### 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 th e Transportation Equity Act for the 21 st 

### Century, I hereby request that New Hampshire be designat ed 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 ther e are no areas of the stat e that exacerbate lead violations in downwind nonattainment areas.

The U.S. Environmental Protection Agency (EPA) issued designati on guidance in its memorandum from William Harnett to EPA Re gional Administrators, dated August 21, 2009. Accordingly, my recommendation considers m easurements of lead air pollution collected between 2006 and 2008. To ensure the appropria teness of proposed designations, we also considered the more recent 2009 data (see Table 1 below), measurements co llected 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 St ate 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 thr oughout the state and that a designation of unclassified is unnecessary. New Hampshire is committed to protec ting the health of its citizens by reducing air pollution emissions in efficien t 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 sector s. Nationwide controls will not only benefit those areas where the controls are implemente d, but will also provide critical background air pollution reductions in states fu rther downwind, such as New Hampshire. Long-term protection of our citizens and environmental res ources will require a collective solution.

Thank you for your consideration of my r ecommendations. If you have any questions regarding this determination, please contact Thomas Burack, Commissioner of the Department of Environmental Serv ices at (603) 271-3449.

cc: Thomas S. Burack, Commissioner DES Robert R. Scott, Air Resources Director DES Jeffrey T. Underhill, DESNew Hampshire Proposed Revised Lead Page 3 Nonattainment Area Boundaries October 15, 2009



## TABLE 1. Estimated 2006 – 2008 Qu arterly Lead Design Values by Monitor, in micrograms per cubic meter ( μ g/m 3 

## )

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 Value 2 Lead NAAQS ( 

### μ g/m 3 )

New Hampshire None 

### -- -- -- -- -- -- 0.15

Massachusetts 0.15

Boston Kenmore Square 250250002 0.01 0.01 0.02 0.01 1 0.01 0.01 2 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) Designation Classification 

# Designated Area 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) contri butes 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 m onitoring 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 si gnificantly when leaded g asoline was phased-out that all but the single highest recording lead monitor we re discontinued. The remaining lead monitor is located at Kenmore Square in Boston Massachusetts . According to Massachusetts Department of Environmental Protection, this monitor was retain ed 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 Ha mpshire were below levels measured at Kenmore Square and are expected to still be lower today.



## TABLE A1. Estimated 2006 – 2009 Qu arterly Lead Design Values by Monitor, in micrograms per cubic meter ( μ g/m 3 

## )

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 Value 2 Lead NAAQ S ( 

### μ g/m 3 )

New Hampshire None 

### -- -- -- -- -- -- 0.15

Massachusetts 0.15

Boston Kenmore Square 250250002 0.01 0.01 0.02 0.01 1 0.01 0.01 2 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 concentrati ons in New Hampshire, there was a time prior to the phase-out of leaded gasoline wh ere some locations exceeded th e level of the new 2008 0.15 μ g/m 3 lead NAAQS. At the time, the prevailing lead NAAQS was 1.5 μ g/m 3

. 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 estimat ed 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 measu red lead data in the state before monitoring was discontinued. Please note, the monitored values ar e presented as maximum 24-hour concentrations, not quarterly averages. Quarterly average data would normally be significantly lower.



## TABLE A2. Estimated 2006 – 2009 Qu arterly Lead Design Values by Monitor, in micrograms per cubic meter ( μ g/m 3 

## )

Monitor Most Recent

Year 24-hour Concentration
μ g/m 3 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 over looked in the New Hampshire designation review, areas in near proximity to potentially sizable lead sources su ch as airports, incinerators, and power plants were considered in this designation. Emission rates, st ack tests, and in some cases dispersion modeling were used in this assessment. This wo rk found that there is no single sour ce within New Hampshire that is a large enough to cause ambient air lead concentrati ons 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 ambien t 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 monitori ng stations in Pembroke are also near the Concord Airport, the second largest airport sour ce of lead emissions in the state (leaded piston aircraft fuel), likely making these s ites 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 im pacts from the two facilities.

In nearly two years of data collection, th e highest 24-hour lead concentration measured was 0.0100 μ g/m 3 (see Table A3). The lead NAAQS is defined as a quarterly average, which is almost always lower than a 24-hour av erage, or estimated to be less than 0.005

μ g/m 3 or about 3 percent of the NAAQS. Assuming that this maximum value somehow persisted for three continuous months (even though measurement s 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 monito ring data demonstrates New Hampshire is currently meeting the revised quarterly lead NAAQS on a state-wi de 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 em issions 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 conclud es 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 Le ad Concentrations Near Major Source (2002 – 2003 – Pembroke, New Hampshire)

24-Hr μ g/m 3 24-Hr μ g/m 3

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%