STATE OF CONNECTICUT

STATE OF CONNECTICUT

Dt~PARTMENT OF ENVIRONMENTAL PROTECTION

Statement of Reasons Pursuant to Connecticut General Statutes Section 4-168(d)

HEARING REPORT

Amendment of the Regulations of Connecticut State Agencies Concerning the Adoption of Section 22a-174-19a -- Control of Sulfur Dioxide Emissions from Power Plants and Other Large Stationary Sources of Air Pollution

and the Revision of Section 22a-174-22 -- Control of Nitrogen Oxide Emissions

Co-Hearing Officers: Carmine DiBattista, Chief, Bureau of Air Management Christopher James, Director, Planning & Standards Division, Bureau of Air

Management Hearing Date: September 21, 2000

(Printed on Recycled Paper) 79 Elm Street * Hartford, CT 06106-5127

An Equal Opportunity Employer ~elebraiing Connecticut Coastal Resource Management: 1980- 2000

TABLE OFCONENTS

Introduction

2

Administrative Requirements

A. Hearing Report Content

B. Adoption of Regulations Pertaining To Activities for which the Federal

Government has Adopted Standards or Procedures

2

C. Summary of Executive Order No. 19

3

III. Background, Summary and Text of the Proposed Reghlations

4

A. Background

4

B. Development of the Proposed Regulations

5

C. Role of Recent Health Studies in the Development of the

Proposed Regulations

.6

D. Summary of the Regulations as Proposed for Public Hearing

6

1. Proposed Section 19a

6

2. Proposed Section 22

7

E. Text of Proposed RCSA Section 22a-174-19a

7

F. Text of Proposed RCSA Section 22a-174-22

13

IV. Statement of Principal Reasons in Support of the Department's Intended Action 29

V. Statement of Principal Considerations in Opposition to the Department's

Intended Action as Urged in Written or Oral Comments and the Department's

Reason for Rejecting Such Considerations

30

A. Principal Considerations Raised in Opposition to the Proposed Regulations 30

B. Reasons for Rejecting Considerations in Opposition to the

Proposed Regulations

31

VI. General Comments on Proposed Sections 22a-174-19a and 22a-174-22

33

A. General Comments on the Public Health Implications of the Proposed Regulations

33

? 1. Connecticut Department of Public Health (DPH)

34

2. Northeast States for Coordinated Air Use Management by

David R. Brown, Sc.D.

34

3. American Lung Association of Connecticut by

Thomas Gordar, M.D.

35

4. Connecticut Coalition for Environmental Justice by

Mark Mitchell, M.D., MPH, FACPM

35

5. Jonathan Levy, lead author of "Estimated Public Health Impacts

of Criteria Pollutant Air Emissions from the Salem Harbor and

Brayton Point Power Plants"

35

6. NRG Energy, Inc. Reports and Revie~vs of the Levy Study

36

7. Wisvest-Connecticut, LLC

37

8. Richard J. Londergan, Ph.D.

38

9. Cambridge Environmental Inc. by Dr. Peter Valberg, Ph.D.

37

10.~ Physicians for Social Responsibility by Jefferson H. Dickey, M.D. 38

11. Pfizer, Inc. by Mr. William D. Huhn

38

Department's Response to General Comments on the Public Health

Implicationsof the Proposed Regulations

39

General Comments on the Environmental Benefits of the

Proposed Regulations

39

1. United States Environmental Protection Agency (EPA) Region 1 39

2. Northeast States for Coordinated Air Use Management

40

3. Clean Air Task Force ecosystem consultant, Ellen Baum

40

Department's Response to Environmental Protection Testimony

40

General Comments on the Implications of the Proposed Regulations

with Respect to Reliability of Electric Service in Connecticut and

Associated Cost

41

Connecticut Department of Public Utility Control

41

2. NRG Energy, Inc.

41

3. NOVARCO, Ltd. By Craig Poler

43

4. Wisvest-Connecticut, LLC

43

5. Clean Air Task Force and Coalition for Clean Air by David Marshal4l 3

6. Conservation Law Foundation

44

7. Pfizer Inc. by William D. Huhn

44

8. Competitive Power Coalition of New England, Inc. by Neal Costello45

Department's Response to General Conmaents on the Implications

of the Proposed Regulations with Respect to Reliability of Electric Service

in Connecticut and Associated Costs

45

1. Electric System Reliability

45

2. Fuel Availability and Cost

46

3. Fuel Diversity Issues

47

General Comments in Support of the Use of Market-based Incentives in the

Proposed Regulations

47

1. Northeast States for Coordinated Air Use Management

by Jason Grumet

47

Northeast States for Coordinated Air Use Management

by David Brown, ScD.

49

Jonathan Levy, lead author of "Estimated Public Health Impacts of

Criteria Pollutant Air Emissions from the Salem Harbon and

Brayton Point Power Plants"

49

Connecticut Business and Industry Association

49

5. Wisvest-Connecticut LLC

50

6. NRG Energy, Inc. Statement ofR.K. Raufer, Ph.D., P.E.

51

7. Fitzgerald Environmental Brokerage Services by Mr. Andrew Kruger 53

8. Pratt & Whitney, a United Technologies Company

53

9. Pfizer Inc. by Mr. William D. Huhn

54

10. The Clean Energy Group by Mr. Michael Bradley

54

11. Connecticut Resources Recovery Authority

54

12. Northeast Utilities Generating Services by Mr. William J. Nadeau 54

13. Capitol District Energy Center by Mr. Brian O'Rourke

54

14. International Brotherhood of Electrical Workers Local 420

55

General Comments in Opposition to the Use of Market-based Incentives

in the Proposed Regulations

55

Comments of Sen. Edith Prague

55

2. Clean Air Task Force/Connecticut Coalition for Clean Air

55

3. Conservation Law Foundation

55

4. Connecticut Coalition for Environmental Justice

56

5. American Lung Association of Connecticut

56

6, Sierra Club - Connecticut Chapter

57

I. Miscellaneous Comments Opposed to the Use of Market-based Incentives 57.

Response to Comments on the Use of Market-based Incentives

in the Proposed Regulations

58

K. Hearing Officers' Recommendation

61

VII. Summary of Specific Comments on Proposed RCSA Section 22a-174-19a

62

A, General Comments

62

1. Comment regarding the extent SO2 emission reductions

62

2. Comment regarding a regional approach

62

Definitions - 22a- 174-19a(a)

63

1. Comment regarding the definition of"early reduction credit"

63

2. Comment regarding the definition of "generation period"

63

3. Comment regarding the definition of"SO2 DERC"

63

Applicability - 22a-174-19a(b)

64

1. Comment regarding the applicability of section 19a to peaking units 64

Sulfur Dioxide Emission Standards and Fuel Sulfur Limits Effective

After December 31, 2001 - 22a-174-19a(c)

65

Comment regarding means of implementation of the first phase

of SO2 emission reductions

65

Comments regarding the implementation date

66

3. Comment regarding the statement of source obligation

67

4. Comments regarding the 0.5% fuel sulfur limit

68

5. Comments regarding the 0.55 lbs/MMBTU emission limit

69

6. Comments regarding the averaging period for the 0.51bs/MMBTU

Emission limit

70

E. Additional Emission Reduction Requirements - 22a- 174-19a(d)

71

iii

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