EPA-450/3-7 5-051
APRIL 1975
IMPLEMENTATION PLAN REVIEW
FOR
CONNECTICUT
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-75-051
IMPLEMENTATION PLAN REVIEW
FOR
CONNECTICUT
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
April 1975
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CONNECTICUT
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 7
2.1 Summary . 7
2.2 Current Air Quality Status of Connecticut
2.3 General Review of the Current State Implementation 12
Plan
3.0 AIR QUALITY CONTROL REGION ASSESSMENTS 13
3.1 The Assessment Criteria 13
3.2 Eastern Connecticut Intrastate AQCR (41) 15
3.3 Hartford - New Haven - Springfield Interstate AQCR (42) 18
3.4 New Jersey - New York - Connecticut Interstate AQCR (43) 20
3.5 Northwestern Connecticut Intrastate AQCR (44) 23
4.0 REFERENCES 25
APPENDIX A - IMPLEMENTATION PLAN BACKGROUND
APPENDIX B - REGIONAL AIR QUALITY ASSESSMENT
APPENDIX C - POWER PLANT ASSESSMENT
APPENDIX D - INDUSTRIAL/COMMERCIAL/INSTITUTIONAL SOURCE ASSESSMENT
APPENDIX E - AREA SOURCE ASSESSMENT
APPENDIX F - FUEL USE SUMMARY
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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 S0£ 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
maintenance of the NAAQS.
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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 S02 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 a!I 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 Standards 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 affect 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 p_r 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, expand the modeling and monitoring data supporting EPA's
findings. In developing a 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 other indus-
trial 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 (SC>2) 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
quality "indicators" in an attempt to provide an evaluation of a region's
candidacy 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 put
in Appendices C, D, and E.
The State Implementation Plan for the State of Connecticut has been
reviewed for the most prevalent causes of over-restrictive emissions lim-
iting regulations. The major findings of the review are as follows:
FOR S02, THE REVIEW INDICATES THAT SOME POTENTIAL EXISTS FOR
REVISING CURRENT FUEL SULFUR CONTENT REGULATIONS IN THE EASTERN
CONNECTICUT AND NORTHWESTERN CONNECTICUT INTRASTATE AQCR'S.
FOR PARTICIPATES. THE REVIEW INDICATES THAT SOME POTENTIAL
ETlSTS FOR REVISING EMISSION LIMITING REGULATIONS IN THE
NORTHWESTERN CONNECTICUT AQCR.
The supportive findings of the SIP review are as follows:
Connecticut - The State of Connecticut has no air quality standard
which is more stringent than any National Ambient Air Quality
Standard and has not utilized the "example region" approach in
developing its SIP.
Eastern Connecticut Intrastate AQCR - Air quality violations, no to.l-
. erance for an emission increase and modeling results for one major
power plant indicate that little potential exists for revising parti-
culate emission limiting regulations at the present time. Some poten-
tial exists for revising sulfur content regulations based on air qua-
lity although modeling results for the major power plant were negative
for the conversion modeled. Further research of the circumstances
would be needed.
Hartford - New Haven - Springfield Interstate AQCR - Air quality vio-
lations, no tolerance for emission increase proposed Air Quality
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Maintenance Areas and power plant modeling results indicate that little
potential exists for revising either participate or sulfur dioxide emis-
sion limiting regulations in this AQCR.
New Jersey - New York - Connecticut Interstate AQCR - Air quality vio-
lations, no tolerance for emission increase, proposed Air Quality Mainten-
ance Areas and power plant modeling results indicate that little poten-
tial exists for revising either particulate or sulfur dioxide emission.
limiting regulations in this AQCR. In addition, the region is densely
populated.
Northwest Connecticut Interstate AQCR - Air quality data indicate
that some potential exists for revising both particulate and sulfur
dioxide'emission limiting regulations though no modeling was avail-
able. Clean fuel savings may be limited, however, since major point
sources are few. Some clean fuel savings may result from revision
of area source emission regulations but these will probably not be
significant.
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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?
t 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 p_r 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?
t Is there an expected 1975 attainment date 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 toler-
ance for increasing emissions?
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.
The main factor in determining the candidacy for regulation revi-
sion is the air quality status. Any AQCR which has an air quality vio-
lation is automatically given a poor rating. On the other hand, a re-
gion with no air quality violations, no AQMA designations, low to mode-
rate emissions, along with a small percentage of emissions from fuel com-
bustion sources, would receive a good rating. Those AQCR's that have
varying indicators would need further evaluation and would be given a
marginal rating.
2.2 CURRENT AIR QUALITY STATUS OF CONNECTICUT
2.2.1 Definition Of Air Quality Control Regions
The State of Connecticut is comprised of four Air Quality Control
Regions (AQCR's), two intrastate and two interstate. These are listed
below:
Eastern Connecticut Intrastate - AQCR 41
Hartford - New Haven - Springfield Interstate (Mass) - AQCR 42
New Jersey - New York - Connecticut Interstate - AQCR 43
Northwestern Connecticut Intrastate - AQCR 44
Figure 2-1 illustrates the geographic boundaries of the Connecticut
portions of these AQCR's.
8
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TABLE 2-1
STATE IMPLEMENTATION PLAN REVIEW
(SUMMARY)
Connecticut
"Indicators" TSP SO?
AQCR 41
Eastern Conn.
TSP SO?
AQCR 42
Hartford
New Haven
Springfield
TSP S02
AQCR 43
N.J.-N.Y.-Conn.
TSP' SO?
AQCR' 44
Northwestern
Connecticut
TSP S02
t Does the State have air quality standards which
are more stringent than NAAQS?
Does the State have emission limiting 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 emission regulations for fuel savings;
i.e., under the Clean Fuels Policy?
Are there ji£ 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 indica-
tions of a tolerance for increasing emissions?
Are the total emissions from stationary fuel com-
bustion sources proportionally lower than those of
other sources?
9 Do modeling results for fuel combustion sources
show a potential for a regulation revision?
Must emission limiting regulations be revised to
accommodate 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 poten-
tial in the region?
No
Yes
Yes
Yes
No
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
No
No
No
No
Yes
Yes
Yes
Yes
No
No
No
No
Yes
Poor
No
Yes
Yes
Yes
Yes
No
No
Yes
Marg.
Yes
Yes
No
No
No
No
Yes
Poor
No
Yes
Yes
No
No '
No
No
Yes
Poor
Yes
Yes
No
No
No
No
Yes
Poor
Yes
Yes
No
No
No
No
Yes
Poor
No
Yes
Yes
Yes
Yes
No
N.A.
Yes
Marg.
No
Yes
Yes
Yes
Yes
No
N.A
Yes
Marg
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NORTHWESTERN
CONNECTICUT
INTRASTA'
NEW JERSEY
NEW YORK-
CONNECTICUT
INTERSTATE.
HARTFORD-
NEW HAVEN-
SPRINGFIELD
INTERSTATE
(CONNECTICUT-
MASSACHUSETR)
EASTERN
CONNECTICUT
INTRASTATE
Figure 2-1 Air Quality Control Regions in Connecticut
10
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2.2.4 Emissions of Sulfur Dioxide and Particulates
The contributions of fuel combustion sources located in Connecticut
to the total emissions in each AQCR are summarized 'in Table A-6 for both
TSP and SO,,. Tables A-7 and A-8 provide a more detailed view by means of
categorization in terms of combustion source type, i.e., electricity gener-
ation, industrial-commercial-institutional, and area. In general, fuel
combustion sources account for a majority of the particulate (56%) and S02
emissions (86%) in the State of Connecticut.
2.3 GENERAL REVIEW OF THE CURRENT STATE IMPLEMENTATION PLAN
The Connecticut State Implementation Plan contained control strate-
gies and regulations for both particulate and sulfur dioxide which will
be adequate enough to attain State air quality standards which are the
same as the Federal Standards. The State did not utilize the example
region approach in formulating its SIP.
