other criteria pollutants, including carbon monoxide (CO), sulfur dioxide (SO2), particulate matter with an equivalent diameter of 10 microns (P M10), and particulate matter with an equivalent diameter of 2.5 microns (PM2.5). For some source c ategories, estimates were also made for ammonia (NH3).

1.2 Methodology

The methodologies used in the preparation of the 20 08 PEI were based on standard guidance and procedures. The resources that New Hampshire used included EPA's Clearinghouse for Inventories & Emissions Factors (CHIEF) and Emission Inventory Im provement Program (EIIP). Stated briefly,emissions estimates are generally made by multiplyi ng an emission factor times an activity or

throughput factor. Many of the emission factors us ed in the calculations were based on AP-42, Fifth Edition, Compilation of Air Pollutant Emission Fact ors, Volume I: Stationary Point and Area Sources

. Activity and throughput data was obtained from a wi de variety of sources, including the U.S. Census Bureau, the U.S. Department of Energy, and New Hamp shire state agencies such as the NH Department of Transportation and the NH Office of E nergy and Planning. The calculations that were used for each category are shown in the tables, whi ch can be found in the Microsoft Excel spreadsheets that accompany this documentation. Ea ch spreadsheet tab is designed to be selfdocumenting, listing the methodology, emission fact ors, activity, and other assumptions that were used
in the calculations.

Emissions were calculated and apportioned to the co unty level using a variety of data elements including population, employment, product sales, ho using units, and heating-degree days. The method that was used to apportion each emissions category is provided on each corresponding spreadsheet tab of the Excel workbook that accompanies this tex t. Many of the data elements used for apportionment are not available at a resolution low er than county level; however, New Hampshire's 8- hour non-attainment area (discussed in greater deta il below) does not follow county boundaries. Since population data for New Hampshire was available at the town level, this data element was used to apportion the emissions estimates for many categori es to the irregularly shaped 8-hour non-attainment area. Detailed population data for New Hampshire h as been provided in the accompanying spreadsheet and is discussed further below.

Quality assurance was employed during inventory pre paration to ensure an accurate and high-quality inventory. Quality assurance measures included "re ality checks" against previous inventories and hand-calculation checks of spreadsheet calculations . In addition, inventory staff from the point and area source sectors worked closely together to ensu re that no emissions were double counted.

1.3 Geographic Coverage

In 1997, EPA promulgated the 8-hour ozone standard and published its final 8-hour ozone attainment designations and classifications in 2004. The State of New Hampshire contains one classified 8-hour non-attainment area, the New Hampshire portion of t he Boston-Manchester-Portsmouth (SE) NH
Ozone Non-Attainment Area. This area is classified as mo derate, and contains parts of Hillsborough, Merrimack, Strafford, and Rockingham counties. So in total, New Hampshire has parts of four counties
classified as moderate non-attainment. Cities and towns that are in the 8-hr non-attainment area are: Amherst, Atkinson, Auburn, Bedford, Brentwood, Broo kline, Candia, Chester, Danville, Derry, Dover, Durham, East Kingston, Epping, Exeter, Fremont, Gof fstown, Greenland, Hampstead, Hampton, Hampton Falls, Hollis, Hooksett, Hudson, Kensington , Kingston, Litchfield, Londonderry, Manchester, Merrimack, Milford, Nashua, Newcastle, Newfields, N ewington, Newmarket, Newton, North Hampton, Pelham, Plaistow, Portsmouth, Raymond, Rochester, R ollinsford, Rye, Salem, Sandown, Seabrook, Somersworth, South Hampton, Stratham, and Windham. As of this writing, New Hampshire is in the process of submitting a formal request to EPA to re -designate this area as being in attainment of the 1997 8-hour ozone standard. Cheshire, Belknap, Coo s, Carroll, Grafton, and Sullivan counties are
classified as unclassifiable/attainment for the ozo ne standard.

The tables in the attached spreadsheets show emissi ons estimates for each county and for the entire
state. Estimates are also shown for the 8-hour non -attainment area. In addition, estimates are shown for the former 1-hour ozone non-attainment areas (i .e. the former Seacoast, Southern, and Marginal non-attainment areas). Estimates for the former 1- hour areas are shown only for continuity with previous inventories. Figure 1, which is provided as an attachment to this document, contains maps showing the former 1-hour non-attainment areas as w ell as the current moderate 8-hour ozone nonattainment area.1.4 Inventory Summary

A summary of New Hampshire's 2008 PEI is presented in the following tables. Estimates in pounds per summer day for VOC and NOx are shown for the 8- hour non-attainment area in Table 1-1 and for
the entire state in Table 1-2. Emissions are broke n down into the point, area, non-road, and on-road sectors. Tables 1-3 and 1-4 compare the 2008 estim ates with New Hampshire's two most recent PEIs
from 2002 and 1999. Statewide 2008 emissions estim ates decreased by approximately 28% and 10% respectively for VOC and NOx when compared with 200 2.

