October 15, 2009 

Mr. Ira W. Leighton 

Acting Regional Administrator 

U.S. Environmental Protection Agency, Region I 

One Congress Street, Suite 1100 

Boston, MA 02114-2023 

Re: Designation of Attainment Area Status under the Revised Lead Standard 

Dear Mr. Leighton: 

 As required by the Clean Air Act and the Transportation Equity Act for the 21st Century, 

I hereby request that New Hampshire be designated as in attainment for the 24-hour and annual 

National Ambient Air Quality Standard (NAAQS) for ground-level lead. All areas of New 

Hampshire currently attain the standard and there are no areas of the state that exacerbate lead

violations in downwind nonattainment areas. 

 The U.S. Environmental Protection Agency (EPA) issued designation guidance in its 

memorandum from William Harnett to EPA Regional Administrators, dated August 21, 2009. 

Accordingly, my recommendation considers measurements of lead air pollution collected 

between 2006 and 2008. To ensure the appropriateness of proposed designations, we also 

considered the more recent 2009 data (see Table 1 below), measurements collected in the 2002 to 

2003, and emissions of potentially large sources that could develop local high lead air 

concentrations. No portions of New Hampshire were found to be at risk for exceeding the new 

lead NAAQS. 

In summary, I propose that the entire State of New Hampshire be designated as 

attainment for the quarterly lead NAAQS. I believe there is sufficient data to support a full 

designation of attainment throughout the state and that a designation of unclassified is 

unnecessary. New Hampshire is committed to protecting the health of its citizens by reducing air 

pollution emissions in efficient and cost-effective ways. 
New Hampshire Proposed Revised Lead Page 2 

Nonattainment Area Boundaries October 15, 2009

 I ask that EPA also continue to seek ways to further protect the nation’s population by 

requiring implementation of new and existing air pollution reducing technology as it is 

developed on a national basis for all source sectors. Nationwide controls will not only benefit 

those areas where the controls are implemented, but will also provide critical background air 

pollution reductions in states further downwind, such as New Hampshire. Long-term protection 

of our citizens and environmental resources will require a collective solution. 

 Thank you for your consideration of my recommendations. If you have any questions 

regarding this determination, please contact Thomas Burack, Commissioner of the Department 

of Environmental Services at (603) 271-3449. 

 

cc: Thomas S. Burack, Commissioner DES 

Robert R. Scott, Air Resources Director DES 

Jeffrey T. Underhill, DES 
New Hampshire Proposed Revised Lead Page 3 

Nonattainment Area Boundaries October 15, 2009

TABLE 1. Estimated 2006 – 2008 Quarterly Lead Design Values by 

Monitor, in micrograms per cubic meter (μg/m3

) 

Location Monitor 

ID 

2006 

Max 

Quarterly 

Avg

2007 

Max 

Quarterly 

Avg

2008 

Max 

Quarterly 

Avg

2009 

Max 

Quarterly 

Avg 1

2006-

2008 

Design 

Value 

2007-

2009 

Design 

Value2

Lead 

NAAQS 

(μg/m3) 

New 

Hampshire 

None -- -- -- -- -- -- 0.15 

Massachusetts 0.15

Boston 

Kenmore Square

250250002 0.01 0.01 0.02 0.011 0.01 0.012 0.15

Maine None -- -- -- -- -- -- 0.15

Vermont None -- -- -- -- -- -- 0.15

TABLE 2. Proposed Designation of Areas of Quarterly Lead 

NAAQS Nonattainment in New Hampshire 

NEW HAMPSHIRE – Lead (QUARTERLY STANDARD) 

Designated Area Designation Classification 

Type Type 

New Hampshire: 

None Nonattainment -- 

All portions of all counties Attainment Attainment 

 

1

 Data for 2009 is presented for illustrative purposes due to being based on preliminary data for the year through 

September. Final data has not yet been delivered in full from the testing laboratory. 

2

 Estimated 2007-2009 design value provided for illustrative purposes only. 
New Hampshire Proposed Revised Lead Page A1 

Nonattainment Area Boundaries – Technical Attachment October 15, 2009

TECHNICAL ATTACHMENT 

The recommendations contained in this letter are fully compliant with Section 107(d)(1)(A) of the Clean 

Air Act (“CAA”) which defines a nonattainment area as any area that (1) does not meet the lead National 

Ambient Air Quality Standard (“NAAQS”), or (2) contributes to ambient lead violations in a nearby area. 

This analysis evaluates the most recent 4-years of quality assured monitoring data for lead pertinent to 

New Hampshire, recent data collected near the state’s largest coal-fired power plant, and emissions data 

for potential major sources, including airports. 

