M. Jodi Rell 

GOVERNOR 

STATE OF CONNECTICUT 

October 6, 2009 

The Honorable Lisa P . Jackson 

Administrator 

U.S . Environmental Protection Agency 

Ariel Rios Building, 1101 A 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460 

Dear Administrator Jackson: 

RECHVED 

OCT 1 3 2009 

--

OFFICE OF THE REGMnL AN"INISTRATOR 

I am writing to provide you with Connecticut's recommended attainment designations for the revised national 

ambient air quality standard (NAAQS) for airborne lead, which was finalized by the U.S. Environmental 

Protection Agency (EPA) on October 15, 2008. Section 107(d)(1) of the Clean Air Act (CAA) provides up to 

one year after adoption of a new or revised NAAQS for states to submit recommendations identifying areas 

that comply with the standard or that violate or contribute to nearby violations of the standard . Based on a 

review of monitored data and consistent with CAA Section 107(d)(1) and EPA guidance, the entire state of 

Connecticut should be designated as attainment for the revised lead NAAQS. 

This recommendation for a statewide attainment designation is supported by available lead monitoring and 

emissions data, as summarized in the attachment. The Connecticut Department of Environmental Protection's 

(CTDEP) most recent ambient lead measurements associated with total suspended particulate (TSP) monitors 

were collected in calendar year 2002. Those data indicate that maximum 3-month running averages at that 

time were 0.01 p,g/m3, well below the revised lead NAAQS of 0.15 pg/m3 . More recent lead levels gathered 

through 2008 are estimated to be less than 0.015 pg/m3, as derived from Connecticut's fine particle (PMZ.5) 

speciation sites . These low measured lead levels are consistent with the low estimated emissions from 

individual lead sources in Connecticut, all of which are significantly less than either the 0.5 ton/year or 

1 .0 ton/year emission thresholds currently identified by EPA as triggering the need for source-specific ambient 

lead monitoring. When considered together, both the ambient monitored data and source emission levels 

support an attainment designation for the revised lead NAAQS throughout Connecticut . 

Please contact Anne Gobin, Chief of CTDEP's Bureau of Air Management at 860-424-3026 with any 

questions regarding this recommendation. 

Attachment 

cc: 1 . Leighton (EPA Region 1) 

D. Conroy (EPA Region 1) 

A . Marrella (CTDEP) 

A . Gobin (CTDEP) 

EXECUTIVE CHAMBERS " STATE CAPITOL 

210 CAPITOL AVENUE, HARTFORD, CONNECTICUT 06106 

TEL (860) 566-4840 " FAX (860) 524-7396 " www.CT.GOV 

GOVERNOR . RELL@CT.GOV 
ATTACHMENT 

Connecticut's Recommended Designations for the 2008 Lead NAAQS 

Summary of Ambient Monitoring and Source Emissions Data 

(October 2009) 

On October 15, 2008, the U.S . Environmental Protection Agency (EPA) finalized revisions to the national ambient air quality standard (NAAQS) for airborne lead, adopting a more stringent 

standard of 0.15 ~tg/m3 (three month rolling average) compared to the previous NAAQS of 1 .5 

ptg/m3(quarterly average) . Section 107(d)(1) of the Clean Air Act (CAA) provides up to one 

year after adoption of a new or revised NAAQS for states to submit recommendations 

identifying areas that comply with the standard or that violate or contribute to nearby violations 

of the standard . As summarized below, available lead ambient monitoring and source emissions 

data support a designation of attainment for all of Connecticut for the revised lead NAAQS. 

Summary of Lead Ambient Monitoring Data 

CTDEP's most recent monitoring for ambient lead levels in total suspended particulates (TSP) 

was conducted in downtown Waterbury through the end of 2002. As summarized in Table 1, 

3-month average lead concentrations in 2002 were more than a full order of magnitude below the 

2008 NAAQS of 0.15 gg/m3. More recent measurements of lead have been collected in New 

Haven as part of the Speciated Trends Network (STN) and in Cornwall as part of the Interagency 

Monitoring of Protected Visual Environments (IMPROVE) program using PM2.5 filters (see 

Figure 1) . Utilizing the "2/3rds method" described in the literature 1,2,3, lead-PM,o concentration 

estimates were calculated from the PM2,5 measurements (i .e ., measured lead-PMZ.S levels were 

multiplied by 1 .5 - the inverse of 2/3rds -- to estimate lead-PM,o levels). Calculated lead-PM~o 

values are all less than 0.01 pg/m3, more than a full order of magnitude below the 2008 lead 

NAAQS. 

Summary of Lead Source Emission Levels 

In addition to reviewing ambient lead measurements, CTDEP also examined available emissions 

data to identify the largest sources of lead in Connecticut, as summarized in Table 2 and Figure 

2. All sources identified had lead emissions below 0.3 tons/year, less than 30% of the 1 .0 

ton/year source magnitude identified by EPA as requiring source-oriented ambient monitoring . 

Recommendation 

When considered together, the low levels of both ambient monitored and source emissions of 

lead support an attainment designation for the revised lead NAAQS throughout Connecticut. 

' Allen et al . 2001 . Size Distributions of Trace Metals in Atmospheric Aerosols in the United Kingdom. Atmospheric Environment. 35. 4581-4591 . 