Table 1-1: Summary of NH 2008 PEI for the 8-Hour No n-Attainment Area

Emissions in Pounds Per Summer Day Category VOC NOx
Point 5,762 24,289 Area 55,871 6,528 Non-Road Mobile 33,512 31,364 On-Road Mobile 35,666 74,352 Total 130,811 136,533

Table 1-2: Summary of NH 2008 PEI, Statewide Total

Emissions in Pounds Per Summer Day Category VOC NOx
Point 8,722 62,551 Area 106,150 12,515 Non-Road Mobile 98,345 61,863 On-Road Mobile 62,652 188,699 Total 275,869 325,628

Table 1-3: Comparison of NH 2008 PEI with 2002 and 1999, Statewide VOC

VOC Emissions in Pounds Per Summer Day Category 1999 2002 2008
Point 21,698 18,096 8,722 Area 112,660 136,347 106,150 Non-Road Mobile 89,248 124,582 98,345 On-Road Mobile 142,440 105,775 62,652 Total 366,046 384,800 275,869

Table 1-4: Comparison of NH 2008 PEI with 2002 and 1999, Statewide NOx

NOx Emissions in Pounds Per Summer Day Category 1999 2002 2008
Point 127,187 87,667 62,551 Area 11,514 14,932 12,515 Non-Road Mobile 93,209 65,881 61,863 On-Road Mobile 248,920 195,136 188,699 Total 480,830 363,616 325,628

2. POINT SOURCES

Each year, NHDES collects emissions information fro m point source facilities within the state, tracks construction and modification actions by these faci lities, and monitors compliance and enforcementactivities. Data collection for the point source i nventory encompasses several types of report collat ion

and evaluation depending on the applicable air prog ram. Generally, reporting is made via three routes :

First, in accordance with CHAPTER Env-A 700 of New Hampshire’s air regulations, all permitted sources are required to submit annual emissions inv entories for the purpose fee calculation. Fees are assessed on a dollar per ton basis for each ton of pollutant emitted.

Second, in accordance with CHAPTER Env-A 900, NOx a nd VOC emission statements are required for sources having 10 tons per year actual emissions of NOx annually and 10 tons per year actual emissions of VOC annually.

Finally, most permitted sources are required to per form additional reporting to demonstrate compliance with various standards (e.g., National Ambient Air Quality Standards, New Hampshire Ambient Air Limits).

Reports for point sources subject to more than one of these programs were collected, collated, crossreferenced and if discrepancies existed, the point sources were contacted in order to determine correc t usages or emissions. Also, many of these sources h ave Continuous Emissions Monitoring Systems (CEMS) or have been stack tested. Both of these ty pes of data have been incorporated into the inventory.

Data for the point source emissions was collected b y the most complete means possible: from point source air program reporting, NOx and VOC emissions statements, reporting required by permits, field engineers, field trip reports, material purchase or ders, material safety data sheets (MSDS) and proces s rate information. It is important to note that the se reports required all of the information necessar y to calculate the emissions, and to categorize them by Source Classification Code (SCC). Reported information includes the process rate, the speciati on, the name of the solvent, the operating schedule

, the permitted emission limitation, and any control equipment as applicable. They also include New Hampshire specific factors, if developed.

A reasonableness check was performed on the informa tion provided by the reports. An emissions number was never accepted by itself, rather the dat a used to calculate that number was reviewed and, if accepted, the emissions were then recalculated i ndependent of the point source report. These emissions were cross-checked against the emissions reported in the 1990, 1996, 1999, 2002 and 2005 inventories, and in some cases, against SARA Title III information. Also, when entered into ISteps, t he in house emissions database, the calculations were redone and any math errors were detected since the computer itself does the emissions calculations

.

All of the sources have been extensively quality as sured by NHDES personnel when entering them into the EIS for the EPA reporting requirement. Therefo re, all of these sources have had the emissions calculated and verified at least twice and usually more. Most of the emissions entered into the EIS were done under method code 9, by which emissions a re calculated by ISteps based on the throughput
and emission factors entered. The ozone dailies we re calculated by ISteps which takes the annual emissions and multiplies it by the seasonal through put percentage then divides it by the number of days of operation during the ozone season. However , where CEM data was available, the ozone dailies were calculated both by the using the throu ghputs, emission factors and seasonal percentages as well as taking the ozone season CEM data and div iding it by the number of days of operation. In al l cases the ozone daily emissions were similar enough so that they were entered with method code 9 as
well.

Point source emissions for the 8-hour non-attainmen t area and for the entire state are summarized in Section 1 in Tables 1-1 through 1-4. Point source emissions by facility for the 8-hour non-attainment
area are shown in Tables 2-1 and 2-2 below. A more detailed summary of emissions by individual facility is provided in Appendix A, which has been submitted electronically with this documentation.Table 2-1: Point Source VOC Emissions for the 8-Hou r Non-Attainment Area

Facility Town VOC (pounds per summer day)

