EPA450/3-75-014

FEBRUARY 1975
     IMPLEMENTATION PLAN REVIEW
                  FOR
          NEW HAMPSHIRE
              AS REQUIRED
                   BY
          THE ENERGY  SUPPLY
                  AND
   ENVIRONMENTAL COORDINATION ACT
     U. S ENVIRONMENTAL PROTECTION AGENCY

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                                                            EPA-450/3-75-014
                     IMPLEMENTATION PLAN REVIEW

                                 FOR

                            NEW HAMPSHIRE

AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
                PREPARED BY THE FOLLOWING TASK FORCE:

            U.  S.  Environmental Protection Agency, Region I
                  J.  F.  Kennedy Federal  Building
                   Boston, Massachusetts  02203
                Environmental  Services of TRW, Inc.
             800 Foil in Lane,  SE, Vienna, Virginia  22180
                        (Contract 68-02-1385)
                U.  S.  Environmental  Protection Agency
                 Office of Air and Waste Management
           Office of Air Quality Planning and Standards
           Research Triangle Park, North Carolina 27711
                            February 1975

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                              NEW HAMPSHIRE
            ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
            (SECTION IV - STATE IMPLEMENTATION PLAN REVIEW)

                            Table of Contents                       Page
1.0  EXECUTIVE SUMMARY 	     1
2.0  STATE IMPLEMENTATION PLAN REVIEW	     5
     2.1  Summary	     5
     2.2  Air Quality Setting — State of New Hampshire	     8
     2.3  Background on the Development of the Current
          State Implementation Plan	    10
3.0  AQCR ASSESSMENTS BASED ON SIP REVIEWS 	    11
     3.1  Androscoggin Valley Interstate AQCR 107	    11
     3.2  Merrimack Valley - Southern New Hampshire
          Interstate AQCR 121	    13
     3.3  Central New Hampshire Intrastate AQCR 149	    15
APPENDIX A - STATE IMPLEMENTATION PLAN BACKGROUND                    17
APPENDIX B - REGIONAL AIR QUALITY SUMMARY  .                          27
APPENDIX C - POWER PLANT SUMMARY                                     29
APPENDIX D - INDUSTRIAL, COMMERCIAL/INSTITUTIONAL SOURCE SUMMARY     31
APPENDIX E - AREA SOURCE SUMMARY                                     33

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                         1.0  EXECUTIVE SUMMARY

     The enclosed report is the U.S. Environmental Protection Agency's (EPA)
response to Section IV of the Energy Supply and Environmental Coordination
Act of 1974 (ESECA).  Section IV requires EPA to review each State Implemen-
tation Plan (SIP) to determine if revisions can be made to control regula-
tions for stationary fuel combustion sources without interfering with the
attainment and maintenance of the National Ambient Air Quality Standards
(NAAQS).  In addition to requiring that EPA report to the State on whether
control regulations might be revised, ESECA provides that EPA must approve
or disapprove any revised regulations relating to fuel burning stationary
sources within three months after they are submitted to EPA by the States.
The States may, as in the Clean Air Act of 1970, initiate State Implementa-
tion Plan revisions; ESECA does not, however, require States to change any
existing plan.

     Congress has intended that this report provide the State with informa-
tion on excessively restrictive control regulations.  The intent of ESECA
is that SIP's, wherever possible, be revised in the interest of conserving
low sulfur fuels or converting sources which burn oil or natural gas to coal.
EPA's objective in carrying out the SIP reviews, therefore, has been to try
to establish if emissions from combustion sources may be increased.  Where
an indication can be found that emissions from certain fuel burning sources
can be increased and still attain and maintain NAAQS, it may be plausible
that fuel  resource allocations can be altered for "clean fuel savings" in
a manner consistent with both environmental and national energy needs.

     In many respects, the ESECA SIP reviews parallel EPA's policy on clean
fuels.   The Clean Fuels Policy has consisted of reviewing implementation
plans with regards to saving low sulfur fuels and, where the primary sulfur
dioxide air quality standards were not exceeded, to encourage States to
either defer compliance regulations or to revise the SOg emission regulations,
The States have also been asked to discourage large scale shifts from coal
to oil  where this could be done without jeopardizing the attainment and main-
tenance of the NAAOS.

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     To date, EPA's fuels policy has addressed only those States with the
largest clean fuels saving potential.  Several of these States have or are
currently in the process of revising SC^ regulations.   These States are
generally in the Eastern half of the United States.  ESECA, however, extends
the analysis of potentially over-restrictive regulations to all 55 States
and territories.  In addition, the current reviews address the attainment
and maintenance of all the National Ambient Air Quality Standards.

     There are, in general, three predominant reasons  for the existence of
overly restrictive emission limitations within the State Implementation Plans.
These are (1) The use of the example region approach in developing State-wide
air quality control strategies; (2) the existence of State Air Quality Stan-
dards which are more stringent than NAAQS; and (3) the "hot spots" in only
part of an Air Quality Control Region (AQCR) which have been used as the
basis for controlling the entire region.  Since each of these situations af-
fect many State plans and in some instances conflict with current national
energy concerns, a review of the State Implementation  Plans is a logical
follow-up to EPA's initial appraisal of the SIP's conducted in 1972.  At
that time SIP's were approved by EPA if they demonstrated the attainment of
NAAQS or more stringent state air quality standards.  Also, at that time an
acceptable method for formulating control strategies was the use of an example
region for demonstrating the attainment of the standards.

     The example region concept permitted a State to identify the most pol-
luted air quality control region (AQCR) and adopt control regulations which
would be adequate to attain the NAAQS in that region.   In using an example
region, it was assumed that NAAQS would be attained in the other AQCR's of
the State if the control regulations were applied to similar sources.  The
problem with the use of an example region is that it can result in excessive
controls, especially in the utilization of clean fuels, for areas of the
State where sources would not otherwise contribute to NAAQS violations. For
instance, a control strategy based on a particular region or source can re-
sult in a regulation requiring 1 percent sulfur oil to be burned state-wide
where the use of 3 percent sulfur coal would be adequate to attain NAAQS in
some locations.

