# State of Maine

Department of Environmental Protection Clean Air Act Section 182 (f) NO, Waiver Petition



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BUREAU OF AIR QUALITY

October 13, 2012

### Table of Contents

I. EXECUTIVE SUMMARY . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2 II . BACKGROUND INFORMATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . .. 2 111. APPLICABLE EPAGUIDANCE FORNO,CONTROL REQUIREMENT EXEMPTIONS . . . . . . . . . . . . .. . 3 IV . SCOPE OF EXEMPTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . 4 V . BASIS OF THIS PETITION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . 4 VI . TECHNICAL DOCUMENTATION. .. . ... . .. .. .. .. .. .. .. .. ... . .. .. .. .. ... . .. .. .. .. ... . .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. 4

A . OZONE BACK TRAJECTORY ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . 7 B . NOZ DATAANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 C . REGIONAL HAZE ANALYSES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . 8 VII . SUMMARY OF RESULTS AND CONCLUSIONS FORTHIS PETITION. .. . . . . . . . . . . . .. . . . . . . . . . . . . . . .. .. . 13 VIII . REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 APPENDIX A- HYSPLIT TRAJECTORY DOCUMENTATION LIST OF FIGURES: Figure I - Northeastern U .S. Counties Ozone Designation with Class I Areas used in Regional Haze Analyses. . .. .. . ... .. . .... . ..6 Figure 2- Back Trajectories fromCT and Martha's Vineyard 2009-11 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . .7 Figure 3- Portland, Maine Daily Maximum1-hour Nitrogen Dioxide (N02) Concentrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8 Figure 4- Nitrate Extinction 10 mBack Trajectories for Northeast Class I Areas When Nitrate Extinction is

30 Mm" and above . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Figure 5- Nitrate Extinction 10 m Back Trajectories for Northeast Class I Areas When Nitrate Extinction is between 15through 29 Mm"' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .12 LIST OF TABLES: Table 1 - 2008 NEI NO,, Emissions Inventory by State . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . 5 Table 2 - Percent of Contribution to Light Extinction at Northeastern U .S. Class I Areas . . . . . . . . . . . . .. . . . . . . . . . .. 9 Table A-1- Statistics on the Regional Haze Data Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . A-2I . Executive Summary

EPA previously granted the State of Maine, CleanAir Act (CAA) §182(f) NO,, Waivers for nine counties under the 1-hour and 8-hour 1997 Ozone National Ambient Air Quality Standards (NAAQS)

. Since then a new8-hr Ozone NAAQS was promulgated in 2008, a 1-hour NOZ NAAQS was promulgated in 2010 and Maine's Regional Haze SIP was approved in 2012. The entire State of Maine is in attainment for the 2008 8-hr Ozone NAAQS. Monitored NOZ data is well below

the 1-hr N02 NAAQS. Regional Haze values in Maine are trending down and are below the SIP modeling glide path fromthe baseline to 2018. Per EPAguidance, photochemical grid modeling is not applicable in this case. Consequently, the analyses consist of: emissions inventory data for the Ozone Transport Region (OTR), back trajectories for ozone exceedance days, N02data in Maine alongwith Regional Haze trends and trajectory analyses. The Maine Department of Environmental Protection's Bureau ofAir Quality (MEDEP) is able to demonstrate that Maine does not contribute to nonattainment of ozone in the 8-hour Ozone NAAQS Nonattainment areas within the OTR . Thus, reductions of NOXemissions in Maine are not necessary to bring the ozone non-attainment areas in the OTR into attainment. Since Maine's monitored N02 values are well belowthe 1-hr N02 NAAQS, reductions of NOX emissions are not necessary for attainment. Furthermore, MEDEP is also able to demonstrate that Maine's NOXemissions do not significantly contribute to visibility degradation at any Class I Area in the Northeastern United States. MEDEP is therefore requesting a CAA §182(f) NOX Waiver under the 2008 8-hour Ozone NAAQS for the entire State ofMaine. II . Background Information Oxides of nitrogen (NOX) emissions are precursors to ground level (tropospheric) ozone. When released into the atmosphere, NOX will react with volatile organic compounds (VOC) in the presence of sunlight to form ozone. Tropospheric ozone is an important contributor to the nation's urban and rural air pollution problem . In 2004, the US Environmental Protection Agency (EPA) designated and classified 8-hour Ozone NAAQS nonattainment areas in Maine based on the 1997 Ozone NAAQS of an 8-hour average of 0