FOSS MANUFACTURING COMPANY INC HAMPTON 48

GENERAL ELECTRIC - SOMERSWORTH SOMERSWORTH 26

GEORGIA-PACIFIC GYPSUM LLC NEWINGTON 130

GOSS INTERNATIONAL AMERICAS INC - DURHAM DURHAM 27

HUTCHINSON SEALING SYSTEMS NEWFIELDS 147

LONZA BIOLOGICS INC - INTERNATIONAL DR PORTSMOUTH 7 2

NATIONAL GYPSUM COMPANY PORTSMOUTH 12

NEWINGTON ENERGY LLC NEWINGTON 3

NOVEL IRON WORKS INC GREENLAND 177

PARK NAMEPLATE COMPANY DOVER 50

PHILLIPS EXETER ACADEMY EXETER 2

PSNH - NEWINGTON STATION NEWINGTON 314

PSNH - SCHILLER STATION PORTSMOUTH 145

SPRAGUE ENERGY CORPORATION/RIVER ROAD NEWINGTON 1

SPRAGUE ENERGY CORP-SHATTUCK WAY NEWINGTON 14

TAPE-O CORPORATION DOVER 476

TEXTILE TAPES CORPORATION GONIC 57

TRELLEBORG SEALING SOLUTIONS US INC SOMERSWORTH 12

TURNKEY RECYCLING & ENVIRONMENTAL ENT ROCHESTER 128

UNIVERSITY OF NEW HAMPSHIRE DURHAM 32

AVILITE CORPORATION MANCHESTER 157

CUMMINGS PRINTING COMPANY HOOKSETT 350

DUNBARTON ENERGY PARTNERS LP MANCHESTER 2

ELECTROPAC COMPANY INC MANCHESTER 46

FREUDENBERG NOK - MANCHESTER MANCHESTER 81

G&K SERVICES COMPANY MANCHESTER 184

HARVEY INDUSTRIES INC LONDONDERRY 108

KALWALL PANELS & ACCESSORIES MANCHESTER 402

MOORE WALLACE MANCHESTER 36

NEXTERA ENERGY SEABROOK LLC SEABROOK 22

NYLON CORPORATION OF AMERICA MANCHESTER 1

OAK DESIGNS INC MANCHESTER 108

VELCRO USA INC - MANCHESTER MANCHESTER 211

ANHEUSER-BUSCH INC MERRIMACK 358

CORIUM CORPORATION SEABROOK 38

FOUR HILLS LANDFILL NASHUA 232

GATES MECTROL INC SALEM 154

GRANITE RIDGE ENERGY LLC LONDONDERRY 77

HITCHINER MANUFACTURING - WILTON ROAD MILFORD 205

NASHUA CORPORATION - MERRIMACK MERRIMACK 382

NORCROSS SAFETY PRODUCTS LLC NASHUA 320

PARKER CHOMERICS - 16 FLAGSTONE HUDSON 57

PRIMERO INC NASHUA 15

SAINT GOBAIN CERAMICS - IGNITER PRODUCTS MILFORD 29

SAINT GOBAIN PERFORMANCE PLASTICS MERRIMACK 181

SPEAR - NEW HAMPSHIRE MILFORD 66

TECHNICAL GRAPHICS INC MILFORD 65

Total 5,762Table 2-2: Point Source NOx Emissions for the 8-Hou r Non-Attainment Area

Facility Town NOx (pounds per summer day)

FOSS MANUFACTURING COMPANY INC HAMPTON 1,072

GENERAL ELECTRIC - SOMERSWORTH SOMERSWORTH 5

GEORGIA-PACIFIC GYPSUM LLC NEWINGTON 256

LONZA BIOLOGICS INC - INTERNATIONAL DR PORTSMOUTH 5 4

NATIONAL GYPSUM COMPANY PORTSMOUTH 186

NEWINGTON ENERGY LLC NEWINGTON 716

PHILLIPS EXETER ACADEMY EXETER 35
PSNH - NEWINGTON STATION NEWINGTON 9,516
PSNH - SCHILLER STATION PORTSMOUTH 7,917

SPRAGUE ENERGY CORPORATION/RIVER ROAD NEWINGTON 163

SPRAGUE ENERGY CORP-SHATTUCK WAY NEWINGTON 15

TAPE-O CORPORATION DOVER 1

TEXTILE TAPES CORPORATION GONIC 5

TRELLEBORG SEALING SOLUTIONS US INC SOMERSWORTH 3

TURNKEY RECYCLING & ENVIRONMENTAL ENT ROCHESTER 723

UNIVERSITY OF NEW HAMPSHIRE DURHAM 568

DUNBARTON ENERGY PARTNERS LP MANCHESTER 98

FREUDENBERG NOK - MANCHESTER MANCHESTER 93

G&K SERVICES COMPANY MANCHESTER 9

KALWALL PANELS & ACCESSORIES MANCHESTER 10

MOORE WALLACE MANCHESTER 5

NEXTERA ENERGY SEABROOK LLC SEABROOK 700

NYLON CORPORATION OF AMERICA MANCHESTER 19

VELCRO USA INC - MANCHESTER MANCHESTER 516

ANHEUSER-BUSCH INC MERRIMACK 342

FOUR HILLS LANDFILL NASHUA 110

GRANITE RIDGE ENERGY LLC LONDONDERRY 965

HITCHINER MANUFACTURING - WILTON ROAD MILFORD 53

NASHUA CORPORATION - MERRIMACK MERRIMACK 85

NORCROSS SAFETY PRODUCTS LLC NASHUA 2

SAINT GOBAIN PERFORMANCE PLASTICS MERRIMACK 47

Total 24,289

3. AREA AND NON-ROAD MOBILE SOURCES

As described in Section 1, area sources represent t hose emissions categories that are too widespread and/or numerous to be inventoried individually. In general, the calculations used to estimate area source emissions involve a descriptor of activity o r throughput multiplied by an emission factor. Examples of activity and throughput include populat ion, employment, and fuel consumption. The types
of area sources for which NHDES has made emissions estimates can be grouped into the following broad categories:

• Gasoline Marketing

• Degreasing (Surface Cleaning)

• Surface Coating

• Graphic Arts

• Asphalt Paving• Pesticide Use

• Commercial and Consumer Solvent Use

• Bakeries

• Waste Management Practices

• Underground Storage Tank Remediation

• Residential, Commercial, and Industrial Fuel Combu stion

• Accidental and Intentional Fires

Further, NHDES made emissions estimates for the fol lowing types of non-road mobile sources:

• Non-road vehicles as contained in EPA's NONROAD em issions model

• Aircraft, Airport Ground Service Equipment, and Au xiliary Power Units

• Locomotives

• Commercial Marine Vessels

The emissions estimates that were made for these ca tegories are described further in the sections that follow. However, the reader is referred to the ind ividual tabs in the attached spreadsheet tables for detailed information on the activity, emission fact ors, and other assumptions that were used in the emissions calculations for each subcategory. Area and non-road emissions estimates for the 8-hour
non-attainment area and for the entire state are sh own in Section 1 in Tables 1-1 through 1-4.