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     EPA anticipates that a number of States will use the review findings
to assist them in making the decision whether or not to revise portions of
their State Implementation Plans.  However, it is most important for those
States which desire to submit a revised plan to recognize the review's limi-
tations.  The findings of this report are by no means conclusive and are
neither intended nor adequate to be the sole basis for SIP revisions; they
do, however, represent EPA's best judgment and effort in complying with
the ESECA requirements.  The time and resources which EPA has had to pre-
pare the reports has not permitted the consideration of growth, economics,
and control strategy tradeoffs.  Also, there have been only limited disper-
sion modeling data available by which to address individual point source
emissions.  Where the modeling data for specific sources were found, how-
ever, they were used in the analysis.

     The data upon which the reports' findings are based are the most cur-
rently available to the Federal Government.  However, EPA believes that the
States possess the best information for developing revised plans.  The States
have the most up-to-date air quality and emissions data, a better feel for
growth, and the fullest understanding for the complex problems facing them
in the attainment and maintenance of air quality.  Therefore, those States
desiring to revise a plan are encouraged to verify and, in many instances,
expanc the modeling and monitoring data supporting EPA's findings.  In devel-
oping 'i suitable plan, it is suggested that States select control strategies
which place emissions for fuel combustion sources into perspective with all
sources of emissions such as smelters or oth,er industrial processes.  States
are encouraged to consider the overall impact which the potential relaxation
of overly restrictive emissions regulations for combustion sources might have
on their future control programs.  This may include air quality maintenance,
prevention of significant deterioration, increased TSP, NOX, and HC emissions
which occur in fuel  switching, and other potential air pollution situations
such as sulfates.

     Although the enclosed analysis has attempted to address the attainment
of all  the NAAQS, most of the review has focused on total suspended particu-
"late matter (TSP) and sulfur dioxide (S02) emissions.  This is because sta-
tionary fuel  combustion sources constitute the greatest source of S02 emission
and are a major source of TSP emissions.

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     Part of each State's review was organized to provide an analysis of
the S02 and TSP emission tolerance within each of the various AQCR's.  The
regional emission tolerance estimate is, in many cases, EPA's only measure
of the "over-cleaning" accomplished by a SIP.  The tolerance assessments
have been combined in Section 2 and Appendix B with other regional air qual-
ity "indicators" in an attempt to provide an evaluation of a region's candi-
dacy for changing emission limitation regulations.  In conjunction with the
regional analysis, a summary of the State's fuel combustion sources (power
plants, industrial sources, and area sources) has been carried out in Appen-
dices C, D, and E.

     The State Implementation Plan for the State of New Hampshire has been
reviewed for the most prevalent causes of over-restrictive fuel combustion,
emission limiting, regulations.  The major findings of the review are:

     FOR TOTAL SUSPENDED PARTICULATES. THERE IS ONLY ONE AQCR, CENTRAL
     NEW HAMPSHIRE. WHICH INDICATED A GOOD POTENTIAL FOR REVISING FUEL
     COMBUSTION SOURCE EMISSION LIMITING REGULATIONS.

     FOR SO,, THERE ARE TWO AQCR'S, ANPROSCOGGIN VALLEY AND MERRIMACK
     VALTEY - SOUTHERN NEVJ HAMPSHIRE HHICH INDICATE A GOOD POTENTIAL FOR
     REVISING FUEL COMBUSTION SOURCE EMISSION LIMITING REGULATIONS.

     The supportive findings of the SIP review are as follows:
     New Hampshire currently uses very little coal for fuel combustion.
     Almost all fuel combustion sources in the State use fuel oil.  In
     most cases the use of low sulfur coal and existing emission control
     technology would be more consistent with national energy policies.
     Considerably more modeling data are needed throughout the State of
     New Hampshire; particularly in areas around the large sources of
     emissions.  It is difficult to evaluate the impact of a regulation
     revision on air quality without knowing how air quality is affected
     by local sources.
     Additional SO? monitoring is needed in AQCR 149, Central New Hampshire
     before a complete assessment of the S02 regulation revision potential
     can be made.

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                  2.0  STATE IMPLEMENTATION PLAN REVIEW
2.1  SUMMARY
     A revision of fuel combustion source emissions regulations will depend
on many factors.  For example:
     •  Does the State have air quality standards which are more stringent
        than NAAQS?
     •  Does the State have emission limitation regulations for control of
        (1) power plants, (2) industrial sources, (3) area sources?
     •  Did the State use an example region approach for demonstrating the
        attainment of NAAQS or. more stringent State standards?
     •  Has the State not initiated action to modify combustion source emis-
        sion regulations for fuel savings; i.e., under the Clean Fuels Policy?
     •  Are there no proposed Air Quality Maintenance Areas?
     •  Are there indications of a sufficient number of monitoring sites
        within a- region?
     •  Is there an expected 1975 attainment date for NAAQS?
     t  Based on (1973) air quality data, are there no reported violations
        of NAAQS?
     •  Based on (1973) air quality data, are there indications of a toler-
        ance for increasing emissions?
     fr  Are the total emissions from stationary fuel combustion sources
        proportionally lower than those of other sources?
     t  Is there a significant clean fuels savings potential in the region?
     •  Do modeling results for specific fuel combustion sources show a
        potential for a regulation revision?
     The following portion of this report is directed at answering these
questions.  An AQCR's potential for revising regulations increases when
there are affirmative responses to the above.

     The initial part of the SIP review report, Section 2 and Appendix A,
was organized to provide the background and current situation information
for the State Implementation Plan.  Section 3 and the remaining Appendices

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provide an AQCR analysis which helps establish the overall potential  for
revising regulations.  Emission tolerance estimates have been combined in
Appendix B with other regional air quality "indicators" in an attempt to
provide an evaluation of a region's candidacy for revising emission limiting
regulations.  In conjunction with the regional analysis, a characterization
of the State's fuel combustion sources (power plants, industrial  sources,
and area sources) has been carried out in Appendices C, D, E.

     Based on an overall evaluation of EPA's current information, AQCR's
have been classified as good, marginal, or poor candidates for regulation
revisions.  Table 2-1 summarizes the State Implementation Plan Review. The
remaining portion of the report supports this summary with explanations.

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                                                           TABLE 2-1

                                               STATE IMPLEMENTATION PLAN REVIEW
                                                           (SUMMARY)
                     "Indicators"
  •  Does the State have air quality standards
which are more stringent than NAAQS?
  •  Does the State have emission limiting regu-
lations for control of:

     1.  Power plants
     2.  Industrial sources
     3.  Area sources

  •  Did the State use an example region approach
for demonstrating the attainment of NAAQS or more
stringent State standards?