.08 parts per million. Those areas were Portland, ME - Subpart 2 Marginal Nonattainment (includes: Sagadahoc county and parts of Cumberland, York and Androscoggin counties) and Hancock, Knox, Lincoln andWaldoCounties - Subpart 1 Nonattainment (includes parts of each of the counties listed in the name) . These 8-hour ozone nonattainment areas were later re-designated as attainment which was posted as a final rule in the Federal Register on December 11, 2006

. In 2008, the new8-hour Ozone NAAQS was promulgated at 0 .075 parts per million which is equivalent to 75 parts per billion (ppb)

. Designations for the 2008 Ozone NAAQS were finalized on April 30, 2012. Design values for the entire State of Maine are currently below the 2008 8-hr Ozone NAAQS and have been for two years. Consequently, all of Maine has been designated as unclassifiable/attainment for the 2008 Ozone NAAQS.Pursuant to the CleanAirAct Amendments of 1990 (CAAA), the entire State of Maine is part of

the OTR . The OTR is a portion of the northeastern U .S. comprised of the six New England states; NewYork, NewJersey, Pennsylvania, Maryland, Delaware, and the Consolidated Metropolitan Statistical Area that includes the District of Columbia and part ofnorthern Virginia (see CAAA Section 184(a)) . The purpose of creating this region was to require regional control strategies on ozone precursor emissions to address the problemofregional transport across state boundaries within the context ofthe State Implementation Planning process. All areas within the OTR became subject to a number ofadditional requirements. Existing major sources of NOX in the OTRare required to reduce NOX emissions through NOX Reasonably Available Control Technology (RACT) . In addition, new major stationary sources and major modifications of NOX which are located in the OTR are subject to a 1 .15 emission offset requirement (see CAA Sections 182 (b) (5), 184 (b) (2), 182 (f) and MEDEP Regulations Chapter 113 (2) (C)) . The NOXRACT requirement as well as the Lowest Achievable Emissions Rate (LAER) and 1 .15 NOX emission offset requirements hinder economic sustainability and development in Maine. The 1-hour N02 NAAQS was promulgated on January 22, 2010 with designations final on January 20, 2012. EPA designated all areas of the country as unclassifiable/attainment. EPA stated that near-road monitors would be required to demonstrate compliance. Portland Maine's Deering Oaks monitoring site has not been declared an official near-road monitor; however MEDEPbelieves that this site currently provides the best representative data. Maine's Regional Haze SIP was approved on April 24, 2012. EPAhas stated that the SIPs need to be done every tenyears. Amid-coarse review at the five year mark is required to demonstrate whether or not the state is meeting the baseline to 2018 SIPmodeled glide path. 111. Applicable EPAGuidance for NOx Control Requirement Exemptions The CAA specifies in Section 182 (f) (1) that NOX requirements shall not apply if the Administrator determines that any one ofthe following tests is met:

In any area, the net air quality benefits are greater in the absence of NO,, reductions fromthe sources concerned; In nonattainment areas not within an ozone transport region, additional NO, reductions would not contribute to ozone attainment in the area; or In nonattainment areas within an ozone transport region, additional NO, reductions would not produce net ozone air quality benefits in the transport region. In addition, Section 182 (f) (2) (A) states that the application of the NOX requirements may be limited to the extent that any portion of those reductions is demonstrated to result in "excess reductions" of NO,{. The NOx requirements of the conformity rules would also not apply in anarea that is granted a Section 182 (f) exemption. Furthermore, certain NOX provisions of the