Additional emissions summaries can be found in the attached spreadsheet in Spreadsheet Tables 3-1 through 3-16. These summaries include VOC and NOx as well as the other criteria pollutants.
Detailed area and non-road mobile emissions summari es by source category are provided for the following geographic areas:

• Statewide (Spreadsheet Table 3-1)

• The former Seacoast 1-hour ozone non-attainment ar ea (Spreadsheet Table 3-2)

• The former Southern 1-hour ozone non-attainment ar ea (Spreadsheet Table 3-3)

• The former Marginal 1-hour ozone non-attainment ar ea (Spreadsheet Table 3-4)

• The 8-hour ozone non-attainment area (Spreadsheet Table 3-5)

• The former total 4-county 1-hour ozone non-attainm ent area (Spreadsheet Table 3-6)

• Belknap County (Spreadsheet Table 3-7)

• Carroll County (Spreadsheet Table 3-8)

• Cheshire County (Spreadsheet Table 3-9)

• Coos County (Spreadsheet Table 3-10)

• Grafton County (Spreadsheet Table 3-11)

• Hillsborough County (Spreadsheet Table 3-12)

• Merrimack County (Spreadsheet Table 3-13)

• Rockingham County (Spreadsheet Table 3-14)

• Strafford County (Spreadsheet Table 3-15)

• Sullivan County (Spreadsheet Table 3-16) 

### Note to Reader: Table numbers from this point forward refer to the
individual tabs in the Microsoft Excel workbook ent itled "NH 2008 PEI Section 3 Tables.xls," which has been submitted electronically along with this documentat ion.Population is an important variable that is used in the emissions calculations for many area source

categories. In many cases, it is also used to appo rtion emissions to the appropriate geographic regions. 2008 population data for New Hampshire wa s obtained from the New Hampshire Office of State Planning. Populations by town were used to a ssign population to the non-attainment areas. The population data used in the New Hampshire 2008 PEI is shown in Spreadsheet Table 3-17.

3.1 Gasoline Marketing

Gasoline marketing emissions estimates were made fo r the following subcategories and source classification codes (SCCs):

2501060050: Gasoline Service Stations Stage I: Tota l
2501060201: Gasoline Service Stations: Tank Breathi ng & Emptying 2505030120: Petroleum Product Transport, Truck, Gas oline

The activity factor used in the emissions calculati ons for these SCCs was gasoline throughput. The number of gallons of gasoline sold by month for 200 8 was obtained from the New Hampshire Department of Safety. These figures are shown in S preadsheet Table 3-18. The emission factors used for these SCCs were based on EIIP Volume III, Chapter 11, Gasoline Marketing (Stage I and II)

. For Stage I (delivery from truck to service station ), it was assumed that 99% of the gasoline in New Hampshire is dispensed with Stage I controls. Emis sions estimates for Stage II (vehicle refueling at the pump) have historically been calculated as an area source category using gasoline throughput and MOBILE6.2 emission factors. However, these emissio ns are now calculated using EPA's Motor Vehicle Emissions Simulator (MOVES) and are include d in the on-road mobile portion of the inventory. For the Stage I estimates, MOBILE6.2 refueling fact ors were developed and used to reflect the use of reformulated gasoline in New Hampshire's southern f our counties. MOBILE6.2 input and output files can be found in Appendix B, which has been submitte d electronically along with this documentation. Total emissions estimates for the gasoline marketin g category were as follows:

Gasoline Marketing (pounds per summer day)
VOC

8-hour NAA 618 Statewide 1,299

Detailed emissions and calculation summaries for th e gasoline marketing subcategories can be found in the attached spreadsheet as Spreadsheet Tables 3 -19 through 3-22.

3.2 Degreasing

Degreasing (or surface cleaning) emissions estimate s were made for the following SCC:

2415000000: Degreasing, All Processes, All Solvent Types

Emissions from degreasing activities were estimated using methodologies found in EIIP Volume III, Chapter 6, Surface Cleaning . The activity factor used in the calculations was employment. Data on the number employees by county for the applicable North American Industry Classification System (NAICS) codes was obtained from the U.S. Census Cou nty Business Patterns data series. A 20% reduction was applied to the emission factor to acc ount for VOC RACT per New Hampshire's 15% VOC Rate of Progress (ROP) plan for the 1-hour ozon e standard. Total emissions estimates for the degreasing category were as follows:

Degreasing (pounds per summer day)
VOC
8-hour NAA 11,279 Statewide 19,336Detailed emissions and calculation summaries for de greasing can be found in the attached

spreadsheet as Spreadsheet Table 3-23.