  •  Has the State not initiated action to modify
combustion source emission regulations for fuel
savings; i.e., under the Clean Fuels Policy?
  •  Are there no proposed Air Quality Maintenance
Areas?

  •  Are there indications of a sufficient number of
monitoring sites within a region?

  •  Is there an expected 1975 attainment data for
NAAQS?

  •  Based on (1973) Air Quality Data, are there
no reported violations of NAAQS?
  •  Based on (1973) Air Quality Data, are there
indications of a tolerance for increasing emissions?

  •  Are the total emissions from stationary fuel
combustion sources proportionally lower than those
of other sources?
  •  Dp modeling results for fuel combustion sources
show a potential for a reoulation revision?

  •  Must emission limiting regulations be revised
to accomodate significant fuel switching?
  •  Based on the above indicators, what is the poten-
tial for revising fuel combustion source emission
limiting regulations?
  •  Is there a significant Clean Fuels Saving
potential in the region?
    New
 Hampshi re

TSP_    S0£       T_SP_


 No    Yes a
Yes    Yes
Yes    Yes
Yes    Yes
Yes    Yes
Yes     No
                                                                            Androscoggin
                                                                               Valley
                                                                              AQCR 107
Yes      rio


N.A.    N.A.


 No      No



Poor    Good


     No
                    Merrlmack
                 Valley-Southern
                  New Hampshire
                    AQCR 121

                   TSP     SO,
                                    Yes
                                    Yes
                                     No
                                             No
                                             No
                                    Poor    Good


                                         No
   Central
New Hampshire
  AQCR 149

 TSP_     S0.2
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes-
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
                                                        Yes
                                                                 No
 N.A.    N.A.


  No      No


              c
 Good    Marg.


      No
a - Due to the fact that Federal secondary SOg standards (annual and 24-hour) were eliminated.
b - Modeling results available for only one power plant.

c - Based on lack of S02 monitoring data.

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2.2  AIR QUALITY SETTING — STATE OF NEW HAMPSHIRE
     The State of New Hampshire is divided into three AQCR's.  These are
AQCR 107, Androscoggin Valley Interstate (New Hampshire and Maine); AQCR
121, Merrimack Valley - Southern New Hampshire Interstate (New Hampshire
and Massachusetts); and AQCR 149, Central New Hampshire Intrastate (Figure
2-1).

     A summary of the Federal and New Hampshire air quality standards for
total suspended particulates, S02S and NOX is presented in Table A-3.  The
New Hampshire standards as originally published in the State Implementation
Plan were identical to the Federal secondary standards.  Since the Federal
secondary standards for S02 annual and 24-hour average concentrations were
eliminated, these New Hampshire standards are now more stringent than Federal.

     Air quality monitoring appears to be fairly adequate throughout most of
the State based on analysis of 1973 SAROAD (Storage and Retreival of Aero-
metric Data) System information.  The one exception is AQCR 149, Central New
Hampshire.  There were no data reported from S02 monitors in this region
during 1973.

     A summary of the New Hampshire Air Quality Status is presented in Tables
A-4 and A-5.  It is significant to note that there were no violations of
Federal S02 standards reported during 1973.  There were, however, several
violations of the Federal particulate standards, mostly secondary, reported.

     A summary of significant New Hampshire emission sources is presented
in Table A-6, as well as the total particulate and S02 emissions.  The per-
centage of the total emissions contributed by New Hampshire fuel combustion
sources is also shown.  Tables A-7 and A-8 follow from Table A-6 by giving
a more detailed analysis of existing emissions.-1

     In general, New Hampshire's air pollution tends to be concentrated in
the northern (AQCR 107) and southern (AQCR 121) portion of the State. Almost
all of the State's S02 emissions are accounted for by fuel combustion with
1 All emissions data taken from NEDS.

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                                                     ANDROSCOGGIN
                                                     VALLEY
                                                     INTERSTATE
                                                     (MAINE -
                                                     NEI HAMPSHIRE)
                                                      CENTRAL
                                                      NEW HAMPSHIRE
                                                      INTRASTATE
                                                      (REMAINING
                                                      AREA)
                                                          MERRIMACK
                                                          VALLEY-
                                                          SOUTHERN
                                                          NEW HAMPSHIRE
                                                          INTERSTATE
                                                          (MASSACHUSETTS-
                                                          NEW HAMPSHIRE)
Figure  2-1   New  Hampshire Air Quality Control  Regions

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about half of  that due to power plant operation.  One third of the particu-
late emissions can be attributed to fuel combustion and an almost equal
amount  to solid waste disposal.

2.3  BACKGROUND ON THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTATION PLAN
     The SIP control strategies and regulations were based on the example
region  approach.  The example region used for the development of both particu-
late and S02 regulations was comprised of Merrimack, Hillsborough, and Rockingham
Counties.  These three counties are in AQCR 121 and incorporate the largest
power plants in the State.  Manchester and Nashua were of greatest concern in
Hillsborough County, while Portsmouth was the area of concern in Rockingham
County.

     The regulation adopted for the control of particulate matter from fuel
combustion sources is based on the input firing rate.  It is applicable to
all fuel burning equipment in the State, and is displayed graphically in
Figure  A-l.  The State particulate emission regulation for new sources com-
plies with the Federal Standard for New Stationary Sources exceeding 250
million BTU per hour.

     A  sulfur  content limitation is used to control sulfur oxide emissions
from fuel combustion sources in New Hampshire.  The maximum allowable sulfur
content is determined by type of fuel burned (coal, oil, or gas) and whether
or not  the source existed at the time of adoption of the regulation.  On
October 17, 1974, the State approved a variance which permitted the use of
higher  sulfur  fuel oil in two of the three AQCR's.  The current S02 regula-
tion and the variance are explained in detail in Appendix A.
                                   10

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               3.0  AQCR ASSESSMENTS BASED ON SIP REVIEWS

     The purpose of this section is to evaluate the available information
for the State of New Hampshire and determine the feasibility of revisions
to the SIP which would result in clean fuel conservation.  The assessments
will be made by AQCR addressing each type of fuel combustion source: power
plants, large industrial and commercial/institutional sources, and area
sources.  The criteria used to make the assessments are listed and tabulated
in Section 2.1 and Table 2-1 of this report.  Tables B-l and B-2 present a
quantitative display of some of the criteria in Table 2-1.