The state regulations for the control of particulate matter include a
requirement that existing fuel burning sources cannot emit particulate
matter in excess of 0.20 pounds per million BTU of heat input and 0.10
pounds per million BTU of heat input for new sources (Table A-9). The
state also has a visible emission regulation which says that no person shall
exceed No. 1 on the Ringleman Chart or 20 percent opacity except for periods
aggregating not more than 5 minutes in any 60 minutes provided they still
do not exceed No. 2 on the Ringleman Chart or 40 percent opacity. Other
regulations covering particulate emission are fugitive dust, incineration,
process industries - general, and process industries - specific (iron
cupolas, asphalt plants, foundries, and concrete batching).
The State regulations for the control of sulfur compound emissions
include the requirement that after April 1, 1973 no person shall burn fuel
which contains sulfur in excess of 0.5% by weight. Other regulations
include controlling sulfur compounds from sulfuric acid plants, sulfur
recovery plants, non-ferrous smelter sulfite pulp mills, and other process
sources.
12
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2.2.2 Air Quality Standards
A summary of the Federal and Connecticut air quality standards for particu-
lates and S02 is presented in Table A-2. It should be noted that the standards
adopted by Connecticut are identical to the Federal standards for both
pollutants.
2.2.3 Air Quality Monitoring
Connecticut air quality data for total suspended particulates (TSP)
and sulfur dioxide (SCL) are given in Tables A-4 and A-5 respectively.
Air quality monitoring in the Eastern Connecticut AQCR consists of six
stations for TSP and eight stations for S02 (eight 24 hr. bubbler, no continuous
stations). Monitoring data for 1973 indicated a violation of federal TSP
standards but no violations of S02 standards.
In the Hartford-New Haven-Springfield Interstate AQCR, air quality
monitoring consists of 67 stations for TSP and 34 stations for S02 (25
24-hr, bubbler, 9 continuous stations). Thirty-four of the TSP monitors,
17 of the 24-hour S02 monitors and 8 continuous S02 monitors are located in
Connecticut. The monitoring data indicated violations of the federal stand-
ards for both TSP and S02- The region has also been proposed as an Air Qua-
lity Maintenance Area (AQMA) for both pollutants.
In the New Jersey-New York-Connecticut Interstate AQCR, air quality
monitoring consists of 166 stations for TSP and 118 stations for S02 (47
24-hr, bubbler, 71 continuous stations). Seventeen of the TSP monitors,
17 of the 24-hour S02 monitors and 16 of the continuous S02 monitors are
located in Connecticut. Violations of the federal standards for both TSP
and S02 were reported and the region has been proposed as an AQMA for both
pollutants.
In the Northwestern Connecticut AQCR there were no violations of TSP
or SCL standards reported by the four TSP stations and the three S02 stations
(all 24-hr, bubbler, no continuous) in 1973.
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3.0 AIR QUALITY CONTROL REGION ASSESSMENTS
The purpose of this section is to evaluate the available information
for the State of Connecticut and determine the feasibility of revisions
to the SIP which would result in clean fuel conservation. The first sub-
section provides explanations of the methods used in making the regional
assessments. Subsections 3.2 through 3.5 present the results of the appli-
cation of the criteria for each of the Connecticut AQCR's.
3.1 THE ASSESSMENT CRITERIA
In determining the potential of the AQCR's in a state for emission
standard relaxation, a set of five evaluation criteria has been established:
The Regional Indicators,
Power Plant Evaluation,
t Other Major Fuel Burning Point Source Evaluation,
Area Source Evaluation,
t Fuel Use Assessment.
The following paragraphs provide explanations of the use of these
criteria.
3.1.1 The Regional Evaluation
This assessment is based on a review of regional air quality data,
various regional or subregional categorizations (e.g., priority classifi-
cations or proposed air quality maintenance area (AQMA) designations), and
other information available to EPA. The assessment must be made for each
pollutant separately and is made on the basis of 7 indicators: (1) recent
air quality violations; (2) expected NAAQS attainment dates; (3) proposed
Air Quality Maintenance Area (AQMA) designations; (4) total emissions; (5)
portion of emissions from fuel combustion sources in Connecticut; (6) regional
tolerance for emission increase; and (7) S02 priority classification. Tables
B-l and B-2 tabulate these criteria for each AQCR for TSP and SO-, respectively.
This preliminary analysis will be supplemented by a more detailed evaluation
after the individual source categories are reviewed.
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3.1.2 . Power Plant Evaluation
The evaluation of power plants was based on the modeling analyses per-
12 3
formed by Walden Research ' and EPA . Both assumed certain oil-to-coal conver-
sions for some of the power plants in Connecticut and then performed plant-
by-plant diffusion modeling to determine the air quality impacts of the
plants, before and after conversion. The power plant data appear in
Appendix C: Table C-l summarizes pertinent data by plant,including
fuel use and emissions; Table C-2 summarizes these data for each AQCR; and
Table C-3 lists the projected 1975 capacity and fuel use for the major
plants in each AQCR.
3.1.3 Major Industrial and Commercial Point Source Evaluation
No modeling results were available for the larger industrial, commer-
cial, or institutional point sources in Connecticut. Consequently, the
analysis was restricted to an estimate of the emissions reduction resulting
from the compliance of these sources with current Connecticut emission and
fuel regulations. The results appear in Appendix D.
3.1.4 Area Source Evaluation
4
Area source emissions data were available by AQCR and by county from
the National Emissions Data System (NEDS). These data were used to determine
the emissions from Connecticut fuel combustion area sources which are given
in Appendix E. Table E-l indicates the types of fuel burned by fuel com-
bustion area sources, sulfur contents and emissions by AQCR.
3.1.5 Fuels Analysis
Fuel usage data for the State of Connecticut are tabulated in Appendix
F. These data provide a survey of the distribution of fuels by user type
for the entire state, as well as by AQCR. The data is fundamentally impor-
tant to potential clean fuel savings which will be significant in a region
which can tolerate a regulation revision only if a significant amount of
fuel is burned in the region. The data has its shortcomings however, be-
cause the data for the Interstate AQCR.'s are for the entire AQCR rather than
the Connecticut portion of the AQCR.
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3.2 EASTERN CONNECTICUT INTRASTATE AQCR 41
3.2.1 Regional Assessment (Appendix B)
The regional evaluation of the Eastern Connecticut AQCR indicates
that little potential exists for increasing particulate emissions but some
potential exists for increasing SOp emissions. The indicators are sum-
marized below:
Particulates - one reported air quality violation and no
tolerance for emission increase.
Sulfur Dioxide - no air quality violations, no proposed
AQMA designations and a positive tolerance for emission
increase.
Tables B-l and B-2 list the indicators by AQCR for TSP and S02,
respectively.
3.2.2 Power Plant Assessment (Appendix C)
NEDS data indicate the existence of six power plants in the Eastern
Connecticut AQCR. Together, they account for approximately 22 percent
and 61 percent of the particulate and sulfur dioxide emissions within the
AQCR, respectively. Three of the six plants; those at Preston, Killingly,
and Putnam, are gas turbine plants burning distillate oil, and contribu-
ting almost negligible amounts of particulates and SOo. Of the three
steam turbine generating plants, two are very small and also contribute
negligible amounts of pollution. These two are the plant at New London
burning liquid petroleum gas (LPG) and the plant at Waterford burning a
small quantity of residual oil. The only major plant in the region is the
600 megawatt plant at Montville which burns significant amounts of both
coal and residual oil, and small amounts of distillate and diesel oil;
the diesel in a reciprocating diesel engine. All six plants are opera-
ted by Connecticut Light and Power.
A fuel conversion was modeled by Wai den Research for the Montville
plant. According to the analysis, units 1, 2 and 5 of the plant's six
15
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units are convertible to coal. These units are rated at 34.5, 34.5 and 82
MW, respectively. The modeling results indicated that currently the plant,
o
burning .9% sulfur oil, contributes about 128 yg/m to the 24-hour S0? con-
3
centrations and about 7 yg/m to the 24-hour TSP concentrations. The anal-
ysis was based on 1972 data and is limited to 24-hour concentrations because
a special diffusion model suited to the valley topography was utilized. If
units 1, 2 and 5 were converted to 3.0% sulfur, 15% ash coal, and op-
erating at 80% control efficiency, the modeling results indicated that
the plant would contribute about 460 yg/m3 to the 24-hour SOg concen-
trations and about 191 yg/m3 to the 24-hour TSP concentrations, vio-
lating the federal primary S0? standard and secondary TSP standard.
