The State of New Hampshire 

Department of Environmental Services 

Mr. David Conroy, Chief 

Air Programs Branch 

Thomas S. Burack, Commissioner 

May 21,2015 

U.S. Environmental Protection Agency, Region I 

5 Post Office Square, Suite 100 

Boston, MA 021 09-3 912 

Re: Supplemental Information for Certification of Adequacy for 2008 Ozone Standard 

SIP Submittal (Infrastructure SIP) 

Dear Mr. Conroy: 

As Governor Hassan's designee, I am enclosing for your review and approval the 

requested supplemental information to New Hampshire's certification of adequacy for the 2008 

National Ambient Air Quality Standard (NAAQS) for ozone which was submitted to the United 

States Environmental Protection Agency, Region I (EPA) on December 31, 2012. This 

supplemental information supports New Hampshire's certification that New Hampshire's State 

Implementation Plan (SIP) fulfills the "infrastructure" requirements established in paragraphs 

llO(a)(l) and (2) ofthe Clean Air Act (CAA). 

Specifically, with respect to subparagraph II 0( a)(2)(G) of the CAA, EPA has requested 

additional ozone monitoring data (the most recent 3 years of data for years 2012 through 2014) 

to support New Hampshire's exemption request in accordance with 40 CFR 51.152(d)(l). As 

stated in New Hampshire's 2008 Ozone Standard Infrastructure SIP submittal, New Hampshire 

is a Priority I region for ozone as defined in 40 CFR 51.150(b)(5). While some areas in New 

Hampshire have experienced ozone levels that marginally exceeded this threshold, those 

incidents are infrequent, and their magnitude remains consistent with a general downtrend in 

ambient ozone concentrations across the region. 40 CFR 51.152 establishes contingency 

planning requirements for certain priority regions. As provided in 52.152( d)(l ), the EPA 

administrator may exempt Priority I regions from contingency planning requirements if those 

regions have been designated as attainment or unclassifiable for the NAAQS. EPA has 

designated all areas of New Hampshire as "unclassifiable/attainment" for the 2008 ozone 

NAAQS. 

www.des.nh.gov 

29 Hazen Drive • PO Box 95 • Concord, NH 03302-0095 

(603) 271-3S03 • TDD Access: Relay Nil 1-800-735-2964 
Mr. David Conroy, Chief, Air Programs Branch 

Supplemental Information- 2008 Ozone Standard Certification o[Adequacv 

Page2 

May21. 2015 

A table was included in the December 2012 SIP submittal that presented the maximum 

one-hour values in parts per million (ppm) for ozone and the number of times the 100 parts per 

billion (ppb) threshold was exceeded each year from 2005 through 2012. Table 1 below provides 

the requested ozone data for the most recent three year period (20 12 through 2014) to 

supplement the data previously submitted. The data for 2012 and 2013 have been certified by 

the New Hampshire Department of Environmental Services, Air Resources Division (DES) and 

concurred on by EPA. The 2014 data has been reviewed for accuracy and DES has issued a 

certification letter to EPA. 

Table 1: Maximum 1-Hour Values (ppm) for Ozone and Number of Times 0.10 ppm Threshold 

Was Exceeded Each Year (2012-2014) 

Monitor Location 2012 2013 2014 

Camp Dodge 0.070 (0) 0.068 (0) 0.073 (0) 

Concord 0.076 (O) 0.071 (0) 0.078 {0) 

Keene 0.081 (O) 0.073 (0) 0.087 (0) 

Laconia 0.074 (0) 0.069 (0) 0.075 (0) 

Lebanon 0.077 {0) 0.070 (0) 0.079 (0) 

Londonderry 0.109 (1) 0.082 (O) 0.085 (0) 

Mt. Washington Summit 0.078 (O) 0.080 (0) 0.076 (0) 

Nashua 0.112 (1) 0.081(0) 0.084 (0) 

Peterborough 0.091 (0) 0.085(0) 0.090 (O) 

Portsmouth 0.101 (1) 0.097 (0) 0.088 (0) 

Rye 0.087 (0) 0.087 (0) 0.089 (0) 

Values from AMP440 Maximum Values Report 

As the above data and previously submitted data show, maximum ozone levels since 

2005 have not come close to the significant harm level of 1,200 )..lg/m3 (0.6 ppm), 2-hour 

average, identified at 40 CFR 51.151. In fact, DES does not envision any circumstances that 

would produce ambient ozone concentrations approaching such as extreme level in the future. 

On this basis, New Hampshire appears to qualify for and requests the exemption from 

contingency planning in accordance with 40 CFR Part 52.152( d)(1 ). 

If you have any questions, please contact me at (603) 271-1088 or via email at 

Craig.Wright@des.nh.gov, or Michele Roberge of my staff at (603) 271-6793 or via email at 

Michele.Roberge@des.nh.gov. 

cc: Anne Arnold, EPA Region I 

Richard Burkhart, EPA Region I 

Sincerely, 

Craig A. Wright 

Director 

Air Resources Division