     The AQCR's are grouped into good, marginal, and poor candidates for
regulation relaxation based on the evaluation of all the presented informa-
tion.  Using available data, any AQCR which displays a 1973 air quality vio-
lation would probably be given a poor ranking.  Conversely, a region with no
violations, no proposed AQMA designations, low to moderate emissions, a posi-
tive emission tolerance, and/or a small fraction of emissions from New Hampshire
fuel combustion sources would receive a good ranking.  All other regions with
varying indicators or incomplete or missing data would be evaluated separ-
ately and grouped in the appropriate class, most likely a marginal ranking.

     The source type groups are evaluated separately using such variables
for criteria as modeling results, emissions data from the SIP and/or NEDS,
and air quality data.

3.1  ANDROSCOGGIN VALLEY INTERSTATE AQCR 107
3.1.1  Regional Air Quality Assessment
       The Androscoggin Valley AQCR received a poor ranking as a candidate
for particulate regulation revision based primarily on the fact that three
monitoring stations reported violations of the particulate standards in 1973.
There are some significant sources in Maine which may contribute to the air
quality in New Hampshire.  An evaluation of the impact of Maine's sources on
New Hampshire's air quality could only be made after reviewing the results
of a regional modeling effort.  Since the other indicators indicate that this
                                     11

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region would be a good candidate for regulation revision, the ranking could
be reversed tf modeling results showed that New Hampshire sources were not
a significant cause of the air quality violations of 1973.

       The Androscoggin Valley AQCR was ranked as a good candidate for revi-
sion of S02 regulations.  There are no proposed Air Quality Maintenance Areas,
there were no S02 Air Quality Standard violations reported in 1973, and there
is a large tolerance for S02 emissions increase based on 1973 air quality
data.  However, since fuel combustion sources contribute such a high percent-
age of the emissions from New Hampshire sources, the large tolerance for emis-
sions increase could easily be used up by a small change in the regulation.

3.1.2  Power Plant Summary
       There are three electric generation facilities in the Region.  Only
one of these is located in New Hampshire, and it is an oil fired gas turbine
plant belonging to the Public Service Co. of New Hampshire; their Lost Nation
Plant.  Both particulate and S02 emissions from this plant are insignificant
to the State's total.

3.1.3  Industrial and Commercial/Institutional Source Summary
       There are three significant fuel  combustion particulate sources which
are also the only three significant S02  fuel combustion sources.  They con-
tribute an estimated one-seventh of the  New Hampshire particulate emissions,
and over three fourths of the SC>2 emissions.  Existing regulations allow a:
very large increase in particulate emissions and no increase in S02 emissions
since all significant S02 sources are presently burning oil with the maximum
allowable sulfur content.

      As pointed out in Section 3.1.1, it would be inadvisable to contemplate
a revision in the particulate regulation without some modeling data.  However,
since the S02 standards were .being met in 1973 with significant sources burning
maximum allowable sulfur content fuel, this region has excellent potential
for S02 regulation modification.
                                  12

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3.1.4  Area Source Summary
       Available data indicate that area source fuel combustion sources are
operating within the sulfur limitations imposed by State regulations.   Since
the particulate control regulations are based on boiler firing rate, it is
impossible to evaluate the status of regulation compliance without additional
area source data.  A summary of the area source data is presented in Table  E-l
3.2  MERRIMACK VALLEY - SOUTHERN NEW HAMPSHIRE INTERSTATE AQCR 121
3.2.1  Regional Air Quality Assessment
       The Merrimack Valley - Southern New Hampshire AQCR was ranked as a
poor candidate for particulate regulation revision because of four violations
of the particulate standards in 1973.  Again, as in the previous interstate
region, detailed modeling results are necessary before an evaluation can be
made of the impact of New Hampshire sources on the air quality.   However,
since the New Hampshire portion of this region includes most of the State's
larger population centers and industrial areas, it seems unlikely that the
regulations could be revised without having an adverse effect on air quality
in the region.

       The region was ranked as a good candidate for revision of S02 regula-
tions based on 1973 air quality data.  However, since such a high percentage
of the region's S02 emissions originate with fuel  combustion, air quality
could be very sensitive to even small changes in control regulations.  In
October 1974, the New Hampshire Air Pollution Control Commission approved
a variance which allows the burning of 2.0 percent sulfur residual  oil. The
effects of this variance are not present in the air quality data available
for this study, and any regulation revision should be delayed until an eval-
uation of the effects can be made.

3.2.2  Power Plant Summary
       There are five steam electric power generating stations in the New
Hampshire portion of this region; all operated by the Public Service Co. of
New Hampshire.  They are the Merrimack Plant, the Schiller Plant, the Daniel
St. Plant, the Newington Plant, and the Manchester Plant.  One of these, the
                                      13

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Merrimack Plant, uses coal as its major source of energy.  All plants currently
operating in the region are burning fuel oil with the maximum allowable sul-
fur content by State regulations.  Therefore, without switching to coal, these
plants could not use a higher sulfur content fuel unless existing regulations
were revised.

       Power plants in the region could possibly increase their particulate
emissions and still be within the legal limits, but since 1973 air quality
data indicate high concentrations of total suspended particulate, this seems
inadvisable at this time.

       Air quality around the Schiller Plant was  modeled by Wai den,  assuming
a switch to coal  containing 2.5 percent sulfur and 15 percent ash.   The
results are shown below.   It is interesting to note that these results indi-
cate a fuel  switch to coal would be feasible.  However, these results are
for one plant only and, therefore, nothing can be said about the advisability
of fuel switches  at other plants.

           Table  3-1  Schiller Plant Modeling Results (yg/m3)3
                       [2.5% Sulfur, 15% Ash Coal]

                             Maximum                Maximum
                       24-hr Concentration    Annual  Concentration
                          TSP      S02            TSP      S02
       Nominal  Load       27       156             2       12
       Maximum Load       27       154
       aModeling Analysis of Power Plants for Fuel Conversion (Group IV),
        Walden Research Division of Abcor Inc., Sept.  12, 1974

3.2.3  Industrial and Commercial/Institutional Source Summary
       Significant fuel combustion sources of this category in Region 121
number six for particulates and seventeen for SC^.  They contribute approxi-
mately one tenth of the total particulate and S02 emissions from all New
Hampshire sources.

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       Small increases in both participate and S02 emissions can be made with-
out regulation revision.  However, in light of the 1973 air quality data, even
an increase of particulate emissions to the maximum currently allowable would
be unwise.  More recent air quality data should be examined prior to making
a decision on particulate regulation revision.