The results of the modeling are given below in Table 3-1:
TABLE 3-1
MONTVILLE PLANT MODELING RESULTS
Maximum 24 Hour Concentration (yg/m") M.
Plant/Conversion
Montville (a)
1972 Operations
Switch Units
(1,2,5)
so2
'Nominal
Load
128
460
k
Maximum
Load
144
533
Parti culates
Nominal
Load
7
191
Maximum SO?
Load
8
224
jximum Annual
2
itrations (yg/m )
Parti culates
_
Nominal Load Case - This presents maximum concentrations calculated
by the model based upon average monthly emission rates.
''Maximum Load Case - This case was calculated assuming the plant to
be operating at 95% of rated capacity. Concentrations were pre-
dicted for the 20 highest concentration days under nominal load.
A 10% safety factor was subsequently added to these predicted con-
centrations because the maximum load case involves a greater plume
rise, and a somewhat higher concentration may therefore occur on a
different day and at a different receptor.
16
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In addition, on the basis of other preliminary modeling, EPA did
not advise conversion of the Montville plant to coal firing for the
following reasons:
The river valley topography, in which the plant is situated,
severely limits effective dispersion of emissions from the
Montville stacks. Consequently, there is a strong likelihood
of a significant impact from increased emissions in the cities
of Norwich and New London, Connecticut. Though presently
below the primary standards, air quality in these areas is not
sufficiently good to be able to absorb a substantial increase
in emissions without a sizeable risk of violating the primary
standards. Furthermore, the age and original design efficiency
of existing particulate control equipment does not warrant
belief that a reasonable degree of particulate collection can
be obtained while operating on coal. Lastly, since it is deemed
impossible to retrofit flue gas desulfurization equipment at the
Montville plant, it is unlikely that the plant could ever be
brought into compliance with Connecticut emission regulations.
In summary, the Montville plant is not recommended for conversion to
coal, at least not the conversion modeled.
3.2.3 Major Industrial and Commercial Point Source Assessment (Appendix D)
Since no modeling was available for industrial and commercial point
sources, the analysis was limited to a comparison of the current emissions
and the allowable emissions for these sources.
As indicated in Tables A-7 and A-8, industrial and commercial point
sources contribute approximately 7 percent to the particulate emissions
and 14 percent to the SCL emissions from fuel combustion sources in the
Eastern Connecticut Intrastate AQCR. Table D-l lists one significant
industrial/commercial point source in the AQCR for particulates; Table
D-2 lists 5 significant sources for SOp. These significant sources ac-
count for about 6 percent and 14 percent of the AQCR fuel combustion
particulate and SOp emissions, respectively. Table D-3 summarizes the
current emissions and potential emission reductions for the AQCR indicating
that existing regulations might allow an increase in particulate emissions
from industrial and commercial sources. However, air quality data for the
AQCR indicates that this would not be possible.
17
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3.2.4 Area Source Assessment (Appendix E)
Area fuel combustion sources contribute significantly to the par-
ticulate and sulfur dioxide emissions in the Eastern Connecticut Intra-
state AQCR. Tables A-6 and A-7 indicate that they represent the source
of about 30 percent and 23 percent of the particulate and sulfur dioxide
emissions, respectively. Table E-l shows area fuel combustion sources
burn coal, oil, natural gas and wood with oil burning accounting for the
majority of emissions. It is unlikely, however, that these sources
could convert from oil or gas to coal in light of the AQCR particulate
problem and the inherent inflexibility of these sources to convert.
Some clean fuel savings may result from increasing sulfur contents but
it is unlikely to be a significant amount.
3.3 HARTFORD-NEW HAVEN-SPRINGFIELD INTERSTATE AQCR 42
3.3.1 Regional Assessment (Appendix B)
The regional evaluation of the Hartford-New Haven-Springfield AQCR
indicated that little potential exists for increasing either particulate
or S02 emissions. The supportive indicators are as follows:
t Particulates - reported air quality violations, proposed
AQMA designations and no tolerance for emission increase.
Sulfur Dioxide - reported air quality violations, proposed
AQMA designations and no tolerance for emission increase.
Tables B-l and B-2 list these .indicators by AQCR for TSP and S02,
respectively.
3.3.2 Power Plant Assessment (Appendix C)
Ten power plants are listed in the NEDS data for the Connecticut
portion of the Hartford-New Haven-Springfield Interstate AQCR. Connecti-
cut Power and Light operates a very small LPG fired plant at Berlin, two
small distillate oil fired gas turbine plants at Enfield and Branford, a
small residual oil and natural gas fired plant at Waterbury, and a plant
at Thompsonville which has one distillate oil and natural gas boiler, and
one gas turbine also using distillate oil and natural gas. The emissions
of both particulates and S02 are less than 100 tons per year for each of
these five plants.
18
-------
The remaining five plants in the region each emit more than TOO tons
per year of SO^. They are: Hartford Electric's 220 megawatt South
Meadow plant and 420 megawatt Middletown plant, both of which have
residual oil fired boilers and distillate oil fired gas turbines; United
Illuminating Company's 20 megawatt Derby plant and 160 megawatt English
plant, both using residual oil fired boilers; and Connecticut Light and
Power's Devon plant which burns coal, residual and distillate oil as
boiler fuel, and distillate oil in a gas turbine.
Collectively, the ten power plants contribute approximately 6 per-
cent and 34 percent to the particulate and sulfur dioxide emissions in
the Connecticut portion of the AQCR, respectively.
Preliminary modeling of a fuel conversion was done by EPA for the
Hartford Electric Company's Middletown plant. The plant consists of three
units, two of which are convertible to coal. Concentrations estimated by
the modeling indicated that changing units 1 and 2 from .5% sulfur oil to
a maximum of 2.5% sulfur coal and keeping unit 3 on a .5% sulfur oil would
result in contributions to 24-hour S02 concentrations of 160 yg/m3, an
increase of about 130 yg/m3 over the oil case. Particulate concentrations
would be about 40 yg/m3 with 15% ash and 90% control. Actual concen-
trations may be higher due to the effects of the river valley topography
in which the plant is located. These terrain effects are not taken into
account in the model. No conclusions can be drawn from this modeling be-
cause of the terrain effects and the lack of air quality data in areas
immediately around the plant. Any conversion would require increased mon-
itoring and high levels of control.
3.3.3 Major Industrial and Commercial Point Source Assessment (Appendix D)
As previously mentioned, no modeling data were available for indus-
trial and commercial point sources, therefore the analysis was limited
to a comparison of the current emissions and the allowable emissions for
these sources. As indicated in Tables A-7 and A-8, industrial and com-
mercial point sources contribute approximately 12 percent to the parti-
culate emissions and 27 percent to the S02 emissions in the Hartford-New
19
-------
Haven-Springfield Interstate AQCR. Table D-l lists one significant
industrial/commercial point source in the AQCR for participates;
Table D-2 lists 26 significant sources for S02> These significant
sources account for about 1 percent and 8 percent of the AQCR fuel
combustion particulate and SOp emissions, respectively. Table D-3
summarizes current emissions and potential emission reductions, in-
dicating that existing regulations might allow a slight increase in
particulate emissions from industrial and commercial sources. How-
ever, air quality data for the AQCR indicate that this would not be
feasible.
3.3.4 Area Source Assessment (Appendix E)
Area fuel combustion sources in the Hartford-New Haven-Spring-
field AQCR account for approximately 41 percent of the particulate
emissions and 36 percent of the sulfur dioxide emissions. Table E-l
shows fuel use for area sources in the AQCR and indicates that oil
is the major fuel used. It is unlikely that these sources could con-
vert from oil to coal because of the inherent lack of flexibility of
the sources themselves and the AQCR particulate problem. It is un-
likely that higher sulfur oil could be used because of the S02 pro-
blem.
3.4 NEW JERSEY-NEW YORK-CONNECTICUT INTERSTATE AQCR 43
3.4.1 Regional Assessment (Appendix B)
The regional evaluation of the New Jersey-New York-Connecticut
AQCR indicates little potential for increasing particulate or sulfur
dioxide emissions based on 1973 air quality data. The indicators are
summarized below:
Particulates - reported air quality violations, proposed
AQMA designations and no tolerance for an emission increase.