inspection and maintenance (I/M) requirements would not apply in an area that is granted a Section 182 (f) exemption (not applicable to the areas currently seeking exemptions) . The EPA's Guideline for Determining the Applicability of Nitrogen Oxides Requirements under Section 182 (f) describes how the EPA intends to interpret the NOX exemption provisions of Section 182 (f). IV. Scopeof Exemptions If the EPA Administrator determines, under Section 182 (f) of the CAA, that additional reductions of NOXwould not contribute to attainment of Ozone NAAQS, or are in excess to the reductions necessary for attainment, the area at issue shall automatically (i .e., a State would not need to submit an exemption request for each requirement) be exempt from the following requirements (as applicable) : the NOX related general and transportation conformity provisions, NOX RACT, offsets, LAER, and nonattainment area requirements under CAA Section 173 for existing sources, newsources and modifications that are major for NOx. Additionally, NOX emission reductions would not be required of an enhanced inspection/maintenance (I/M) program . V . Basis of this Petition The Maine DEPbases itspetition on: a demonstration that NO ., emissions in the State are not impacting nonattainment areas in the OTR during times when elevated ozone levels are monitored in those areas; and also on a demonstration that NO ., emissions in the State are not significantly contributing to visibility degradation at any MANE-VUClass IArea. Current N02data in the largest city in Maine is demonstratingcontinued compliance with the NAAQS . These conclusions are derived from the supporting analyses. As such, reductions in NO, emissionsfromMaine are not necessaryfor ozone attainment in these upwind areas and are excess to attainment under Section 182 (f) (2). Additionally, reductions in NO, emissions fromMaine are not necessaryfor MANE-VUClassJ'Areas to remain at or below the baseline to 2018SIPmodeledglidepaths. Consistent with EPA's Section 182 (f) guidance, the State's excess emissions reductions demonstration is tied to the attainment demonstration SIP required by the CAAA . The State of Maine will use a trajectory analysis to demonstrate that major source nonattainment requirements under CAA Section 173 for major source NOX RACT, major newsources and major modifications including LAER, and offsets requirements in the State are excess to the reductions necessary to attain the NAAQS for ozone in the nonattainment areas in the OTR . VI . Technical Documentation The purpose ofthis technical documentation is to support a demonstration that stationary source emissions fromMaine do not contribute to ambient ozone in excess ofthe NAAQS, violations ofN02 nor significantly to Regional Haze. Thus, reductions of NO, emissions in Maine are not

necessary to bring the non-attainment areas in the OTRinto attainment. In Chapter 7 of the Guidance on Limiting Nitrogen Oxides Requirements Related to 8-hour Ozone Implementation3, EPA states that "photochemical grid modeling is generally needed to document cases where NOX reductions . . . include excess reductions." The next paragraph states: "It is important to note that EPA believes that photochemical grid models are not sufficient to assess incremental changes to area wide ozone concentrations from emissions reductions at a single or group of small sources. Emission changes should amount to some significant fraction of base emissions before modeling results can be interpreted with sufficient confidence that the results are not lost in the noise ofthe model and the input data. The EPAhas reservations with respect to modeling NOX reductions at a single source or group of sources unless the modeling includes at least 10%of the domain-wide emissions." EPA retains the discretion to adopt approaches on a case-by-case basis that differ fromthe NOXWaiver guidance where appropriate. Thetotal annual NOx emissions for the entire State of Maine are small, less than 3%ofthe OTR as displayed in Table 1 . Therefore, any reductions would be miniscule. So it is consistent with EPA's position, stated above, that photochemical grid modeling is not a viable analysis for Maine at this time.



### Table 1 : 2008 NEI NOX Emissions Inventory by State: OTR State Annual NOX Emissions (TPY) Connecticut 8593.24 Delaware 13849.35 District of Columbia 579.88 Maine 16761 .04 Maryland 56790.36 Massachusetts 23167.30 New Hampshire 6969.19 New Jersey 28709.12 New York 78082.37 Pennsylvania 254591 .50 Rhode Island 1630.71 Vermont 501 .28 Virginia 103626.50 OTRTotal 593851 .84 Maine's Contribution 2.82%

Several analyses center on whether or not Maine contributes to nonattainment or to visibility degradation. In order to provide a geographic understanding ofthe region, Figure 1 displays the2008 Ozone Nonattainment Designations with the Class I Areas in the Northeastern United

States. 