3.3 Surface Coating

Surface coating activities involve applying paints, varnishes, lacquers, and other materials to a wide variety of surfaces, including residential structur es, roadways, vehicles, and manufactured products. Surface coating emissions estimates were made for t he following subcategories and SCCs:

2401003000: Architectural Surface Coating - Water B ased 2401002000: Architectural Surface Coating - Solvent Based 2401008000: Traffic Markings 2401005000: Auto Body Refinishing 2401020000: Surface Coating, Wood Furniture 2401025000: Surface Coating, Metal Furniture 2401070000: Surface Coating, New Automobiles 2401055000: Surface Coating, Machinery & Equipment 2401075000: Surface Coating, Other Transportation E quipment 2401050000: Surface Coating, Misc. Finished Metals 2401015000: Surface Coating, Factory Finished Wood 2401065000: Surface Coating, Electronic & Electrica l Equipment 2401080000: Marine Coatings

For architectural surface coating, the activity fac tor used in the emissions calculations was gallons of paint, which was obtained from "2008 Quantity of Pa int & Allied Products", which can be found in Table
2 of the U.S. Census form MA325F. The nationwide e stimates of the amount of paints used were proportioned to New Hampshire using the ratio of Ne w Hampshire population to U.S. population. Similarly, for traffic markings, the quantity of pa int was obtained from the same reference. The estimated amount of traffic markings used in New Ha mpshire were obtained by using the ratio of New Hampshire highway spending to total U.S. highway sp ending (highway spending for maintenance & services). These figures were obtained from the U. S. Department of Transportation.

Employment data was used as the activity factor for the other surface coating categories. As describe d above for degreasing, this information was obtained from the County Business Patterns data series. Emission factors for all surface coating subcategor ies included adjustments to account for the regulations New Hampshire adopted to meet its 15% R OP plan for the 1-hour ozone standard, as some of those rules contained lower applicability thresh olds and thus required reductions at area sources. Many of the subcategories involve a variety of indu strial activities and facilities. Therefore, where applicable, point source subtractions were made to ensure that emissions were not double counted. Emissions estimates for the surface coating categor y were as follows:

Surface Coating (pounds per summer day)
VOC
8-hour NAA 18,784 Statewide 35,486

Detailed emissions and calculation summaries for th e surface coating subcategories can be found in the attached spreadsheet in Spreadsheet Tables 3-24 through 3-36.

3.4 Graphic Arts

Emissions estimates for the graphic arts category w ere made for the following SCC:

2425000000: Graphic Arts, Total, All Solvent TypesThe methodology used in the calculations was taken from EIIP, Chapter 7, Graphic Arts and used population as an activity factor. Since printing a nd other activities that fall under this category c an occur at fairly large facilities, point source emis sions associated with graphic arts were subtracted to eliminate double counting.

Emissions estimates associated with the Graphic Art s category were as follows:

Graphic Arts (pounds per summer day)
VOC
8-hour NAA 3,246 Statewide 5,356

Detailed emissions and calculation summaries for th e graphic arts category can be found in the attached spreadsheets in Spreadsheet Table 3-37.

3.5 Asphalt Paving

Emissions estimates for the asphalt paving category were made for the following SCC:

2461022000: Emulsified Asphalt

The activity factor for the asphalt paving category is gallons of asphalt paved. During the 2002 PEI cycle, the number of gallons of asphalt paved was o btained from the NH Department of Transportation. Similar data for calendar year 2008 (or other recen t year) were not readily available. Therefore, EPA 's Economic Growth Analysis System (EGAS) Version 5.0 was used to grow the 2002 activity data to 2008. The emission factor for this category was de veloped during the 1999 PEI cycle and assumed that 37% of the asphalt is emulsifier and that 9.5% of the emulsifier is VOC. The calculations also assumed 75% evaporation and a density of 8.34 lb/ga llon. Emissions for this category were apportioned to the counties using the total number of lane miles. Emissions estimates for the asphalt paving category were as follows:

Asphalt Paving (pounds per summer day)
VOC
8-hour NAA 3,399 Statewide 9,276

Detailed emissions and calculation summaries for as phalt paving can be found in the attached spreadsheet in Spreadsheet Table 3-38.

3.6 Pesticide Application

Emissions estimates for pesticide application were made for the following SCC:

2461850000: Pesticide Application, Agricultural

Data on the amount of pesticide applied was obtaine d from the NH Department of agriculture. The most recent readily available data was for calendar year 2003. It was felt that this activity would n ot necessarily follow any particular economic trends, and therefore it was assumed that 2003 would be adequately representative of 2008 for this category . Emission factors and calculation methodologies came from EIIP Volume III, Chapter 9, Pesticides - Agricultural and Nonagricultural . Emissions were apportioned to the individual counties using agricu ltural acreage, which was obtained from the 2007 Census of Agriculture. Emissions estimates for pes ticide application were as follows:Pesticide Application (pounds per summer day)
VOC

8-hour NAA 570 Statewide 2,210

Detailed emissions and calculation summaries for th is category can be found in the attached spreadsheet in Spreadsheet Table 3-39.

3.7 Commercial and Consumer Solvent Use

Emissions estimates for solvent use were made for t he following SCC:

2460000000: Solvent Utilization, Miscellaneous Non- Industrial, Total

Calculations for this category were based on EIIP V olume III, Chapter 5, Solvent Use . The emission factor that was used incorporated an adjustment to account for the regulations New Hampshire adopted to meet its 15% ROP plan for the 1-hour ozo ne standard, and the activity factor was based on population. Emissions estimates for this category were as follows:

Commercial and Consumer Solvent Use (pounds per sum mer day)
VOC
8-hour NAA 13,712 Statewide 24,749

Detailed emissions and calculation summaries for co mmercial and consumer solvent use can be found in the attached spreadsheet as Spreadsheet Table 3- 40.