       Since the tolerance for S02 emissions increase, based on 1973 air qual-
ity data, is relatively large, it seems safe to say that an increase to the
maximum allowable emissions would not have a large adverse effect on air
quality.  Again, more recent air quality data should be available prior to
revising the regulations.

3.2.4  Area Source Summary

       As is shown in Table E-l, area sources, as a whole, are complying with
existing regulations.  However, using available data it is impossible to eval-
uate particulate source compliance since input firing rates are not included.

3.3  CENTRAL NEW HAMPSHIRE INTRASTATE AQCR 149
3.3.1  Regional  Air Quality Assessment
       The Central New Hampshire AQCR was the only one of the three New
Hampshire AQCR's reporting no particulate air quality violations in 1973.
Therefore, it was also the only AQCR to receive a ranking of good in evalu-
ating the potential for particulate regulation revision.   Particulate emis-
sions from fuel  combustion sources comprise only a moderate portion of the
total particulate emissions and therefore, increases in particulate emissions
from fuel combustion sources are less likely to have a significant impact on
air quality.

       No air quality data are available on S02 concentrations in the region.
Therefore, the region's S02 regulation revision potential was ranked as mar-
ginal.   All  indicators point toward a good ranking, but without air quality
data no quantitative assessment can be made.
                                    15

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3.3.2  Power Plant Summary
       The Public Service Co. of New Hampshire operates the only electric
generation facility in the region.  This is the White Lake Plant and it is
a gas turbine plant burning distillate oil.  Particulate and S02 emissions
from this type of operation are very small, and form an insignificant part
of the regional total.

3.3.3  Industrial and Commercial/Institutional Source Summary
       There are four significant industrial and commercial/institutional
sources of fuel combustion particulate emissions in this region.  They con-
tribute about one tenth of the regional particulate emissions.   Particulate
emissions from these sources would approximately double if all  four plants
increased their emissions to the maximum allowed by State regulations.

       There are also four significant sources of S02 emissions in this source
category.  Together they emit about one third of the region's S02 emissions.
Since all sources are burning fuel with either the maximum allowable sulfur
content, or very close to it, it would require a regulation revision before
they could burn fuel with a higher sulfur content.  However, as stated before,
S02 air quality data are inadequate to assess the impact of such a regulation
revision.

3.3.4  Area Source Summary
       Area sources in this region emit an estimated one fourth of the region's
particulate fuel combustion emissions, and over half of the S02.  As in the
other two regions, available area source data are insufficient to evaluate
the status of particulate control regulation compliance.
                                    16

-------
                                                                APPENDIX A

                                                   STATE IMPLEMENTATION PLAN BACKGROUND

                                    TABLE A-l   NEW HAMPSHIRE  AQCR  PRIORITY  CLASSIFICATIONS AND AQMA's
Demographic Information
AQCR Priority
Classification3
AQCR Name
Androscoggin Valley0
Merrimack Valley - Southern
New Hampshire
Central New Hampshire
AQCR No.
107
121
149
TSP SOX
I I
I I
III III
NO*
III
III
III
Population
1975b
36,346d
679,026d
77,545
Area
(sq. mi.)
1 ,820d
4,538d
2,670
Population
Density
(persons/mi .')
20d
150d
29
AQMA
Designations
TSP
Counties
No
No
No
SOX
Counties
No
No
No
  - Classification based on maximum measured (or estimated)  pollution concentration  in  the  area:
Priority

Sulfur oxide :
Annual arithmetic mean
24-hour maximum
Particulate matter:
Annual geometric mean
24-hour maximum
I
Greater than
100
455
95
325
II
From - To
60-100
260-455
60-95
150-325
III
less than
60
260
60
150
b - Source:  Projections of Economic Activity for Air Quality Control  Regions,  Prepared  by  U.S.  Department  of  Commerce,  Bureau of Economic
             Analysis, August 1973.
c - Interstate region.
d - Data are for the New Hampshire portion of the AQCR only.

-------
00
                                              TABLE A-2  ATTAINMENT DATES
TSP
Attainment
Dates
AQCR Name
Androscoggin Valley9
Mem'mack Valley - Southern9
New Hampshire
Central New Hampshire
AQCR No.
107
121
149
Primary
7/75
b
7/75
Secondary
7/75
b
7/75
S02
Attainment
Dates
Primary
7/75
b
7/75
Secondary
7/75
b
7/75
            a - Interstate region
            b - Air quality levels presently below standards

-------
             TABLE A-3  AMBIENT AIR QUALITY STANDARDS (yg/m3)

                         TSP            	SO?
Federal
Primary
Secondary
New Hampshire
Annual
75a
60a
60a
24 hr
260b
150b
150b
Annual
80C
60C
24 hr
365b
260b
3 hr
1300b
1300b
Annual
100C
100C
100C
a - Annual geometric mean.
b - Maximum concentration not to be exceeded more than once a year.
c - Annual arithmetic mean.
                                  19

-------
TABLE A-4  NEW HAMPSHIRE AQCR AIR QUALITY STATUS(1973),  TSPa
      TSP Concentration (yg/m3)
                                          No.  Stations Violating Federal

AQCR Name
Androscoggin Valley*3'6
Merrimack Valley - Southernb»e
New Hampshire
Central New Hampshire

AQCR
No.
107
121

149

No.
Stations
Reporting
13
30

3

Highest
Annual
83
60

NA

Reading
24-hr
291
209

162
2nd
Highest
Reading
24-hr
231
197

110
Ambient Air Quality
Primary
Annual
1
0

NA
24-hrc
0
0

0
Annual
1
0

NA
Standards
Secondary
%
8
0

-
24-hrc
3
4

0
%
23
13

0
Reduction
Required
to Meet .
Standards0
+39
+28

-50
Standard
on Which
Reduction
Is Based
Annual
24-hr

24-hr
             x 100
a - 1973 air quality data in National  Air Data Bank as  of July  28,  1974.
b - Interstate region.
c - Violations based on second highest reading at any station.
d - Formula:
               (2nd Highest 24-hr -  24-hr Secondary Standard)
                     (2nd Highest 24-hr - Background)
        or:    (Highest Annual - Annual  Secondary Standard)
                       (Highest Annual - Background)
        whichever is more stringent
e - All noted values occurred in New Hampshire.
NA - Not available

-------
                                                   TABLE A-5  NEW HAMPSHIRE  AQCR  AIR QUALITY  STATUS(1973), S02a
	AQCR Name	