Sulfur Dioxide - reported air quality violations, proposed
AQMA designations and no tolerance for an emission increase.
Tables B-l and B-2 list these indicators by AQCR for TSP and
S02, respectively.
20
-------
3.4.2 Power Plant Assessment (Appendix C)
Of the four power plants in the Connecticut portion of the New Jersey-
New York-Connecticut AQCR, three emit a significant amount of SO^; Two
of these, the 170 megawatt Steel Point plant and the 650 megawatt Bridge-
port Harbor plant burn residual oil and are operated by United Illuminating
Co. The third, Connecticut Light and Power's Norwalk Harbor plant has a
capacity of 325 megawatts and burns coal, residual and distillate oil in
boilers, plus a small quantity of deisel fuel in a reciprocating engine
generator. The fourth plant is a small distillate oil fired gas turbine
plant operated by Connecticut Light and Power at Greenwich.
Jointly, the four plants contribute approximately 43 percent to the
particulate emissions and 68 percent to the sulfur dioxide emissions in
the AQCR.
A fuel conversion was modeled by Wai den Research for Connecticut Light
and Power Norwalk Harbor plant. The results (shown in Table 3-2) indicated
o
that presently the plant, burning .8% sulfur oil, contribures about 23 yg/m
to local 24-hour S02 concentrations and about 1 yg/m to local 24-hour
TSP concentrations.
Converting Units 1 and 2 to 2.5% sulfur, 15% ash coal, and operating
at 95% control efficiency yielded local 24-hour concentrations of 96 yg/m3
and 13 yg/m3 for S02 and TSP, respectively.
TABLE 3-2
NORWALK HARBOR PLANT MODELING RESULTS
Maximum 24-Hour Concentration (yg/m ) Max
S00
Plant/Conversion
Norwalk Harbor
1972 Operations
Switch Unit 1, 2
Nominal
Load
23
96
*" Maximum
Load
28
115
Parti culates Concen
Nominal
Load
1
13
Maximum S0?
Load
2 <1
15 4
imum Annual ^
trations (yg/m )
Parti culates
:;
21
-------
Preliminary modeling performed by EPA indicated similar results. Using
.5% sulfur oil the plant contributed about 15 yg/m3 to local 24-hour S00
3
concentrations and 2 yg/m to local 24-hour TSP concentrations. Converting
the two units to 2.5% sulfur, 15% ash coal and operating at 95% control
efficiency would result in local 24-hour concentrations of approximately 110
yg/m3 of S02 and 15 yg/m3 of TSP.
Other factors were considered by the Connecticut Department of
Environmental Protection which estimated on an annual basis, combustion of
2.5% sulfur coal in units 1 and 2 would result in an incremental impact
of S02 of 17 yg/m3.
Existing annual S09 averages in nearby areas range from 50 to 70
3
yg/m . The incremental inpact in particulates of burning 15% ash coal
would be approximately 8 yg/m . Annual background TSP concentration in
3
the area of maximum impact is 80 yg/m . By these modeling results, the
annual primary standards for TSP and SOp would probably be violated by
conversion of the Norwalk Harbor plant to coal. Furthermore, the plant
is located in a densely populated region of Connecticut and conversion
to coal would exacerbate an existing TSP problem.
3.4.3 Major Industrial and Commercial Point Source Assessment (Appendix D)
Since no modeling data were available for industrial and commercial
point sources, the analysis was limited to a comparison of the current
emissions and the allowable emissions for these sources. As indicated in
Tables A-7 and A-8, industrial and commercial point sources contribute
approximately 2 percent to the particulate emissions and 3 percent to the
S02 emissions in the New Jersey-New York-Connecticut Interstate AQCR.
Table D-l lists no significant industrial/commercial point source in
the AQCR for particulates; Table D-2 lists 5 significant sources for
S02. These significant sources account for about 2 percent of the AQCR
fuel combustion S02 emissions. Table D-3 summarizes current emissions
and potential emission reductions indicating that existing regulations
do not allow any increase in either particulate or S02 emissions.
22
-------
emissions for these sources. As indicated in Table A-7 and A-8, indus-
trial and commercial point sources contribute approximately 6 percent to
the particulate emissions and 10 percent to the SO emissions in the
Northwestern Connecticut Intrastate AQCR. Table D-l lists no significant
industrial/commercial point sources in the AQCR for particulates; Table
D-2 lists 1 significant source for SOp. This significant source accounts
for about 7 percent of the AQCR fuel combustion SOp emissions! Table D-3
summarizes the current emissions and potential emission reductions for
the AQCR indicating no potential for increasing emissions under the exis-
ting regulations.
3.5.4 Area Source Assessment (Appendix E)
Area fuel combustion sources account for 67 percent of the parti-
culate emissions and 84 percent of the sulfur dioxide emissions in the
Northwestern Connecticut AQCR. However, total emissions for the AQCR
are relatively low and conversion from oil to coal is not very practical
for these sources. Some clean fuel savings may result from increasing
sulfur contents but it is unlikely to be a significant amount.
24
-------
3.4.4 Area Source Assessment (Appendix E)
Area fuel combustion sources contribute approximately 38 percent
and 26 percent to the particulate and sulfur dioxide emissions in the
New Jersey-New York-Connecticut AQCR, respectively (Tables A-6 and A-7).
Table E-l shows fuel use for area sources in the AQCR. Conversions are
unlikely because of the TSP and SCk problems, and the inflexible nature
of the sources involved.
3.5 NORTHWESTERN CONNECTICUT INTRASTATE AQCR 44
3.5.1 Regional Assessment (Appendix B)
The regional evaluation for the Northwestern Connecticut AQCR
indicates that some potential exists for increasing particulate and sulfur
dioxide emissions. The indicators are summarized below:
Parti cul ates - no reported air quality violations, no
proposed AQMA designations and a tolerance for an
emission increase.
Sulfur Dioxide - no reported air quality violations,
no proposed AQMA designations and a tolerance for an
emission increase.
Tables B-l and B-2 list these indicators by AQCR for TSP and
SOp, respectively.
3.5.2 Power Plant Assessment (Appendix C)
The only power plants in the Northwestern Connecticut AQCR are two
distillate oil gas turbines operated by Hartford Electric Co. at Torrington.
These plants both emit less than 20 tons per year each of particulates and
SOp, and therefore are relatively insignificant sources. Together, they
account for approximately 3 percent of the particulate emissions and 1 per-
cent of the SOp emissions from fuel combustion sources.
3.5.3 Major Industrial and Commercial Point Source Assessment (Appendix D)
As previously mentioned no modeling data were available for
Connecticut industrial and commercial point sources, therefore the analysis
was limited to a comparison of the current emissions and the allowable
23
-------
4.0 REFERENCES
1. "Modeling Analysis of Power Plants for Fuel Conversion", (Group I),
prepared by Wai den Research, for Environmental Protection Agency,
15 July 1974.
2. Ibid.. (Group IV), 9 September 1974.
3. Preliminary modeling done by the Monitoring and Data Analysis
Division of the Office of Air Quality Planning and Standards, EPA,
Research Triangle Park, North Carolina.
4. "1972 National Emissions Report," Report No. EPA 450/2-74-012,
U.S. Environmental Protection Agency, June 1974.
5. "Steam - Electric Plant Factors/1972," 23rd edition, National
Coal Association, 1973.
6. "Compilation of Air Pollutant Emission Factors," Publication
No. AP-42, U.S. Environmental Protection Agency, January 1972.
7. "Federal Air Quality Control Regions," Publication No. AP-102,
U.S. Environmental Protection Agency, January 1972.
8. SAROAD (Storage and Retrieval of Aerometric Data) computer print-
outs for 1973.
9. Federal Power Comission (FPC) fuel usage projections for major
power plants in Connecticut, status as of 5 July 1974.
10. "Stationary Source Fuel Summary Report," National Emission Data
System, Environmental Protection Agency, 23 September 1974.
25
-------
26
-------
APPENDIX A
IMPLEMENTATION PLAN BACKGROUND
-------
TABLE A-l
CONNECTICUT AIR POLLUTANT PRIORITY CLASSIFICATIONS
Air Quality
Control Region
Eastern Conn.