3.8 Bakeries

Emissions estimates for this category were made for the following SCC:

2302050000: Food & Kindred Products, Bakery Product s

Calculations were based on EIIP Volume III, Area Source Method Abstracts - Bakeries and used population as the activity factor. The emission fa ctor was based on the straight dough baking process

, and a consumption factor of 70 lb/person was assume d. Emissions estimates for bakeries were as
follows:

Bakeries (pounds per summer day)
VOC

8-hour NAA 70
Statewide 126

Emissions and calculation summaries for bakeries ca n be found in the attached spreadsheet as Spreadsheet Table 3-41.

3.9 Waste Management Practices

Emissions estimates for waste management were made for the following SCCs:

2630020000: Waste Water Treatment, Publicly Owned 2620000000: Landfills, All Categories 2680001000: Bio-Solids Composting 2680002000: Mixed Waste CompostingEmissions estimates for wastewater treatment have b een carried forward from historical inventories

starting in 1996. The original methodologies were taken from Section 3.5.1 of Procedures for the Preparation of Emissions Inventories for Carbon Mon oxide and Precursors of Ozone, Volume I: General Guidance for Stationary Sources . The activity for this category, millions of gall ons per day of wastewater treated, were grown from the historical data using EGAS to obtain estimates for more recent inventories, including the 2008 PEI.

Emissions for landfills were estimated with EPA's L andfill Gas Emissions Model (LandGEM) Version 3.02 using the latest available data on landfill ca pacity for landfills throughout the state. Two of the state's largest landfills, Four Hills Landfill in N ashua and Turkey Recycling & Environmental Enterpri ses in Rochester, are inventoried as point sources and are therefore not included in the area source
estimates described here.

Also included in the waste management category are bio-solids composting and mixed waste composting. These estimates were taken from an amm onia emissions inventory prepared for the MidAtlantic Regional Air Management Association (MARAM A) as documented in Technical Memorandum: MANE-VU 2002 Ammonia Emissions Inventory for Miscel laneous Sources, Final , dated March 31, 2004. Emissions estimates for the waste management practices category were as follows:

Waste Management Practices (pounds per summer day)
VOC

8-hour NAA 985 Statewide 1,918

Emissions and calculation summaries for waste manag ement practices are presented in Spreadsheet Tables 3-42 through 3-45.

3.10 Underground Storage Tank Remediation

Emissions estimates for underground storage tank re mediation were made for the following SCC:

2660000000: Leaking Underground Storage Tanks

The methodology for this category was carried forwa rd from historical inventories that estimated 0.75 tons of VOC per remediation. The number of remedia tion events for 2008 was obtained from the NHDES Waste Management Division, Oil Remediation & Compliance Bureau, resulting in the following emissions estimates for this category:

Underground Storage Tank Remediation (pounds per su mmer day)
VOC

8-hour NAA 125
Statewide 226

Emissions and calculation summaries for this catego ry are shown in the attached spreadsheet in Spreadsheet Table 3-46.

3.11 Area Source Fuel Combustion

Area source fuel combustion emissions estimates wer e made for the following SCCs:

2104006000: Residential Natural Gas Combustion
2104004000: Residential Distillate Combustion
2104007000: Residential LPG Combustion
2104008000: Residential Wood Combustion
2103001000: Commercial Coal Combustion2103006000: Commercial Natural Gas Combustion

2103004000: Commercial Distillate Combustion
2103007000: Commercial LPG Combustion
2103008000: Commercial Wood Combustion
2102006000: Industrial Natural Gas Combustion
2102004000: Industrial Distillate Combustion
2102007000: Industrial LPG Combustion
2102005000: Industrial Residual Combustion

The methodologies for the area source fuel combusti on category came primarily from EIIP Volume III and AP-42. The activity factor for the combustion source categories was the amount of each fuel type burned. This data was obtained from the U.S. Depar tment of Energy, Energy Information Administration (EIA). Data was available for New H ampshire for each fuel type for the residential, commercial, and industrial sectors. Point source f uel use was obtained from the NHDES Air Emissions Inventory and Reporting program and subtracted from the EIA statewide fuel consumption figures. The remaining fuel consumption figures were assumed to apply to the area source category. In the case of industrial wood, the net remaining fuel use after s ubtraction was zero, implying that all industrial w ood combustion occurs at permitted point sources.

For the residential sector, the activity data was a pportioned to the counties by the number of houses that use each fuel type and by heating degree days. For the commercial sector, the data was apportioned by heating degree days and employment, and for the industrial sector, the data was apportioned by employment. Housing data by fuel ty pe was obtained from the U.S. Census, and heating degree day data was obtained from the Natio nal Climactic Data Center. Detailed information on the fuel consumption and apportionment data that was used in the area source fuel combustion estimates can be found in Appendix C, which is encl osed electronically with this submittal.