## Figure 1 : Northeastern U.S. Counties Ozone Designation

with Class I Areas used in Regional Haze Analysis

Created by Martha Webs[er MEDEP revised 5i14f12 based on EPA's 2008 Designations Legend * Class 1 Locations County Designation county2012map ' Unclassifiable/Attainment ® NonattainmentA

. OZONE BACK TRAJECTORYANALYSIS MEDEPAir Quality Meteorologists conducted a trajectory analysis of ozone exceedance days for the 2009 through 2011 ozone seasons. Atrajectory was created for each hour that ozone levels were equal to or greater than 75 ppb for every day that an 8-hour ozone exceedance was recorded. The analysis was conducted for monitoring sites in the nearest 2008 Ozone NAAQS Ozone Nonattainment Areas (which are the State of Connecticut and Martha's Vineyard in Massachusetts) . Figure 2 displays the hourly endpoints fromback trajectories calculated for all days when sites in CT and Martha's Vineyard exceeded the 2008 Ozone NAAQS. It is clear that Maine does not contribute to ozone nonattainment within the OTR . Furthermore, transportation patterns haven't changed since Maine's last NOXWaiver was requested in 2005.

backirajectorivsat M

., 160mand 250mAOL r ~.1ae,a'Neb~ar, Veins I3EP 11072011B

. N02 DATA ANALYSIS EPA promulgated a 1-hour N02 NAAQS on February 9, 2010 . EPA has stated that near-road monitoring is required to demonstrate compliance. Portland is Maine's largest city and includes many of the State's most heavily trafficked roads. The Deering Oaks Park monitor is located just off Interstate 295 near the intersection of Forest Avenue and State Street. This monitor began collecting data February 6, 2008. The chart belowincludes quality assured data through May 31, 2012. The daily maximum of hourly data from this site clearly demonstrates compliance with the 1-hour NOZ NAAQS as displayed in Figure 3 . Figure 3: PORTLAND, MAINE DAILY MAXIMUM1-HOUR NITROGEN DIOXIDE (N02) CONCENTRATIONS

S a _o . c 0 r m w c m 0 c 0 v

" 7-hr MAX Portland-DEERING OAKS - NAAQS C . REGIONAL HAZE ANALYSES NO, emissions not only contribute to the formation of ozone, but also to Regional Haze. Therefore, it is important to consider how Maine's NO, Waiver could impact Regional Haze in the Northeastern United States. Based on analyses conducted for MANEVU (Mid-Atlantic Northeast Visibility Union), Sulfate accounts for one halfto twothirds oftotal fine particle mass on the 20 percent haziest days (20%worst) at all Class I areas in the northeast. Organic carbon typically consumes another 20 to 30 percent of total fine particle mass on the haziest days. Nitrates, elemental carbon (EC) and fine soil (FS) together are estimated to account for ten percent or less of the overall fine particulate mass. Nitrate is higher than EC and FS in urban areas most likely due to motorvehicle and other urban pollution sources.In addition to total fine particle mass, visibility parameters must be accounted for. The data"

used in the analysis is the most recent quality assured data using the new revised Interagency Monitoring of Protected Visual Environments (IMPROVE) algorithm . The results presented here were part of a larger analysis created for MANEVU. The data was downloaded and compiled in Excel for the following Class I Areas in the MANEVUregion: " Acadia National Park in Maine, " Moosehorn National Wildlife Refuge in Maine, " Great Gulf Wilderness Area in New Hampshire, " Lye BrookWilderness Area in Vermont, and " Brigantine National Wildlife Refuge in New Jersey. Note: the first four Class I Areas listed above are in New England. Table 2presents the relative contributions to light extinction for the 20%best (cleanest) and 20% worst (haziest) visibility days due to the following particles in the atmosphere: ammonium sulfate, ammoniumnitrate, organic mass, light absorbing carbon, fine soil, coarse mass (PMIo), sea salt, and Rayleigh scattering. Table 2 : PercentofContributfontoLight Extinctionat Northeasterni1.5.CtassIAreas