Since the late 1970s and early 1980s, the lead monitoring network was significantly reduced due to 

rapidly declining lead air pollution levels. Of our three neighboring states (Maine, Massachusetts, and 

Vermont) previous lead concentrations dropped so significantly when leaded gasoline was phased-out that 

all but the single highest recording lead monitor were discontinued. The remaining lead monitor is 

located at Kenmore Square in Boston Massachusetts. According to Massachusetts Department of 

Environmental Protection, this monitor was retained because it represented the highest monitored lead 

levels in Massachusetts as well as the northern New England region. Current design values at this 

monitor are less than ten percent of the new lead NAAQS as indicated in Table A1 below. Since New 

Hampshire is a much more rural state with fewer sources as compared to the Kenmore Square area, 

previously measured lead concentrations in New Hampshire were below levels measured at Kenmore 

Square and are expected to still be lower today. 

TABLE A1. Estimated 2006 – 2009 Quarterly Lead Design Values by 

Monitor, in micrograms per cubic meter (μg/m3

) 

Location Monitor 

ID 

2006 

Max 

Quarterly 

Avg

2007 

Max 

Quarterly 

Avg

2008 

Max 

Quarterly 

Avg

2009 

Max 

Quarterly 

Avg 1

2006-

2008 

Design 

Value 

2007-

2009 

Design 

Value2

Lead 

NAAQ

S 

(μg/m3)

New 

Hampshire 

None -- -- -- -- -- -- 0.15 

Massachusetts 0.15

Boston 

Kenmore Square

250250002 0.01 0.01 0.02 0.011 0.01 0.012 0.15

% of NAAQS 6.7% 6.7% 13.3% 6.7% 6.7% 

Maine None -- -- -- -- -- -- 0.15

Vermont None -- -- -- -- -- -- 0.15

In a review of historical lead monitored concentrations in New Hampshire, there was a time prior to the 

phase-out of leaded gasoline where some locations exceeded the level of the new 2008 0.15 μg/m3

 lead 

NAAQS. At the time, the prevailing lead NAAQS was 1.5 μg/m3

.

 Lead monitors were located in Berlin, 

Concord, Hollis, and Portsmouth New Hampshire. Exceedances of the level of the new 2008 lead 

NAAQS ended around April of 1980 and concentrations continued to decline to below 10 percent of the 

new lead NAAQS where it stabilized and is estimated to remain today. Lead monitoring was 

 

1

 Data for 2009 is presented for illustrative purposes due to being based on preliminary data for the year through 

September. Final data has not yet been delivered in full from the testing laboratory. 

2

 Estimated 2007-2009 design value provided for illustrative purposes only. 
New Hampshire Proposed Revised Lead Page A2 

Nonattainment Area Boundaries – Technical Attachment October 15, 2009

discontinued in New Hampshire because measured levels were less than 1% of the former lead NAAQS. 

Table A2 below summarizes the most recent year’s measured lead data in the state before monitoring was 

discontinued. Please note, the monitored values are presented as maximum 24-hour concentrations, not 

quarterly averages. Quarterly average data would normally be significantly lower. 

TABLE A2. Estimated 2006 – 2009 Quarterly Lead Design Values by 

Monitor, in micrograms per cubic meter (μg/m3

) 

Monitor 

Most 

Recent 

Year 

24-hour 

Concentration 

μg/m3

New Quarterly 

(3-month avg) 

Lead NAAQS 

Berlin 1978 0.086 0.15 

Concord 1988 0.038 0.15 

Hollis 1988 0.010 0.15 

Portsmouth 1988 0.019 0.15 

To ensure that isolated “hotspots” were not overlooked in the New Hampshire designation review, areas 

in near proximity to potentially sizable lead sources such as airports, incinerators, and power plants were 

considered in this designation. Emission rates, stack tests, and in some cases dispersion modeling were 

used in this assessment. This work found that there is no single source within New Hampshire that is a 

large enough to cause ambient air lead concentrations to approach the NAAQS. Emissions from large 

facilities were found to be either well controlled or were low enough to not create notable lead hotspots. 

Modeling of the state’s largest source predicted ambient concentrations of less than ten percent of the 

NAAQS and average concentrations of one-third of that. Specifics of this analysis are as follows: 

In the 2002 to 2003 timeframe, concentrations of various toxic pollutants were measured 

near the single largest remaining source of lead emissions in the state, Merrimack Station. 