Hartford-New Haven-
Springfield (Mass.)
New Jersey-New York-
Conn. {N. J., N. Y.)
Northwest Conn.
Program
Number
41
42
43
44
Priority
Classification
TSP S0u
II
I
I
III
A
III
I
I
III
Population
1975
(Millions)
. 0.45
2.54C
18.72°
0.16
Proposed .
AQMA Designation
TSP S0₯
None None
Total Connecticut Portion
for Both Pollutants
Total Connecticut Portion
for Both Pollutants
None None
'Criteria based on maximum measured (or estimated) pollution concentration in area:
Priority
Sulfur dioxide:
Annual arithmetic mean
24-hour maximum
Particulate matter:
Annual geometric mean
2 4 -hour maximum
I
Greater than
(pg/m3)
100
455
95
325
II
From - To
(pg/m3)
60-100
260-455
60-95
150-325
III
Less than
(pg/m3)
60
260
60
150
Federal Register, July, 1974 counties showing potential for NAAQS violations due to growth.
"AQCR Total population. The population in the Conn, portion of AQCR's 42 and 43 were
1.7 (xlO6) and .78 (xlO6) respectively in 1970.
-------
TABLE A-2
AMBIENT AIR QUALITY STANDARDS
All Concentrations in yg/m3
Federal
State
Total Suspended Particulates
Annual 24-Hour
Sulfur Dioxide
Annual 24-Hour 3-Hour
Primary
Secondary
Primary
Secondary
75(6)
60(6)
75(6)
60(6)
260a
150a
260a
150a
80(A)
-
80 (A)
60(A)b
365a
-
365a
260a« b
1300a
_
1300a
(G) Geometric Mean
(A) Arithmetic Mean
a Not to be exceeded more than once per year.
b These values were Federal Standards until they were rescinded.
-------
TABLE A-3
AIR QUALITY STANDARDS ATTAINMENT DATES
Air Quality Particulates Sulfur Dioxide
Control Region Primary Secondary Primary Secondary
Eastern Conn.
Hartford-New Haven-
Springfield
New Jersey-New York-
Conn.
Northwest Conn.
a Air Quality Levels Presently Below Primary Standards
b Air Quality Levels Below Secondary Standards
a
5/75
5/75
b
6/75
5/75
.5/75
b
b
6/75
6/75
b
b
6/75
6/75
b
-------
TABLE A-4
CONNECTICUT AIR QUALITY STATUS (1973), TSPa
TSP Concentration(tjg/m3)
# Stations Exceeding
Air Quality
Control Region
Eastern Conn. (41 )
Hartford-New Haven-
Springfield5 (42)
New Jersey-New York-
Conn. b (43)
Northwest Conn. (44)
*
Stations
Reporting
6
67
166
4
Highest
Annual
_
117e
125f
-
Reading
24-Hr
270
443
489C
165
Highest
Reading
24-Hr
156
396
4249
124
Ambient Air
Primary
Annual 24-Hrc
0
1 1
5 5
0
Qual i ty
Annual
.
2
18
-
Standards
Secondary
%
-
1
11
-
2^-Hr" %
1 17
12 18
56 34
0 0
Reduction
Required
to Meet .
Standards0
+ 5
+70
+72
-29
Standard
on Which?
Reduction
Is Based
24-Hr
Annual
Annual
24-Hr
*1973 air quality in National Air Data Bank, July 28, 1974.
Interstate.
Violations based on more than one reading in excess of standard.
Fonnula:
2nd Highest 24 Hr - 24 Hr Secondary Standard lnn Annual - Annual Secondary Standard ,nn
2nd Highest 24-Hr - Backgroundx ' Annual - Backgroundx IUU
eReading recorded in Massachusetts portion of AQCR.
Reading recorded in New Jersey portion of AQCR.
9Reading recorded in New York portion of AQCR.
Background Values: Eastern Connecticut and Northwestern Connecticut AQCRs: 30yg/m3
Hartford-New Haven-Springfield: 36yg/m3
New Jersey-New York-Connecticut 35ng/m3
-------
TABLE A-5
CONNECTICUT AIR QUALITY STATUS (1973),
Air Quality
Control Region
Eastern Conn. (41)
Hartford-New Haven-
Springfield0 (45)
New Jersey-New York-
Conn.0 (43)
Northwest Conn. (44)
Stations
Reporting
24-Hr
(Bubbler)
8
25
47
3
a!973 air quality data in National Air
b Interstate.
°Violation based on 2nd highest reading
Formula:
2nd Highest 24-Hr - 24-Hr
1
Stations
Reporting
(Contin.)
0
9
71
0
f_
Highest Reading
Annual 24-Hr
8 45
32e 992
869 1381
37
2nd
Highest
Reading Primary Secondary
24-Hr Annual 24-Hrc 3-Hr
30 00 -
-f 0 41
93h 1 10 2
30 0 0 0
Reduction
Requi red
To Meet
Standards
-900
+ 63f
+ 7
-1166
Standard
on Which %
Reduction
Is Based
Annual
24-Hour
Annual
24-Hour
Data Bank, July 28, 1974.
at any station.
Standard inn Annual - Annual Standard ,nn
2nd Highest 24-Hr A ' Alinual
eReading recorded in Massachusetts portion of AQCR.
Highest reading used to calculate reduction since 2nd highest was not available.
^Reading recorded in New York portion of AQCR.
Reading recorded in New Jersey portion of AQCR.
data indicated the existence of four stations exceeding the standard more
an once. However, data was only given for one station.
-------
TABLE A-6
CONNECTICUT FUEL COMBUSTION SOURCE SUMMARY
AQCR Name
Eastern Conn.
Hartford-New Haven
Springfield
N.J. - N.Y. -
Conn.
Northwest Conn.
AQCR
No.
41
42
43
44
No. of
Power Plants
Other Fuel
Combustion Point
Sources*5
TSP S00
5
26
No. of
Area Sources
4
5
AQCR
Total Emissions
(10J tons/year)
Part. S02
6.9
31.2
59.4 191.5
(Conn. (Conn...
23.8)f 93.0)T
228.4 641.2
(Conn. (Conn.
12.2)f 57.9)f
% Emissions from
Conn. Fuel Coabustioo.
Sources(10 tons/year)
Part. S00
1.2
3.2
59
24
(59)9
4
(82)9
75
98
46
(96)9
9
(97)9
93
a - Connecticut Power Plants.
b - All data for significant sources in Connecticut only. Significant sources are those non-power plant
sources whose total plant emissions are greater than 100 tons per year of the pollutant in question.
c - Conn, counties.
d - In addition to these six power plants indicated by NEDS, there is also another plant (Norwich Department
of Public Utilities) indicated by Steam Electric Plant Factors and a nuclear plant (Millstone Point Co.).
The Norwich plant is not included in emission totals.
e - In addition to these ten power plants indicated by NEDS there is also another plant (Wellington Dept. of
Public Utilities) indicated by Steam Electric Plant Factors and a nuclear plant (Conn. Yankee Atomic Power)
The Wallington plant is not included in emission totals.
f - Conn, emissions.
g - Percentage of Conn, emissions.
-------
TABLE A-7
CONNECTICUT PARTICULATE EMISSIONS SUMMARY6
AQCR
Eastern Conn. (41)
Hartford-New Haven-
Springfield (42)
Conn. Portion
Mass. Portion
Total
New Jersey-New York-
Conn. (43)
Conn. Portion
N.J., N.Y. Portion
Total
Northwestern Conn. (44)
Total
Conn. Total
.Total
(10J) tons/yr)
Electricity Generation
(103 tons/yr)d %
6.9
Point Source Fuel Combustion
(1Q3 tons/yr) _%_
0.5
Area Source Fuel Combustion
(1Q3 tons/yr) %
23.8
35.6
59.4
8
12
20
1.5
12.6
14.1
6
35
24
2.8
5.6
8.4
12
16
14
12.2
216.2
228.4
1.2
295.9
44.1
4
73 '
77
1
100
100
5.2
8.2
13.4
0 04
29.0
8.2
43
4
6
3
10
19
0.2
9.0
9.2
0.07
18.2
3.6
2
4
4
6
6
8
2.1
9.8
3.7
13.5
4.6
55.6
60.2
0.8
76.6
17.3
30
41
10
23
38
26
27
67
26
39
Source: 1972 National Emissions Report, EPA, June 1974.