0 YI

w Ammonium Lightabsorbing sutfate961ight Ammonium nitrateorganicmass9L carbonBGiight Pinesoi19611ght coarsemass96 5eaSaft'%ItghtRayk:igh9blight site extinction 96fightextinction 1ightextinction extinction extinction tightextinction extinction extinction Baseline2000-2004 Average Acadia NP 63 .32 7.66 10 .19 4.04 0.48 1 .79 1.30 11 .22 Mooseharn 60 .02 6.83 1218 4 .53 0.40 2 .25 1.12 12 .67 GreatGulf 67.59 2.75 12 .76 3

.54 0.51 273 0 .12 10

.01 LyeBrook 66 .98 7.18 11.49 3 .71 0.49 1 .41 0 .08 8

.66 Brigantine 66 .07 8

.17 12

.32 3

.61 0.51 285 0 .21 6

.25 2006-2010 Average Acadia NP 58 .87 6

.96 10

.86 3

.75 0

.46 2.80 1.72 1458 Moasehorn 54 .96 5

.99 1291 4.03 0S3 2 .46 1.87 17.27 GreatGut( 6270 2 .37 12

.35 3.70 0 .52 3.47 0 .17 14.73 LyeBrook 6299 6 .69 10

.77 3.89 0 .62 256 0 .30 1218 Brigantine 59A4 10.67 9.94 4.02 0 .54 5.79 0 .98 8.65 BaseOne 2000-2004 Average Acadia NP 27.90 4.45 9.25 3.59 0 .46 296 1 .82 49 .58 Moosehorn 26.33 4.19 1213 4 .05 0

.45 4

.20 1 .19 47A6 GreatGulf 26.50 4.44 9.23 3.83 0 .47 4

.02 0.79 50 .72 LyeBrook 23.17 6 .01 6.72 3 .12 0

.49 270 0.27 57.53 Brigantine 34 .91 9.09 10 .72 5

.70 0

.55 7.55 3.17 28 .30 2006-2010 Average Aadia NP 22 .94 3.17 8 .55 289 OAO 3 .72 2.66 56 .17 Moosehorn 21.28 2.82 9 .15 3

.06 0.47 3 .33 265 57.25 GreatGufF 24 .07 2.82 7.82 3 .15 0.45 3 .81 0

.90 56

.99 LyeBrook 17.69 4.22 4 .20 2

.28 OAO 269 0 .58 67.94 Brigantine 30 .79 8.45 9 .79 4.80 0.64 8.37 4 .93 32

.24Thedata for the 20% Worst Visibility Days for the Class I Areas closest to Maine is summarized as follows: Data for the years 2006-10 demonstrates that contribution to light extinction due to sulfates continues to dominate (55-63%) at all Northeast sites (note this is down from60- 68% during the 2000-04baseline period) . Contribution to light extinction due to organic mass for the years 2006-10 is the third highest at all New