Androscoggin Valley

Merrimack Valley - Southern
  New Hampshire"

Central New Hampshire
AQCR
No.
107
121
No.
Stations
Reporting
(24-hr
Bubbler)
8
13
SO? Concentration (pg/m3)
No.
Stations
Reporting
(Contin.)
3
2
Highest
Annual
NA
51
Reading
24-hrc
173
248
2nd
Highest
Reading
24-hr
66
141
No. Stations Violating
Federal Ambient Air
Quality Standards
Primary
Annual
NA
0
24-hrc
0
0
Secondary
3-hr
0
0
                                                                                                 Reduction
                                                                                                 Required
                                                                                                 To Meet  d
                                                                                                 Standards

                                                                                                   -453

                                                                                                   - 57
Standard
On Which
Reduction
Is Based

 24-hr

 Annual
149
a - 1973 air quality data in National £ir Data Bank as of July 28, 1974
b - Interstate region.

c - Violations based on second highest reading at any station.

d - Formula:
                 (2nd Highest 24-hr - 24-hr Standard)
                          2nd Highest 24-hr

         or:     (Highest Annual - Annual Standard)
                           Highest Annual

         whichever is more stringent
                        x 100

-------
                                           TABLE A-6  NEW HAMPSHIRE  FUEL  COMBUSTION  SOURCE  SUMMARY
                                                                                                                          % AQCR Emissions From


AQCR Name
Androscoggin Valley6
Merrimack Valley - Southern6
New Hampshire
Central New Hampshire


AQCR No.
107
X
121
149


Plants3
1

5
1
Other Fuel
Combustion
Point Sources'3
Part.
3
e
6f
4
SO*
3

17
4
Total Emissions

Sources
1

7
2
(103 tons/yr)d
Part.
30.0

19.9
1.4
SO*
68.6

114.0
3.3
N.H. Fuel Combustion
Sources
Part.
2

22
39
S°_x
17

33
95
a - New Hampshire power plants only
b - New Hampshire point sources,  not including power plants,  which  combined  with  power  plants,  contribute  at  least 90% of  the point source
    fuel combustion emissions
c - Counties in New Hampshire only
d - AQCR total
e - Interstate region
f - These six sources combined with power plants contribute only 60%  of the  point source  fuel combustion particulate emissions, but all
    other sources emit less than  30 tons of particulates  per  year.

-------
                                        TABLE  A-7   NEW HAMPSHIRE EMISSIONS SUMMARY, PARTICULATES

AQCR Name AQCR No.
Androscoggin Valley 107
N.H. Portion
Maine Portion
Merrimack Valley - Southern
New Hampshire 121
N.H. Portion
Mass. Portion
Tft-fal
Tons/yr
29,979
2,515
27,464

19,921
12,581
7,340
Percent
Fnol
Combustion13
20
21
20

42
34
56
Electricity Generation
Point Sources3
Tons/yr
476
17
459

774
774
0
%b
2
1
2

4
6
0
Other Point Source
Fuel Combustion
Tons/yr
3,705
356
3,349

2,339
980
1,359
%b
12
14
12

12
8
19
Area Source
Fuel Combustion
Tons/yr
1,853
145
1,708

5,293
2,558
2,735
%b'
6
6
6

27
20
37
Central  New Hampshire
149
1,350
39
16
                                                                                                             174
                                                                                   13
                                                                                    336    25
a - Power plants only.   NEDS inventory includes  some  industrial  power  generation in  this category.
b - Percentage of total  emissions.

-------
                                              TABLE  A-8  NEW  HAMPSHIRE  EMISSIONS SUMMARY, S02
AQCR Name
Androscoggin Valley
N.H. Portion
Maine Portion
Merrimack Valley - Southern
New Hampshire
N.H. Portion
Mass. Portion
Total
AQCR No. Tons/yr
107 68,618
12,205
56,413
121 113,999
79,948
34,051
Percent
Fuel
Combustion"
35
94
84
98
98
97
Electricity Generation
Point Sources3
Tons/yr
10,980
14
10,966
52,046
52,046
0
_%b
16
0
19
46
65
0
Other Point Source
Fuel Combustion
Tons/yr
37,223
10,563
26,660
19,183
10,085
9,098
&
54
87
47
17
13
27
Area Source
Fuel Combustion
Tons/yr
10,430
913
9,517
40,276
16,294
23,982
_|b
15
7
17
35
20
70
Central  New Hampshire
149
3,304
95
13
1,181
36
1,938
59
a - Power plants only.   NEDS inventory includes  some  industrial  power  generation  in  this  category.
b - Percentage of total  emissions.

-------
                 NEW HAMPSHIRE EMISSION REGULATIONS FOR
                   STATIONARY FUEL COMBUSTION SOURCES

                              Particulates
All stationary combustion sources are limited to the maximum allowable par-
ti cu late emissions obtained from the graph in Figure A-l.

                              Sulfur Oxides
•  Coal:  Existing installations may burn coal with a maximum sulfur content
   of 2.8 pounds per million BTU gross heat content, provided that the weighted
   average of all coal received during a tri-monthly period does not exceed
   2.0 pounds per million BTU gross heat content.  The limit for new installa-
   tions is a maximum of 1.5 pounds of sulfur per million  BTU gross heat con-
   tent, with a maximum tri-monthly average of 1.0 pounds  per million BTU.

•  Fuel Oils:  Sources may burn No. 2 fuel oil with a maximum sulfur content
   of 0.4 percent by weight, No. 4 fuel oil with a maximum of 1.0 percent and
   No. 5 or No. 6 fuel oil with a maximum of 1.5 percent,  except for use in
   the New Hampshire portion of the Androscoggin Valley Air Quality Control
   Region where a 2.2 percent sulfur limit for No. 5 and No. 6 fuel oil is
   permitted.

•  Gaseous Fuels:  A sulfur content of not more than 5 grains per 100 cubic
   feet calculated as hydrogen sulfide (H2S) at standard conditions is permitted.

•  Variance:   On October 17, 1974, the New Hampshire Air Pollution Control
   Commission approved a variance which would permit the use of residual fuel
   oil (No. 5 and No. 6) whose sulfur content does not exceed 2.0 percent by
   weight until May 31, 1975 in the New Hampshire portion  of the Merrimack
   Valley - Southern New Hampshire Interstate AQCR and in  the Central New
   Hampshire Intrastate AQCR.  This variance has been forwarded to EPA for
   approval/disapproval.
                                     25

-------
                                                                  figure A-1

                                NEW HAMPSHIRE  ALLOWABLE PARTICULATE EMISSIONS  FROM FUEL COMBUSTION SOURCES
  DO

  VO
  o
ro
   s-
   (O
  O.

   to
  -a
o
D.