Excludes emissions from electricity generation.
cPercent of total for all AQCR's.
NEDS data; year of record 1971. NEDS data summary includes emissions from industrial power
generation under the heading "Electric Generation". The values in this Table are for power
plants operated by electric utility companies only.'
-------
TABLE A-8
CONNECTICUT SULFUR DIOXIDE EMISSIONS SUMMARY8
AQCR
Total
(IP3 tons/yr)
Electricity Generation
(IP3 tons/yr)d %
Point Source Fuel Combustion
(1Q3 tons/yr) %
Area Source Fuel Combustion
(1Q3 tons/yr) %
Eastern Conn. (41)
Hartford-New Haven-
Springfield (42)
31.2
4.4
14
7.2
23
Conn. Portion
Mass. Portion
Total
New Jersey-New York-
Conn. (43)
Conn. Portion
N.J., N.Y. Portion
Total
Northwestern Conn. (44)
Total
Conn. Total
93.0
98.5
191.5
57.9
583.3
641.2
3.2
867.1
185.3
11
11
22
7
67
74
0
100
100
31.2
46.3
78.0
39.6
154.7
194.3
0.03
291.2
89.7
34
48
41
68
27
30
1
33
48
24.9
19.0
43.9
1 .6
44.6
46.2
0.3
94.8
31.2
27
19
23
3
8
7
10
11
17
32.6
31.5
64.1
15.3
310.5
325.8
2.7
399.8
57.8
35
32
33
26
53
51
84
46
31
Source: 1972 National Emissions Report, EPA, June 1974.
Excludes emissions from electricity generation.
°Percent of total for all AQCR's.
dNEDS data; year of record 1971. NEDS data summary includes emissions from industrial power
generation under the heading "Electric Generation". The values in this Table are for power
plants operated by electric utility companies only.
-------
TABLE A-9
CONNECTICUT EMISSION REGULATIONS
Particulate Emissions
Existing Sources New Sources
.20 lbs/106 BTU .10 lbs/106 BTU
Sulfur Dioxide
All Sources (After April 1, 1973)
sulfur content of fuels limited
to 0.5% by weight
-------
APPENDIX B
REGIONAL AIR QUALITY ASSESSMENT
-------
TABLE B-l
REGIONAL INDICATORS FOR REVISION OF TSP REGULATIONS
AQCR Name
Eastern Conn.
Hartford-New Haven-
Springfield
N. J. - N. Y. - Conn.
Northwest Conn.
No. of Stations3
Violating
AQCR No. Reporting Standards
41 6
42 67
43 166
44 4
1
14C
74d
0
Expected
Attainment
Date
6/75
5/75
5/75
b
Any
Proposed Total Conn.
AQMA Emissions
Designations? (103Tons/Year)
No 6.9
Yes 23.8
Yes 12.2
No 1.2
Tolerance
for Conn.
% Emission Emissions
from Fuel Increase
Combustion (10JTons/Year)
59 - .345
59 -16.66
82 - 8.78
75 + .348
aTotal number of stations throughout AQCR.
Air Quality levels presently below Secondary Standards.
GTwo stations violating annual secondary standard, and 12 stations
violating 24-Hr secondary standard.
18 stations violating annual secondary standard, and 56 stations
violating 24-Hr standard.
-------
TABLE B-2
REGIONAL INDICATORS FOR REVISION OF S02 REGULATIONS
AQCR Name
Eastern Conn.
Hartford-New Haven-
Springfield
N. J. - N. Y. - Conn.
Northwest Conn.
AQCR No.
41
42
43
44
No. of
Reporting
8
25
47
3
Stations
Violating
Standards
0
4b
13C
0
Expected
Attainment
Date
a
6/75
6/75
a
Any
Proposed
AQMA
Designations?
No
Yes
Yes
No
Total Conn.
Emissions
(lO^Tons/Year)
31.2
93.0
57.9
3.2
% Emission
from Fuel
Combustion
98
96
97
93
Tolerance
for Conn.
Emissions
Increase
(103Tons/Year)
+ 280.80
- 58.59
- 4.05
+ 37.12
Air Quality levels presently below standards.
Stations violating 24-Hr primary standard.
C0ne station violating annual primary standard, 10 stations
violating 24-Hr primary standard and 2 stations violating
the 3-Hr secondary standard.
-------
APPENDIX C
POWER PLANT ASSESSMENT
-------
TABLE C-l
CONNECTICUT POWER PLANT SUMMARY3
AQCR Name AQCR No. Plant Ownership and Location
Eastern Connecticut 41 Connecticut Light
Montville
Connecticut Light
New London
Connecticut Light
Preston
Connecticut Light
Waterford
Connecticut Light
Killingly
Connecticut Light
Putnam
Hartford-New Haven- 42 Connecticut Light
Springfield Berlin
Connecticut Light
and
and
and
and
and
and
and
and
Power
Power
Power
Power
Power
Power
Power
Power
Fuel
Type
Coal
Dist. Oil
Resid. Oil
Diesel6
LPG
Dist. Oilf
Resid. Oil
Dist. Oilf
Nat. Gasf
Dist. Oilf
LPG
Dist. Oilf
Fuel .
Quantity0
37
218
2
1
1
2
1
1
,900
730
,860
406
,000
,870
,000
96
6
,310
,970
,900
Sulfur0
Content
2
0
0
0
0
0
0
0
0
.60
.20
.99
.20
0
.01
.95
.02
0
.02
0
.01
NEDS Emissions
(T/yr)
Part.
1380
2
16
12
1
19
2
16
SO,
18,826
0
13
75
1
16
0
13
Allowable Emissic
(T/yr)a
Part.
3394
18
26
15
2
32
18
27
SO,
8955
0
650
39
25
400
0
650
-------
AQCR Name
Hartford-New Haven-
Springfield
AQCR No. Plant Ownership and Location
42 Connecticut Light and Power
Thompsonvilie
Hartford Electric Co.
Hartford
Hartford Electric Co.
Middletown
Connecticut Light and Power
Branford
United Illuminating Co.
Derby
Connecticut Light and Power
Devon
TABLE C-l
(cont.)
Fuel
Type
Dist. Oil
Nat. Gas
Dist. Oilf
Nat. GasT
Resid. Oil
Dist. Oilf
Resid. Oil
Dist. Oilf
Fuel .
Quantity
209
9
159
8
84,b70
25,536
175,900
970
Sul furc
Content
0.02
0
0.02
0
0.99
0.01
0.98
0
NEDS Emissions Allowable Emissions
(T/yr) (T/yr)d
Part. S00 Part. S00
31 7 25
488 6758 1627 12,273
486 13537 2652 6,903
Dist. Oil'
1,990
0.01
17
14
28
700
Resid. Oil
Coal
Dist. Oil
Resid. Oil
Dist. Oilf
3,091
3,920
112
80,930
1,060
0.99
2.70
0.20
0.96
0.20
14
332
238
6311
46
1241
120
3,238
United Illuminating Co.
Resid. Oil
55,780
0.99
161 4335
837 2,189
-------
AQCR Name
Hartford-New Haven-
Springfield
New Jersey-New York-
Connecticut
AQCR No. Plant Ownership and Location
42
43
Northwestern Connecticut
44
a - NEDS data; year of record 1971.
b - Solid fuel in tons, liquid fuel
c - Percent sulfur by weight.
d - Calculated by applying existing
e - Reciprocating engine.
f - Gas turbine.
Connecticut Light and Power
Waterbury
United Illuminating Co.
Bridgeport
United Illuminating Co.
Bridgeport
Connecticut Light and Power
Greenwi ch
Connecticut Light and Power
Norwalk
Hartford Electric Co.
Torrington
Hartford Electric Co.
10 gallons, gas 10 cuboc feet. All annual rates.
regulations to NEDS emission and fuel use data.
TABLE C-l
(cont.)
Fuel
Type
Resid. Oil
Nat. Gas
Resid. OH
Dist. Oilf
Resid. Oil
Dist. Oilf
Coal
Resid. Oil
Dist. Oil
Diesel6
Dist. Oilf
Dist. Oilf
Fuel .