England sites after light extinction due to Rayleigh scattering. For both the baseline and 2006-10 dataset it ranges from 10 to 13% . At Brigantine light extinction due to organic mass is greater than that due to Rayleigh scattering. Contribution to light extinction due to nitrate at all NewEngland sites is less than Rayleigh scattering and is the fourth highest contributor to light extinction (note the average for 2006-10 is lower than the baseline years) . Brigantine's light extinction contribution due to nitrate is the second highest with Rayleigh scattering coming in fourth and has actually increased during the most current 5 year period. However, as demonstrated in the trajectory analysis to follow, Maine does not contribute to Brigantine on poor visibility days. Summaries on contribution to light extinction for the 20 % Best Visibility Days for the years 2006-10for the same Class I Areas are as follows: " Rayleigh scattering (56-68%) dominates (this is higher than the baseline years which ranged from(28-58%) . , " Sulfate was second at 18-31%(note the range was 23-35%during the baseline years) . " Organic mass third at 4-10% (note the rangewas 7-12%during the baseline years) . " Nitrate is fourth at 3-8%(note the rangewas 4-9% during the baseline years) . This analysis demonstrates that, at all New England sites, nitrate is a very small contributor to light extinction for both the best and the worstvisibility days. Values for the most current 5 year dataset are lower than during the baseline 5 year dataset. Yet, it is also important to document that ifthe NOXWaiver is granted Maine's emissions will not cause or contribute to backsliding at any Class I Area. Consequently, MEDEPAir Quality Meteorologists created back trajectories for a subset of the 20%worst days for 2007 - 2010 fromthe same Class I Areas in the northeast. Appendix A includes information about how the data was processed to select dates for the Regional Haze trajectory analysis. In Figure 4, back trajectory endpoints for days with nitrate extinction values >30 .0 Mm-1 were displayed. Figure 4clearly demonstrates that Maine's NOXemissions do not cause or contribute to high levels of nitrate extinction at Class I Areas anywhere in the Northeastern United States.

### Figure 4 Nitrate Extinction 'ID mBack Trajectories for

Northeast Class I Areas When Nitrate Extinction is 30 Mm4 and above

Legend 7k classi locations i tbl trajectory Events 6riesftom20-doys at each site with the hghest nitrate ®XUnE3iQn levels f[,-Vtha 20%worst v isibikty dafs for 2007-2010 Endpc .lnt !ites aaitsd i;~ NDRXs H YSPLIT dI31J2012 To further demonstrate that Maine does not significantly contribute to visibility degradation, Figure 5 displays the back trajectory endpoints for days when the nitrate extinction values range from15.0 to 29.9 Mm-1 for all Northeast Class I Areas. In Figure 5 a few trajectories pass over 11Maine so the height ofthe endpoints is also symbolized to help visualize what is happening on

those days. Those trajectories that pass over Maine either: originate elsewhere and are descending froma higher altitude before reaching sites in Maine, or they begin in very rural areas of Maine with fewemission sources then pass over large metropolitan areas to the southwest before reaching a Class I Area.

Figure 5 Nitrate Extinction 10 m Back Trajectories for Northeast Class I Areas When Nitrate Extinction is 15through 29 Mm"

Legend * class1locations tbl trajectory Events height (m) <100 100- 199 200-399 J 400-999 " 7999 rn 20days afsaCh sdewfth the highest nitrate e 20% worstviAi6iy'dapsfor 2001 -2010

aaA~ HrsPUraraIrm12V1I . Summary of Results and Conclusions for this Petition:

The entire State of Maine is attainment/unclassifiable for both the 2008 8-hour Ozone NAAQS and the 2010 1-hour N02 NAAQS. Regional haze in all MANE-VU Class I Areas is currently trending below

SIPmodeled glide paths. Technical analyses document that: NO,, emissions from Maine are much smaller than NO,, emissions emanating from sources in states to the south and west. This disparity in total stationary source NO, emissions is readily apparent fromthe information presented in Table 1 . Examination of Hybrid Single Particle Lagrangian Integrated Trajectory Model (HYSPLIT) back trajectories, for sites in the nearest nonattainment areas withinthe OTR, clearly illustrates that NOX emissions fromMaine do not cause or contribute to ozone transport or production in any nonattainment areas within the OTR . Thus, reductions of NO,, emissions in Maine are not necessary to bring the non-attainment areas in the OTR into attainment . Monitored 1-hr N02values in Maine's largest city, in an area of high trafficvolumes, are well below

the NAAQS. " Assessment of regional haze light extinction data shows that sulfates is the prime dominating contributor to regional haze in the northeast with nitrates contributing significantly less at levels belowRayleigh scattering. Assessment of regional haze, through HYSPLIT back trajectories during the 20%worst visibility days from Class I Areas in the Northeast United States, demonstrates that Maine's NOXemissions do not significantly contribute to visibility degradation. MEDEPis therefore requesting a NOXWaiver for the entire state.