O)


CO

i
     o.oi
                                                                 -..:.-"|4Federal Standard for New Stationary
                                                                      Sources Exceeding 250 x 106  BTU/hr.I
                                                                                                                         m.
                                 10
ill ..._'.JL. ..!_
  100
                                                                                               L_[.L
                                                                                                                  __i.u.-j.t:
                                                                                                                     ma
                                                                                                                    . j. * -'  j--^- liU
                   I
                                                                                                                           If.
                                                                                                                           .-*
                                                                                                                           <

             1000


106 BTU/hr  Input
10,000
                                                                                                                          100,000

-------
                                                              APPENDIX   B
                                                      REGIONAL AIR QUALITY  SUMMARY

                                                                TABLE B-l
                                       REGIONAL INDICATORS FOR  REVISION  OF  PARTICULATE  REGULATIONS



AQCR Name
Androscoggin Valley
Merrimack Valley - Southern
New Hampshire
Central New Hampshire



AQCR No.
107
121

149

No. of


Reporting
13
30

3

Stations

Violating3
Standards
3
4

0

Expected
Attainment
Date
7/75
e

7/75

Total
Emissions
(103 j/yr)
2.5
12.6

1.4

% Emission
From N.H. Fuel
Combustion
20.6
34.3

39.0
Tolerance
For
Emission
Increase
(103 t/yr)c
-11.7
- 5.6

+ 0.7
a - 1973 data
b - For interstate regions this value is the contribution from sources  in the New Hampshire  portion  only.
c - Based on percent reduction required to meet standards from Table A-4 applied against total  emissions.
d - Interstate region
e - Air quality levels presently below standards.

-------
FS>
00
                                                                        TABLE B-2
                                                   REGIONAL INDICATORS FOR REVISION OF S02 REGULATIONS


AQCR Name
Androscoggin Va11eyd
Merrimack Valley - Southernd
New Hampshire
Central New Hampshire


AQCR No.
107

121
149
No. of


Reporting
11

15
0
Stations

Violating9
Standards
0

0
-
Expected
Attainment
Date
7/75

e
7/75
Total
Emissions
(1Q3 T/yr)
12.2

79.9
3.3
% Emission
From N.H. Fuel
Combustion
94.1

98.1
94.8
Tolerance
For
Emission
Increase
(103 t/yr)c
55.3

45.5
NAf
        a - 1973 data
        b - For interstate regions this value is the contribution from sources in the New Hampshire portion only.
        c - Based on percent reduction required to meet standards from Table A-4 applied against total emissions.
        d - Interstate region
        e - Air quality levels presently below standards.
        f - Not available due to lack of SOg air quality monitoring equipment in Region 149.

-------
                                                                 APPENDIX C

                                                             POWER PLANT SUMMARY

                                                                  TABLE C-l

                                                     EXISTING NEW HAMPSHIRE POWER PLANTS

AQCR Name AQCR No.
Androscoggin Valley 107




Plant Name
Public Service Co.
of
New
Hamp.
1975
Capacity
MWa
NA
Est. %
Fuel
Type
oil
1975
Quantity"
2
,050
S
by c
Regulation
0
.4
Boiler
Also
Designed
For Coal
-__
Lost Nation Plant0
Merrimack Valley - Southern 121
New Hampshire




(


Public Service Co.
Merrimack Plant
Public Service Co.
Schiller Plant
Public Service Co.
Daniel St. Plant
Public Service Co.
Newington Plant9
Public Service Co.
of

of

of

of

of
New

New

New

New

New
Hamp.

Hamp.

Hamp.

Hamp.

Hamp.
459

179

21

424

20
coa!
oil
oil

oil

oil

oil

2
86

8

240

8
914
,134
,210

,718

,187f

,344
2
2
2

2

2

2
.6e
.0
.0

.0

.0

.0
yes

yes

no

. no

no
^
Central  New Hampshire
              Manchester Plant

149         Public Service  Co.  of New  Hamp.
              White Lake Plantd
NA
oil
1,860
                                                                                                                             0.4
a - Source:   Steam Electric Plant Factors.  1973  Edition,  National Coal Assn., Washington, D.C.
b - Coal  in  10^ Tons,  Oil  in 103 gal.  NEDS  data.
c - Regulation approved by State, but  still  awaiting  EPA  approval.
d - Gas turbine plant
e - Calculated from 2.0 pounds  of sulfur per million  BTU  assuming 26 million BTU per ton of coal.
f - Calculated using 9.7 BTU/hr per megawatt of  generating  capacity and  150,000 BTU per gallon of fuel oil.  Assume an overall  plant efficiency of 35&
g - Plant scheduled to begin operation in 1974.

-------
                                                       TABLE C-2

                                       NEW HAMPSHIRE POWER PLANT SUMMARY BY AQCR
OJ
o
                                                                          1975
                                                                     Fuel  Required
       1975
Emission Reduction

AQCR Name
Androscoggin Valley


Merrimack Valley - Southern
New Hampshire

Central New Hampshire



AQCR No.
107


121


149


1 UC 1
Type
coal
oil
gas
coal
oil
gas
coal
oil
gas

^-9°/ C
^_L./0 *J
0
2,050
0
0
345,593
0
0
1,860
0

•^^o/ O
^ ' C*lQ O
0
0
0
914
0
0
0
0
0

Part. SO.,
—b -14


-5152C 0


«b NAd


           a - Coal in 10  tons per year; oil  in 10  gal.  per year
           b - Gas turbines not covered by State fuel  combustion particulate regulations.
           c - Includes no data from the new plant scheduled to begin operation in  1974.
           d - Not available due to a lack of data in  NEDS on present sulfur content.

-------
                                                       APPENDIX  D
                                   INDUSTRIAL, COMMERCIAL/INSTITUTIONAL SOURCE SUMMARY

                                                        TABLE D-1
                                           NEW HAMPSHIRE SIGNIFICANT SOURCES3
CO
                 AOCR Name
Androscoggin Valley
Merrimack Valley - Southern
  New Hampshire
Central  New Hampshire
AQCR No.
107
121
NEDS Emissions
(T/yr)
Part. S02
347 10,450
276 4,585
Reduction Under
Existing Regulations
(T/yr)
Part. S0£
-1,564 0
- 251 -85
' % NEDS
Parti cul ate
Emissions
From Coal
(before regulations)
0
0
                                        149
159
1,088
-  112
-21
        a - See Table A-6
        b - Only for significant sources not including power plants.