Quanti typ
120
2,142
276,600
1,120
70,940
5,400
382,000
66,600
1,140
999
2,250
2,010
NEDS Emissions
Sulfur0 (T/yr)
Content Part. S00
0.99 17 9
0
0.56 355 12,178
0.06
0.60 190 3,343
0.01 45 38
2.60 4606 24,009
0.99
0.20
0.20
0.01 19 16
0.01 17 14
Allowable Emissions
(T/yr)d
Part. S00
22 5
4165 10,933
1064 2,786
86 1 ,900
1985 6,305
32 800
28 700
-------
TABLE C-2
CONNECTICUT POWER PLANT SUMMARY
AQCR Name
Eastern Connecticut
Hartford-New Haven-
Springfield
New Jersey-New York-
Connecticut
AQCR No.
41
42
43
Northwestern Connecticut 44
Reduction Under
Existing Regulations
No. of
Plants3
6
10
4
Fuel
Type
Coal
Resid. Oil
Dist. Oil
Nat. Gas
Diesel
LPG
Coal
Resid. Oil
Dist. Oil
Nat. Gas
LPG
Coal
Resid. Oil
Dist. Oil
Diesel
Fuel . (Tons/yr)
Quantity Part. S00
37,900 1430 18,931
219,860
5,006
6
406
2,000
3,920 1536 31,216
400,391
31,936
2,159
1,970
382,000 5196 39,568
414,140
7,660
999
(Tons/yr)a
Part. S00
-2057 8862
-4969 5113
-2104 17644
Dist. Oil
4,260
36
30
- 24 -1470
- Connecticut plants only.
d -
See Table C-l for data on individual plants
All annual use.
3 c
Solid fuel in tons, liquid fuel 10 gallons, gas 10 cubic feet.
NEDS data; year of record 1971. NEDS data summary includes emissions*from industrial power
generation under the heading "Electric Generation". The values in this Table are for power
plants operated by electric utility companies only.
Existing regulations applied against NEDS emissions and Fuel data.
NEDS emissions are currently below allowable emissions.
Negative values indicate
-------
TABLE C-3
1975 POWER PLANT FUEL USE SUMMARY
Air Quality
Control Region
Eastern Conn. (41)
Plant Name
Connecticut
Light & Power Co.
(Mentville)
1975 Capacity.
(MW)
557
1975 Fuel Use
Type %S
Coal 2.8
Oil .55
Quality3
12
234,611(F)
1974
%sb
2.44
%S by
Regulation
.5
.5
Hartford-New Haven
Springfield (42)
Norwich Dept. of
Public Utilities 143
(Norwich)
Conn. Light & Power
Co. (Devon) 454
Hartford Electric Co.
(Wddletown) 797.39
Hartford Electric Co.
(Hartford) 216.75
United Illuminating
Co. (Derby) 20.0
Wellington Dept. of
Public Utilities 22.5
(Wallingford)
United Illuminating Co.
(New Haven) 445C
United Illuminating Co.
(New Haven) 146.29
Oil
Oil
NA
.53
Coal
Oil
Oil
Oil
Coal
2.2
.55
.50
NA
NA
Oi 1 NA
1344(S)
MA
Oil
.46
189,546(F) 1.13
41 2.07
260,861(F) 1.10
71,862(F) .50
2730(S) NA
9(S) NA
^,167d NA
42,042(F) .46
.5
.5
.5
.5
.5
.5
.5
.5
.5
-------
TABLE C-3 (Cont.)
1975 POWER PLANT FUEL USE SUMMARY
Air Quality
Control Region
N.J.-N.Y. -
Conn. (43)
Plant Name
1975 Capacity
(MM)
1975 Fuel Use
Conn. Light & Power
Co. (Norwalk)
326.39
United Illuminating Co.
(Bridgeport) 660.50
United Illumingating Co.
(Bridgeport) 155.50
Type %S
Oil .56
011 .39
Oil .40
e ,
Quality
148,218(F)
260, 609 (F)
41,874(F)
1974
%sb
1.15
.40
.40
%S by
Regulation
.5
.5
.5
a Coal - 103 tons/year, Oil - 103 gal/year, Gas - 106 cu.ft./year. Estimates are from FPC (F), the NEDS (N)
files of June 1974, or Steam Electric Plant Factors (S), 1973 Edition, National Coal Association, Washington,
D.C. 1975 fuel use was assumed the same as 1973 unless there was a change in generating capacity.
In some cases fuel sulfur contents have changed between 1973 and 1974 though complete fuel use was not
available for 1974.
Operative in 1975.
JO
Fuel use calculated from generating capacity using 8.5 x 10 BTU/yr input per megawatt (assumes 35% over-
all plant energy conversion efficiency) and 150 x 10^ BTU per gallon of oil.
-------
APPENDIX D
INDUSTRIAL/COMMERCIAL/INSTITUTIONAL SOURCE ASSESSMENT
-------
TABLE D-l
CONNECTICUT SIGNIFICANT9 SOURCES, PARTICULATE
AQCR Name
Eastern Connecticut
Hartford-New Haven-
AQCR No.
41
42
Plant Name
Pfizer Inc.
Uni royal
Fuel
Type
Resid. Oil
Resid. Oil
Fuel b
Quantity
39,850
10,709
Sulfurc
Content
0.96
0.98
Emissions
(T/yr)
NEDSd Allowable'
246 598
124 161
Springfield
a - All data for significant sources in Connecticut only. Significant sources are
those non-power plant sources whose total plant fuel combustion emissions are
greater than 100 tons per year of the pollutant in question.
o c
b - Liquid fuel in 10 gallons, gas 10 cubic feet. All annual rates.
c - Percent sulfur by weight.
d - NEDS data; year of record 1971.
e - Calculated by applying existing regulations to NEDS emission and fuel use data.
-------
TABLE D-2
CONNECTICUT SIGNIFICANT3 SOURCES, SO,
AQCR Name AQCR No. Plant Name
Eastern Connecticut 41 Pfizer Inc.
Federal Paper Board Co.
American Thread Co.
General Dynamics
Rogers Corp.
Hartford-New Haven- 42 Uni royal
Springfield
01 in Corp.
United Aircraft Corp.
United Aircraft Corp.
Yale University
Yale University
Chase Brass & Copper
Fuel
Type
Resid. Oil
Res id
Resid
Resid
Resid
Resid
Resid
Resid
Dist.
Resid
Resid
Nat.
Resid
Resid
Resid
. Oil
. Oil
. Oil
. Oil
. Oil
. Oil
. Oil
Oil
. Oil
. Oil
Gas
. Oil
. Oil
. Oil
Fuelb
Quantity
39,850
13
4
1
2
1
10
8
8
6
5
5
5
,500
,740
.650
,025
.750
,709
,940
,563
,828
139
635
,280
,220
,640
Sul furc
Content
0
0
0
0
0
0
0
0
0
0
1
0
0
0
.96
.50
.95
.47
.48
.87
.98
.94
.85
.80
.30
0
.98
.95
.85
Emissions
(T/yr)
NEDS Allowable6
3004
528
351
139
120
823
660
523
444
408
391
376
1565
528
185
146
69
420
351
308
273
208
206
221
-------
TABLE D-2
(cont.)
AQCR Name AQCR No. Plant Name
Hartford-New Haven- 42 United Aircraft Corp.
Springfield
Combustion Engineering
Dexter Corp.
United Aircraft Corp.
A. N. Pierson Inc.
United Aircraft Corp.
Pratt Whitney Mach. Tool
Uni royal
Hartford Hospital
Uni royal
Pond Lily Co.
Armstrong Rubber Co.
Fuel Fuelb
Type Quantity
Resid. Oil 5,320
Resid. Oil 8,091
Resid. Oil
Nat. Gas
Resid. Oil
Resid. Oil
Resid. Oil
LPG
Resid. Oil
Resid. Oil
Resid. Oil
Resid. Oil
Resid. Oil
Resid. Oil
Nat. Gas
7,000
54
3,425
2,880
5,750
17
2,716
2,598
2,340
2,400
2,179
3,990
33
Sul furc
Content
0.81
0.47
0.50
0
1.00
0.98
0.48
0
1.00
0.98
0.98
0.95
0.95
0.47
0
Emissions
(T/yr)
NEDS Allowable
338
297
274
270
222
216
212
200
180
178
162
147
209
316
274
135
113
225
106
102
92
94
85
156
-------
TABLE D-2
(cent.)