Merrimack station is the only source in the state that reports emissions of lead greater 

than 0.05 tons per year. Lead data was collected at two sites near the power plant, 

Brickett Hill and Exchange Street. Dispersion modeling of the facility assisted when 

determining the location for these monitors by identifying worst-case locations. In 

addition to power plant emissions, the monitoring stations in Pembroke are also near the 

Concord Airport, the second largest airport source of lead emissions in the state (leaded 

piston aircraft fuel), likely making these sites worst-case locations in New Hampshire. 

The Exchange Street site is aligned with the power plant and the Concord Airport, 

enabling it to capture combined impacts from the two facilities. 

In nearly two years of data collection, the highest 24-hour lead concentration measured 

was 0.0100 μg/m3 (see Table A3). The lead NAAQS is defined as a quarterly average, 

which is almost always lower than a 24-hour average, or estimated to be less than 0.005 

μg/m3

 or about 3 percent of the NAAQS. Assuming that this maximum value somehow 

persisted for three continuous months (even though measurements prove this not to be the 

case), the maximum quarterly value would still be below 10 percent of the lead NAAQS 

(6.7%). Based on this data, it is safe to conclude that New Hampshire’s worst case 

location is well below the level of the 2008 lead NAAQS and consequently other 

locations in the state that previously met the new standard and did not see any notable 

emission increases are also attaining the standard. 
New Hampshire Proposed Revised Lead Page A3 

Nonattainment Area Boundaries – Technical Attachment October 15, 2009

In summary, historical and more recent lead monitoring data demonstrates New Hampshire is currently 

meeting the revised quarterly lead NAAQS on a state-wide basis. Historical data geographically spans 

the state and the most recent measurements, even though 20 to 30 years old, were already safely below 

the levels of the new 2008 lead NAAQS. Since then large sources have either been controlled, shut 

down, or not reporting any notable increases in lead emissions anywhere in the state. Recent 2002 to 

2003 data collected in Pembroke supports that lead emissions are lower than data reported in the late 

1980s. Further, if recent worst-case (Pembroke 24-hour maximum) measurements of lead emissions is 

less than 10 percent of the new NAAQS, then there is little risk that any location in the state exceeds the 

2008 lead NAAQS. As a result, New Hampshire concludes that a state-wide designation of attainment for 

the 2008 lead NAAQS is justified. 
New Hampshire Proposed Revised Lead Page A4 

Nonattainment Area Boundaries – Technical Attachment October 15, 2009

TABLE A3. Measured Lead Concentrations Near Major Source (2002 – 

2003 – Pembroke, New Hampshire) 

24-Hr μg/m3 24-Hr μg/m3

Date Brickett Hill Exchange Str 

09/11/02 0.0035 0.0046 

09/23/02 0.0013 0.0020 

10/05/02 0.0013 0.0014 

10/17/02 0.0007 0.0017 

10/29/02 0.0012 0.0011 

11/10/02 0.0035 0.0020 

11/22/02 0.0051 0.0055 

12/04/02 0.0059 -- 

12/16/02 0.0025 0.0021 

12/28/02 0.0044 0.0029 

01/09/03 0.0017 0.0023 

01/21/03 0.0079 0.0020 

02/02/03 0.0013 0.0027 

02/14/03 0.0042 0.0034 

02/26/03 0.0073 0.0059 

03/10/03 0.0034 0.0031 

03/22/03 0.0100 0.0082 

04/03/03 0.0042 0.0037 

04/15/03 0.0070 0.0079 

04/27/03 0.0019 0.0017 

05/09/03 0.0020 0.0036 

05/21/03 0.0035 0.0031 

06/02/03 0.0015 0.0023 

06/14/03 0.0045 0.0035 

06/26/03 0.0041 0.0047 

07/08/03 0.0030 0.0037 

07/20/03 0.0024 0.0024 

08/01/03 0.0007 0.0012 

08/13/03 0.0023 0.0016 

08/25/03 0.0032 0.0026 

09/06/03 0.0034 0.0024 

09/18/03 0.0009 0.0021 

09/30/03 0.0011 0.0045 

10/12/03 0.0037 0.0016 

10/24/03 0.0008 0.0011 

11/05/03 0.0014 0.0062 

11/17/03 0.0058 0.0014 

12/11/03 0.0004 0.0012 

12/23/03 0.0054 0.0087 

2002 Avg 0.0029 0.0026 

2003 Avg 0.0034 0.0034 

NAAQS 0.1500 0.1500 

2 year Avg 0.0033 0.0032 

2 year Max 0.0100 0.0087 

Max % 

NAAQS 6.7% 5.8%