-------
                                                                TABLE D-2

                                NEW HAMPSHIRE SIGNIFICANT INDUSTRIAL AND COMMERCIAL/INSTITUTIONAL SOURCES
    AQCR Name
Androscoggin
  Valley

Merrimack Valley-
  Southern New
  Hampshi re
AQCR
 No.

 107
 121
                                               Particulate Sources3
                                                                                     SO? Sources'
Central New
  Hampshire
 149
           Plant Name
Groveton Papers Co.
Brown Co.
Brown Co. (Gorham Plant)

Spaulding and Frost
Anheuser-Busch
Emerson Mfg. Co.
Univ. of N.H.
Nashua Corp. (Nashua)
Sprague and Carleton
   County
Coos
Coos
Coos
Rpckingham
Hi llsborough
Merrimack
Strafford
Hillsborough
Cheshire
Draper Div. (N. Amer. Rockwell)      Graf ton
L.W. Packard Co.                     Grafton
Hitchcock Mem. Hosp.                 Grafton
Dartmouth College (McKenzie Hall)    Grafton
           Plant Name
Brown Co.
Brown Co. (Gorham Plant)
Groveton Papers Co.

Anheuser-Busch
Univ. of N.H.
Nashua Corp. (Nashua)
Pease AFB
Phillips Exeter Academy
USM Corp. (Bosboard Div.)
Spaulding Fiber Co.
Clemson Auto Fabrics
Concord Steam Corp.
Nashua - N.H. Foundation
Great Falls Bleachery
Ashuelot Paper Co.
Nashua Corp. (Merrimack)
Hinsdale Products
Syntextils
Paper Service Mills
Homestead Woolen
Dartmouth College (McKenzie Hall)
L.W. Packard Co.
Hitchcock Mem. Hosp.
Plymouth State College
    County
 Coos
 Coos
 Coos
 Hi llsborough
 Strafford
 Hillsborough
 Kockingham
 Rockingham
 Merrimack
 Strafford
 Rockingham
 Merrimack
 Hillsborough
 Strafford
 Cheshire
 Hillsborough
 Cheshire
 Hi llsborough
 Cheshire
 Cheshire
 Grafton
 Grafton
--Grafton
 Grafton
a - Sources listed in descending order of emission quantities.

-------
                                  APPENDIX  E

                              AREA SOURCE SUMMARY



                                  TABLE E-l

                         NEW HAMPSHIRE AREA SOURCES*
                                                        Fuel Burned
       AQCR Name
Androscoggin Valley
AQCR No.

  107
    Type
Coal:
  Anthracite
  Bituminous

Oil:
  Distillate
  Residual
Gas:
  Natural
  Process
Wood:
Amountc
                                                                  510
                                                                  370


                                                               17,540
                                                                  170
                                                                  650
                                                                    0
                                                                2,200
                                           0.7
                                           0.6
                                           2.2
Merrimack Valley -
Southern New Hampshire
  121
Coal:
  Anthracite
  Bituminous

Oil:
  Distillate
  Residual

Gas:
  Natural
  Process
Wood:
                                  5,780
                                 12,530


                                283,520
                                 13,240


                                 20,330
                                      0

                                 18,500
           0.7
           0.6
                                                                         1.9
Central  New Hampshire           149           Coal:
                                                Anthracite        630
                                                Di tuminous      1 ,340

                                              Oil:
                                                Distillate     36,130
                                                Residual          780

                                              Gas:
                                                natural         2,680
                                                Process              0

                                              Wood:             5,200

 a - NEDS data
 b - Coal in  tons; oil in  1,000 gals.;  gas  in MCF; wood  in  tons.

                                    33
                                           0.7
                                           0,6
                                           1.9

-------
                                    TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
  EPA-450/3-75-014
4. TIT
  TITLE AND SUBTITLE
  IMPLEMENTATION PLAN REVIEW FOR  NEW HAMPSHIRE AS
  REQUIRED BY  THE ENERGY SUPPLY AND ENVIRONMENTAL
  COORDINATION ACT
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  U.S. Environmental  Protection Agency,  Office of Air
  Quality Planning and Standards,  Research Triangle
  Park, N.C.,  Regional Office  I,  Boston, Massachusetts
  and TRW, Inc.,  Vienna, Virginia.
12. SPONSORING AGENCY NAME AND ADDRESS
  U.S. Environmental  Protection Agency
  Office of Air  and Waste Management
  Office of Air  Quality Planning  and Standards
  Research Triangle Park, North Carolina 27711
                                                            3. RECIPIENT'S \CCESSION>N( I
             5. REPORT DATE
               February 1975
             6. PERFORMING ORGANIZAT £..'
                                                            8. PERFORMING ORGANIZATION
                                                            10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.

               68-02-1385 '
                                           -H!
             13. TYPE OF REPORT AND PE 3JOS COVES»2.O
                     Final
             14. SPONSORING AGENCY CODE
                                          J
15. SUPPLEMENTARY NOTES
16. ABSTRACT
       Section  IV  of the Energy  Supply and Environmental  Coordination Act of
  (ESECA) requires EPA to review each State Implementation  Plan (SIP) to det?ir:1r;£
  if revisions  can be-^jiade to control regulations for  stationary fuel combusrier;
  sources without  interfering with  the attainment and maintenance of the na;,icj;5l
  ambient air quality standards.   This document, which is also required by S ?r,tie.'?
  IV of ESECA,  is  EPA's report to the State indicating where regulations migrt fcs
  revised.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                                             II
                                             !
                                            J
                                          —li
                  DESCRIPTORS
                                               b.IDENTIFIERS/OPEN ENDED TERMS
                           c. cosf T! Field/Group
 Air  pollution
 State implementation  plans
IS. DISTRIBUTION STATEMENT

  Release unlimited
19. SECURITY CLASS (This Report)
  Unclassified
                                                                          21. NO.
                                               20. SECURITY CLASS (This page)

                                                 Unclassified 	
                                                                          22. PRIC
EPA Form 2220-1 (9-73)
                                              34

-------