Detailed emissions summaries and calculations for e ach area source fuel combustion category can be found in the attached spreadsheet in Spreadsheet Ta bles 3-47 through 3-59. As mentioned earlier, the activity data described above was multiplied by emi ssion factors obtained primarily from EIIP and AP42. The exception was the residential wood combust ion category - these estimates were derived using EPA's Residential Wood Combustion Tool, Version 3 M V. Emissions estimates for the area source fuel combustion category were as follows:

Area Source Fuel Combustion (pounds per summer day)
VOC NOx
8-hour NAA 3,001 6,512 Statewide 5,992 12,480

3.12 Accidental and Intentional Fires

Emissions estimates for accidental and intentional fires were made for the following SCCs:

2810030000: Structure Fires
2810050000: Vehicle Fires 2610000100: Open Burning, Yard Waste, Leaves 2610040400: Municipal Yard Waste Burning

The methodologies for structure fires and vehicle f ires came from EIIP Volume III, Chapter 18,
Structure Fires

and Volume III Method Abstracts, Vehicle Fires . Data on the number of structure and
vehicle fires in the U.S. came from a 2009 National Fire Protection Association Document entitled Fire Loss in the United States During 2008 . The number of fires that occurred in New Hampshi re was estimated using the proportion of New Hampshire pop ulation to U.S. population. Data were further apportioned to the New Hampshire counties using pop ulation.Estimates for open burning of yard waste and munici pal yard waste burning were taken from a report

prepared for the Mid-Atlantic/Northeast Visibility Union (MANE-VU) entitled Open Burning in Residential Areas, Emissions Inventory Development Report , January 31, 2004. Because the estimates in this report were for 2002, they were g rown to 2008 using EGAS. Emissions estimates for
accidental and intentional fires were as follows:

Accidental and Intentional Fires (pounds per summer day)
VOC NOx

8-hour NAA 87 16
Statewide 177 35

Detailed emissions and calculation summaries for th ese categories can be found in the attached spreadsheet in Spreadsheet Tables 3-60 to 3-63.

3.13 NONROAD Model Sources

Emissions estimates were made for the following SCC s and categories, which are included in EPA's
NONROAD emissions model for non-road vehicles and e quipment:

2260000000: Off-Highway Vehicles, 2-Stroke Gasoline 2265000000: Off-Highway Vehicles, 4-Stroke Gasoline 2267000000: Off-Highway Vehicles, LPG 2268000000: Off-Highway Vehicles: CNG 2270000000: Off-Highway Vehicles: Diesel

As described in Section 1, the non-road emissions s ource category includes vehicles that generally do not travel on public roadways. This category inclu des a wide variety of vehicles and equipment including construction equipment; recreational vehi cles such as snowmobiles and ATVs; and lawn and garden equipment such as lawnmowers, trimmers, and chain saws. For these types of equipment, emissions were estimated using the EPA's NONROAD200 8a model for estimating emissions from nonroad vehicles. The NONROAD model does not include aircraft, locomotives, or commercial marine vessels; these categories are discussed in the sect ions that follow. NONROAD model input files (*.OPT files) have been provided electronically in Appendix D. Emissions estimates for the non-road
vehicles contained in the NONROAD model are shown b elow. It is important to note that these estimates do not include airport ground service equ ipment (GSE). Estimates for airport GSE were made separately and are discussed further in Sectio n 3.14.

Non-Road Vehicles contained in NONROAD (pounds per summer day)
VOC NOx
8-hour NAA 32,891 26,710 Statewide 97,351 53,115

More detailed emissions estimates for NONROAD model sources are shown in the attached spreadsheet in Spreadsheet Tables 3-64 to 3-68.

3.14 Aircraft, Ground Service Equipment, and Auxili ary Power Units

Aircraft emissions estimates were made for the foll owing SCCs:

2275020000: Commercial Aircraft
2275060000: Air Taxis
2275050000: General Aviation 2275001000: Military Aircraft 2270008000: Airport Ground Service Equipment and Au xiliary Power UnitsManchester-Boston Regional Airport is New Hampshire 's largest airport. It serves northern New

England and serves as an alternative airport for th e greater Boston area. Emissions estimates for all aircraft-related categories at Manchester Airport w ere estimated using the Federal Aviation Administration's (FAA) Emissions Dispersion Modelin g System (EDMS) Version 5.1.2. These estimates were made on behalf of the airport by KM Chng Environmental Inc. and documented in their report, Manchester-Boston Regional Airport

, 2008 Airport Emissions Inventory, dated September 2010. As mentioned above, these estimates addressed all a ircraft-related activity at the airport, including commercial, commuter, general aviation, and militar y aircraft as well as ground support equipment (GSE) and auxiliary power units (APUs).

Emissions estimates for other airports in New Hamps hire were made by NHDES using aircraft activity data taken from the FAA Air Traffic Activity Data S ystem (ATADS) and the GCR & Associates 5010Web website. The unit of activity for aircraft emissions estimates is the landing-takeoff operati on (LTO), which represents a complete takeoff and land ing cycle. Specific phases of flight represented b y the LTO include taxi out, takeoff, climb out, appro ach, landing, and taxi in. LTO activity data was multiplied by emission factors taken from reference s such as Procedures for Emission Inventory Preparation, Volume IV: Mobile Sources dated 1992 and Documentation for Aircraft Component of the National Emissions Inventory, Methodology dated December 15, 2009.

Emissions estimates for aircraft, ground support eq uipment, and auxiliary power units were as follows:

Aircraft, GSE, and APUs (pounds per summer day)
VOC NOx
8-hour NAA 443 1,171 Statewide 655 1,206

Detailed emissions summaries for aircraft, GSE, and APUs can be found in the attached spreadsheet in Spreadsheet Tables 3-69 through 3-73. Further d etails, including activity and emission factor data

, can be found in Appendix E, which is submitted elec tronically along with this documentation. Please note that all GSE and APUs have been lumped under a single SCC (2270008000) in this documentation (although estimates were made for GSE of all fuel types, a breakdown by fuel type was not available).

