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 ------- 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 ------- 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 ------- 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. ------- 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. ------- 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. ------- 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. ------- 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 ------- 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. ------- 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. ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- |