### References

Maine DEP-BAQRegulations Chapter 113: http://www

.maine .gov/sos/cec/rules/06/096/096c 113.doc MANE-VUprepared by NESCAUM, Section 2 .2 ofContributions to Regional Haze in the Northeast and Mid-Atlantic United States, finalized August 2006, printed October 2006 U .S. EPA, 1990

: CleanAirAct as Amended (CAAA) in 1990 : http://www

.epa.gov/air/caa/ U .S. EPA, 1995: Approval and Promulgation of Implementation Plans; Maine: NOX Exemption Request forNorthern Maine and NOXControl Approval . Federal Register 60:247 (26 December, 1995) p. 66748 : http://www

.epa. ovg /fedrgrstr/EPAAIR/1995/December/Day-26/pr-368.htm1 U .S. EPA, 2005: Guidance on Limiting Nitrogen Oxides Requirements Related to 8-Hour Ozone Implementation, Air Quality Strategies and Standards Division, Office ofAir Quality Planning and Standards, January 14, 2005: http://www

.epa.gov/ttn/oarpg/t1/memoranda/guide8hr-oz .pdf U .S. EPA, 2006a: Approval and Promulgation ofAir Quality Implementation Plans; Maine; Nitrogen Oxides Exemption Request for Northern Maine. Federal Register 71 :23 (3 February, 2006) p. 5791 : http://www .epa.gov/fedrgstr/EPA-AIR/2006/February/Day03/a984.htm U .S. EPA, 2006b: Approval and Promulgation of Implementation Plans and Designation of Areas for Air Quality Planning Purposes; Maine's Redesignation ofthe Portland, ME and the Hancock, Knox, Lincoln andWaldo Counties, Maine 8-hr Ozone Nonattainment Areas to Attainment for Ozone. Federal Register 71 :237 p. 71489, (11 December, 2006) : http://www

.epa. ov/fedrgstr/EPA-AIR/2006/December/Day-11/a20901 .htm

Data for the Regional Haze analyses was gathered fromthe following web sites: IMPROVE data: http://vista.cira.colostate.edu/improve/Data/IMPROVE/summary data.htm and VIEWS data: http://views.cira.colostate.edu/web/DataWizard/Appendix A-Trajectory Analyses Documentation

Atrajectory is a three dimensional representation of the path an air parcel followed based on forecast or archived meteorological data. Aback trajectory is the path the parcel took to reach a specific point intime and space. Maine Department of Environmental Protection's Bureau of Air Quality (MEDEP) Meteorologists conducted two trajectory analyses. O The first analysis was for the nearest 2008 Ozone NAAQS Ozone Nonattainment Areas at sites in Connecticut and Martha's Vineyard in Massachusetts. This analysis covered ozone exceedances for the 2009 through 2011 ozone seasons and included each hour that ozone levels were equal to or greater than 75 ppb at a monitoring site for every day that an 8-hour ozone exceedance was recorded. 24-hour back trajectories from10, 150and 250meters (m) above ground level (AGL) were created. O The second analysis focused on regional haze and was based on visibility data for 2007 - 2010 for the following Class I Areas in the northeast: Acadia National Park and Moosehorn National Wildlife Refuge in Maine, Great Gulf Wilderness Area in New Hampshire, Lye Brook Wilderness Area in Vermont and Brigantine National Wildlife Refuge in New Jersey. 48-hour back trajectories from 10, 150 and 250 meters (m) above ground level (AGL) were created for each hour of the day. Information about howthe days were selected for the analysis is placed after the Hybrid Single Particle Lagrangian Integrated Trajectory Model (HYSPLIT) discussion. The National Oceanic and Atmospheric Administration (NOAA) Air Resources Laboratory's HYSPLIT is a computer model used to create and map trajectories. The model uses gridded meteorological data, which is selected within the online model's graphical user interface (GUI) . For more information about HYSPLIT please refer to the following document : Description of the HYSPLIT 4 Modeling System by Draxler and Hess (http://www