AQCR Name AQCR No. Plant Name
Hartford-New Haven- 42 Dart Ind.
Springfield
Amerbelle Corp.
Lydall Inc.
Yale University
G. Fox Co.
Betnis Co.
Tad Jones
New Jersey-New York- 43 General Electric
Connecticut
United Aircraft Corp.
Industrial Development
Fund
American Cyanamid
Fuel
Type
Res id
Res id
Res id
Res id
Res id
Resid
Res id
Resid
Resid
Resid
Resid
Resid
Nat.
. Oi
. Oi
. Oi
. Oi
Fuelb
Quantity
1 1,780
1 1 ,760
1
1
. Oil
. Oi
. Oi
. Oi
. Oi
. Oi
. Oi
. Oi
Gas
1
1
1
1
1
1.
1
1
1
1
1
2
8
2
2
1
,700
,736
,500
,295
150
,600
,010
,540
,270
,770
100
Sul f urc
Content
1
1
0
0
0
1
0
0
1
0
1
1
.00
.00
.97
.95
.98
.00
.50
.50
.00
.90
.00
.00
0
Emissions
^(T/yr) e
NEDSd Allowable6
140
138
130
130
115
109
102
627
179
178
139
70
69
67
68
59
58
102
314
99
89
70
Carpenter Technology
Corp.
Resid. Oil 3,164
0.50
124
124
-------
TABLE D-2
(cont.)
AQCR Name
Northwestern Con-
necticut
AQCR No. Plant Name
44
Kimberly Clark
Fuel
Type
Fuelu
Quantity
Resid. Oil 5,310
Sulfuru
Content
0.50
Emissions
d(T/yr)
NEDS0 Allowable6
208
208
a - All data for significant sources in Connecticut only. Significant sources are
those non-power plant sources whose total plant fuel combustion emissions are
greater than 100 tons per year of the pollutant in question.
J c.
b - Liquid fuel in 10 gallons, gas 10 cubic feet. All annual rates.
c - Percent sulfur by weight.
d - NEDS data; year of record 1971.
e - Calculated by applying existing regulations to NEDS emission and fuel use data.
-------
TABLE D-3
CONNECTICUT SIGNIFICANT9 SOURCE SUMMARY
NEDS Emissions
Reduction Under
Existing Regulations
AQCR Name
Eastern Connecticut
Hartford-New Haven-
Springfield
New Jersey-New York-
Connecticut
Northwestern Connecticut
AQCR No.
41
42
43
44
Fuel
Type
Resid. Oil
Resid. Oil
Dist. Oil
Nat. Gas
LPG
Resid. Oil
Resid. Oil
Fuel0
Quantity
63,515
103,966
8,563
722
17
17,754
5,310
(Tons/yr)c
Part. S00
246 4142
124 7185
0 1247
0 208
(Tons/yr)d
Part. S00
-352 1649
- 37 2798
0 551
0 0
a - All data for significant sources in Connecticut only. Significant sources are those
non-power-plant sources whose total plant emissions are greater than 100 tons per
per year of the pollutant in question. Sources are listed in Tables D-l and D-2.
o c
b - Liquid fuel in 10 gallons, gas in 10 cubic feet. All annual rates.
c - NEDS data year of record 1971. Emissions listed are those from sources which are
significant emitters of the indicated pollutant, i.e. particulate emission values
do not include particulate emissions from significant SOp sources unless a source
is a significant source of both pollutants.
d - Existing regulations applied against NEDS emissions and fuel data.
-------
APPENDIX E
AREA SOURCE ASSESSMENT
-------
TABLE E-l
CONNECTICUT AREA SOURCES'
Fuel Burned
Emissions
AQCR Name AQCR No.
Eastern Conn. 41
Hartford-New Haven - 42
Springfield
Type
Coal :
Anthracite
Bituminous
Oil:
Distillate
Residual
Gas:
Natural
Process
Wood:
Coal :
Anthracite
Bituminous
Oil:
Distillate
Residual
Gas:
Natural
Process
Wood:
Amount
1,530
5,630
125,270
35,580
6,450
4,200
4,560
32,150
464,290
211,700
38,640
2,400
%S TSP
.7 14
2.4 676
.2 701
.6 563
58
52
.7 41
2.4 3,862
.2 2,756
.6 2,730
361
30
S00
35
593
2,674
3,849
2
1
104
3,386
10,433
18,634
12
1
-------
TABLE E-l (Cont.)
CONNECTICUT AREA SOURCES*
Fuel Burned
Emissions'
AQCR Name AQCR No. Type
New Jersey-New York - 43 Coal :
Connecticut Anthracite
Bituminous
Oil:
Distillate
Residual
Gas:
Natural
Process
Wood:
Northwestern Conn. 44 Coal:
Anthracite
Bituminous
Oil:
Distillate
Residual
Gas:
Natural
Process
Wood:
Amount
2,560
14,950
233,180
106,280
18,840
900
1,220
2,300
52,450
17,150
2,660
1,300
%S
.7
2.4
.2
.6
-
. -
.7
2.4
.2
.6
-
-
TSP
23
1,796
1,304
1,277
172
1
11
277
251
212
24
16
so2
58
1,575
4,933
8,723
5
0
28
243
963
1,447
0
0
a NEDS data 3
b Coal in tons; Oil in 10 gals; Gas in MCF; Wood in tons.
c Emissions in tons/year.
-------
APPENDIX F
FUEL USE SUMMARY
-------
APPENDIX F
FUEL USE SUMMARY
-------
TABLE F-l
CONNECTICUT FUEL USE SUMMARY'
Air Quality
Control Region
Coal (10J tons)
Anthracite Bituminous
Oil (10-3 Gals)
Residual Distillate
Gas (10. cu.ft.)
Natural Process
Eastern Connecticut
Intrastate (41)
Area Sources
Point Sources
Total
Hartford-New Haven
Springfield Interstate
(42)
Area Sources
Point Sources
Total
New Jersey-New York ,
Connecticut Interstate
(43)
Area Sources
Point Sources
Total
Northwestern
Connecticut Intrastate
(44)
Area Sources
Point Sources
Total
Connecticut0
Area Sources
Point Sources
Total
1.53
1.53
12.44
226.06
238.50
426.86
167.33
549.19
1.22
1.22
9.87
226.06
353.93
5.63
37.9
43.53
35.74
933.94
977.16
57.97
3209.93
3267.90
2.30
2.30
55.03
419.30
474.34
35,580
286,891
322,471
345 ,950
737,573
1083,523
3405,720
5214,636
8620,356
17,150
6,387
23,537
370,710
1328,513
1699,223
125,270
5,011
130,281
745,680
42,424
788,104
4524,760
535,764
5060,524
52,450
4,259
56,709
875,190
60,431
935,621
6350
6
6356
54,960
5,355
60,315
479,220
145,407
624,627
2,660
92
2,752
67,180
4,650
71 ,830
a NEDS "Stationary Source Fuel Summary Report"
b Entire AQCR not just Conn, portion
c Connecticut fuel use includes only the Conn, portion of the two interstate
AQCR's (42, 43)
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-051
3. RECIPIENT'S ACCESSIOWNO.
4. TITLE AND SUBTITLE
IMPLEMENTATION PLAN REVIEW FOR CONNECTICUT AS REQUIRED
BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION
ACT
5. REPORT DATE
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle
Park, N.C., Regional Office I, Boston, Mass., and
TRW, Inc., Vienna, Virginia
11. CONTRACT/GRANT NO.
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
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Section IV of the Energy Supply and Environmental Coordination Act of 1974,
(ESECA) requires EPA to review each State Implementation Plan (SIP) to determine
if revisions can be made to control regulations for stationary fuel combustion
sources without interfering with the attainment and maintenance of the national
ambient air quality standards. This document, which is also required by Section
IV of ESECA, is EPA's report to the State indicating where regulations might be
revised.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Air pollution
State Implementation Plans
18. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
61
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
------- |