'' Fernandez et al 2001 . Size Distribution of Metals in Urban Aerosols in Seville. Atmospheric Environment. 35. 2595-2601 . 

j Singh et al . 2002. Size Distribution and Diurnal Characteristics of Particle-Bound Metals in Source and Receptor Sites of the Los Angeles Basin. Atmospheric Environment.36 . 1675-1689. 

1 
Table 1 . Waterbury, Connecticut; Low-Volume TSP Lead Monitoring Data for 2002 

Date 

Monthly 

Lead-TSP Concentration (pg/m3) 

3 Month Running Average 

Lead-TSP Concentration 

( 

Jan-02 0.016 0.012 

Feb-02 0.018 0.014 

Mar-02 0.006 0.013 

Apr-02 0.006 0.010 

May-02 0 0.004 

Jun-02 0.015 0.007 

Jul-02 0.005 0.007 

Aug-02 0.006 0 .009 

Sep-02 0.01 0.007 

Oct-02 0.0058 0.007 

Nov-02 0 0.005 

Dec-02 0.0029 0.003 

Annual Average: ~ 0. 008 

Figure 1 . Monthly Ambient Lead Estimates from Connecticut's IMPROVE (Cornwall, CT) 

and STN (New Haven, CT) Ambient Monitoring Sites 

0,160 

0.140 

0 .120 

0 .100 

aa 

0,080 

m 

e 

c 0 .060 0 

u 

0,040 

0.020 

0.000 

Estimated P:1Ilo Lead Concentrations For Conneticut's Two PN1,.5 

Speciated Sites 

2008 NAAQS Level 

--+-Corti,,vall NTohawk I 

I Niountain 

--~'-'Nevv Haven 

Criscuolo Park 

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7 

Z 
Sources 

Facility Name" Town Data Source ~ Best Estimate (TPY) 

Danbury Municipal Airport Danbury 2005 CT Airport Survey Estimate 0.270 

Hartford"Brainard Airport Hartford 2005 CT Airport Survey Estimate 0.265 

Robertson Field Plainville 2005 CT Airport Survey Estimate 0 .193 

Igor I. Sikorsky Memorial Airport Bridgeport 2005 CT Airport Survey Estimate 0.193 

C&M Corp Wauregan TRI 2007 0.180 

Tweed-New Haven Airport New Haven 2005 CT Airport Survey Estimate 0.178 

Cttoton "New London Airport (3roton 2005 CT Airport Survey Estimate 0 .171 

Ellington Airport Ellington 2005 CT Airport Survey Estimate 0 .114 

Skylark's Air Park East Windsor 2005 CT Airport Survey Estimate 0.110 

Waterbury" Oxford Airport Waterbury 2005 CT Airport Survey Estimate 0 .089 

Bradley International Airport Windsor CT Airport Survey Estimate 0.082 

Covanta MID CT RRF/CRRA Hartford May 7 2008 Stack Test 0.055 

Danielson Airport Danielson 2005 CT Airport Survey Estimate 0.054 

Meriden-Markham Municipal Airport Meriden 2005 CT Airport Survey Estimate 0 .054 

Oriswold Airport Essex 2005 CT Airport Survey Estimate 0 .042 

Wheelabrator Bridgeport Bridgeport June 24 2008 Stack Test 0 .040 

MIISTPEQ/Specialty Minerals North Canaan TRI 2007 0 .036 

Simsbury Tri-Town Airport Sirnsbury 2005 Cl' Airport Survey Estimate 0.036 

Amerbelle Textiles Vernon Annual Emissions Estimate (LPE(t) 

2005 0 .034 

Windham Airport Windham 2005 CT Airport Survey Estimate 0 .033 

AES Thames LLC Uncasville Emissions Statement 2007 0.031 

Waterbury-Plymouth Airport WaterburY 2005 CT Airport Survey Estimate 0.020 

Chester Airport Chester 2005 CT Airport Survey Estimate 0 .017 

PSECt PWR CT LLC / BPT Harbor Station Bridgeport March 17 2009 Stack Test 0 .017 

North Canaan Airport North Canaan 2005 CT Airport Survey Estimate 0.011 

Toney S Crane Plantsville TRI2007 0.003 

MCP Metal Specialties FairFeld TRI2007 0.003 

H.B Ives New Haven TRI 2007 0.002 

Sargent Manufacturing New Haven TRI2007 0.001 

MDC Hartford Hartford October 29 2008, Stack Test 0 .001 

Borough of Naugatuck Naugatuck July 312002, Stack Test negligible 

Ameteck Wallingford Emissions Statement 2008 negligible 

RarlctffWire Bristol Lead use negligible negligible 

Turner & Seymour Torrlngton No lead use reported negligible 

Peter Paid etectronfss New Britain TRI2007corrected negligible 

H Krevlt& Caryaanlp New Haven No lead use reported negligible 

Table 2. Ranking of Connecticut's Largest Lead 
N 

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C 

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N aa ~ 

o 

O Cl 

N (O 

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p W W 

pJ C C N 

OP O O f0 (U I 

N (!7 

-~ N N A E 'E ~ ` www 

O 

_N 

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V Al C 

N N Ql 

C N Vi N 

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N N O 

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