3.15 Railroad Locomotives

Locomotive emissions estimates were made for the fo llowing SCC:

2285002006: Railroad Locomotives

The activity factor for this category is the gallon s of diesel fuel consumed by the railroads. This d ata was obtained by surveying the railroad companies th at operate in New Hampshire. In many cases, the railroad companies were able to provide fuel use da ta for their locomotive operations in New Hampshire for 2008. For existing railroad companie s that did not respond to the survey, the fuel use data that was used for previous inventory cycles wa s grown to 2008 using EGAS. Emission factors
were drawn from Technical Highlights, Emission Factors for Locomoti ves , dated April 2009. Locomotive emissions were apportioned to the indivi dual counties using track miles.

Emissions estimates for locomotives were as follows :

Locomotives (pounds per summer day)
VOC NOx
8-hour NAA 60 1,506 Statewide 221 5,566

A more detailed emissions summary for locomotives c an be found in the attached spreadsheet inSpreadsheet Table 3-74. Further details, including activity data and emission factors, can be found i n

Appendix F, which is included electronically with t his submittal.

3.16 Commercial Marine Vessels

Commercial marine vessel (CMV) emissions estimates were made for the following SCCs:

2280002200: Commercial Marine Vessels, Underway Emi ssions 2280002100: Commercial Marine Vessels, Port Emissio ns

Emission factors used in the emissions estimates fo r CMVs were taken primarily from Chapter 7 of Final Regulatory Support Document: Control of Emiss ions from New Marine Compression-Ignition Engines at or Above 30 Liters per Cylinder , dated January 2003. Additional emission factor d ata was taken from the MANE-VU Marine Non-road Source Category Calculation Methodology Sheet

. Additional information used in the calculations inc luded assumptions about the amount of time that each vessel spends in the various phases of operati on (i.e. cruise, reduced speed zone, maneuvering, and hotelling) and the engine load factor associate d with each phase. The data used for these assumptions were based on Commercial Marine Activity for Deep Sea Ports in th e United States, Final Report , dated September 1999.

All major commercial marine vessel activity in New Hampshire occurs in the port of Portsmouth in Rockingham County. Monthly pilot reports for the p ort of Portsmouth were obtained from the Pease Development Authority for 2008. These reports prov ided the name of each vessel that made a call to port, the date of its arrival and departure, its de ad weight tonnage, and the horsepower of its assist tugs. These reports provided the activity data nec essary to make the emissions estimates using the emission factors and operational assumptions descri bed above. In some cases, it was clear from the pilot reports that the visiting vessel made a shift from one dock to another during its stay in port. In these particular instances, only the emissions asso ciated with maneuvering and the assist tugs were accounted for. Emissions for the other phases of o peration were accounted for on the days when the vessel arrived and departed. For most cases, howev er, the vessel remained at one dock or terminal during its stay, allowing emissions to be calculate d for a single, complete cycle of operation.

Emissions estimates for CMVs are shown below. The port of Portsmouth, where all major CMV activity in New Hampshire occurs, lies entirely within the 8 -hour ozone non-attainment area.

Commercial Marine Vessels (pounds per summer day)
VOC NOx
8-hour NAA 118 1,977 Statewide 118 1,977

CMV emissions estimates for underway and in-port ar e shown in the attached spreadsheet in Spreadsheet Tables 3-75 and 3-76, respectively. De tailed data and calculations for CMVs are provided in Appendix G, which is submitted electronically wi th this documentation.

4. ON-ROAD MOBILE SOURCES

As described in Section 1, on-road mobile sources r epresent vehicles that operate principally on roadways; this includes cars, trucks, buses, and mo torcycles. Historically, the method used to
calculate emissions from on-road mobile sources was to multiply vehicle activity times an emission factor. On-road vehicle activity is commonly expre ssed in units of vehicle miles traveled (VMT). In the past, emission factors were derived from MOBILE6.2. For this 2008 inventory however, NHDES used the MOVES model (MOVES2010a). Further, using VMT, vehicle population, and other input data, NHDES ran MOVES in inventory mode to produce on-roa d mobile emissions estimates directly rather than use the historic activity times emission facto r approach.NHDES obtained 2008 VMT from the New Hampshire Depa rtment of Transportation and from the

Metropolitan Planning Organizations (MPOs) that com prise the 8-hour ozone non-attainment area. VMT were provided by town, allowing it to be distri buted to the applicable geographic regions, includi ng the counties and the non-attainment area. The MPOs derived VMT using the traffic demand models set up for their specific planning areas. Together , the MPOs' planning areas comprise New Hampshire's 8-hour non-attainment area. Therefore, the VMT that was obtained from the MPOs and
that was used to derive the on-road mobile source e missions estimates was specific to the 8-hour nonattainment area. Vehicle population data were obta ined from the New Hampshire Department of Safety and from the MPOs.

On-road mobile source emissions estimates are summa rized in Section 1 in Tables 1-1 through 1-4. As mentioned in Section 3.1, these estimates includ e emissions from Stage II vehicle refueling activit y. Detailed MOVES input files have been submitted elec tronically as part of the overall submittal package for the re-designation request for the 8-hour ozone non-attainment area.

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### ATTACHMENT H

Projected 2012 and 2022 Emissions Inventories

(Files available on accompanying CD.)