.arl .noaa.gov/documents/reports/arl-224.pdf) . HYSPLIT is available for use online and also on a local computer (PC) . MEDEP staff meteorologists used the online version to create the trajectories included in this analysis. To insure the hour ofozone matches with the hour of meteorology, the time ofthe ozone value was converted fromEastern Standard Time (EST) to Universal Time Code (UTC) by adding 5 hours. Archived ETA Data Assimilation System (EDAS) meteorological data at 40 kmwas used because this data set had the best resolution and had an excellent data recovery rate. The model was set to include vertical velocity. For each run, the HYSPLIT model generates both a graphical presentation ofthe trajectories and a text file. The text file contains information about the hourly endpoints along each trajectory path including the location in time and space. Hundreds ofendpoint text files were subsequently loaded into an Access database for each analysis, which was then mapped in ARCMAP, a geographical mapping tool used within the department. A-1 Maine's NOx Waiver Petition 2012DATACALCULATIONS TODETERMINE THE DAYS FORTHE REGIONAL HAZE TRAJECTORYANALYSIS Regional Haze data was downloaded fromthe Visibility Information Exchange Web System (VIEWS) web site (http://views .cira.colostate .edu/web/DataWizard) . The data for each site included the visibility data in deciviews as well as the light extinction coefficient data in inverted mega meters (Mm-) for ammoniumsulfate, ammoniumnitrate, soil, elemental carbon, sea salt, organic carbon and coarse mass. Data was available on a 1 in 3 day monitoring cycle. This data was then sorted and processed to identify each year's 20%worst days based on the visibility parameter in deciviews. The 20% worst days were sorted by the ammoniumnitrate light extinction coefficient. To ensure that a reasonable number ofdays were analyzed for each site, the highest 20 days of ammoniumnitrate light extinction coefficient fromthe 20%worst days' visibility at each site were chosen for the trajectory analysis. This resulted in 100 site-days for which twenty-four hourly 48 hour back trajectories were calculated. Upon reviewing the nitrate light extinction data for the subset of days, 30.0 Mm"' was chosen because it seemed like a natural breakpoint to illustrate the differences between the NewEngland sites and Brigantine in NJ . 15 Mm-1 was chosen as another breakpoint because it is half of 30 . The title ofeach endpoint file contained a classification code, based on these breakpoints, to enable the display of trajectories in ARCMAP using the three nitrate light extinction classifications (i .e. above 30.0, 15.0 to 29.9 and below15.0 Mm"') . For the NewEngland sites' subset of data, there was only one day (at Acadia) where the ammonium nitrate light extinction coefficient was slightly over 30 Mm' . The nitrate extinction values for the New England Class I Areas were usually below15 Mm-1 . Conversely, Brigantine NJ's subset contained a high of 60 Mm-1 and only a few days below

30 Mm-1 . Column 2 ofTable A-1 shows the 2007 to 2010 count ofavailable valid data days at each site from which to calculate each year's 20% worst days. Columns 3- 5 ofTable A-1 characterize the nitrate light extinctionvalues within the subset of 20 days fromeach site. Figure 4 in the NOx Waiver included 18 site-days (the total of column 3) and Figure 5 included 12 sitedays (the total of column 4) . When all 100 site-days trajectories were mapped nothing substantial could be gleaned fromthe resulting image. Since nitrate light extinction is such a tiny fraction oftotal visibility degradation, the decision was made to display trajectories for only the higher values. Site Name Total #ofValid Days to # ofdays nitrate # ofdays nitrate # ofdays nitrate

compute the annual 20% extinction >_30.0 extinction is >_15.0 extinction is < worst visibility days for Mm"' of the 20 and < 30.0 Mm-1 15.0 Mm-1 of the 2007-2010 fromthe 20% of the 20fromthe 20from the 20% worst 20% worst worst Acadia 478 1 2 17 Bri g antine 411 17 3 0 

### Great Gulf 371 0 0 20 Lye Brook 413 0 6 14 ~ Moosehorn 469 0 1 19

Table A-1 : Statistics on the Regional Haze Data Anal ysis

A-2 Maine's NOx Waiver Petition 2012