Attachment 2 

Final Text of Revision 

State Implementation Plan Revision 

8-Hour Ozone Reasonably Available Control Technology State 

Implementation Plan Analysis for the State of Connecticut 

FINAL 

November 3, 2006 
8-Hour Ozone Reasonably Available Control Technology State Implementation 

Plan Analysis for the State of Connecticut 

FINAL 

Connecticut Department of Environmental Protection 

Bureau of Air Management 

November 3, 2006 
Table of Contents 

Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 

RACT Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2 

Regional and State Efforts to Limit Ozone Precursor Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 

A. Regional Efforts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 

B. State Efforts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5 

Connecticut's RACT Analysis for CTG and Major Non-CTG Sources . . . . . . . . . . . . . . . . . . . . . . 6 

A. CTG Category Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7 

B. Major Non-CTG Sources of NOx and VOC. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 

Conclusion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12 

References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22 

Tables and Figures 

Table 1 . OTC Recommended Control Strategies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 

Table 2. Connecticut's Ozone Precursor Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 

Table 3 . CTG Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14 

Table 4. Major Non-CTG Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19 

Figure 1 . Connecticut VOC Emission Trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 

Figure 2. Connecticut NOx Emission Trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 

Figure 3 . Connecticut Ozone Exceedance Day Trends with Control Strategies . . . . . . . . . . . . . 13 
SUMMARY 

In satisfaction of the reasonably available control technology (RACT) requirements of Sections 

172(c)(1) and 182 of the Clean Air Act (CAA) for the 8-hour ozone national ambient air quality 

standard (NAAQS), the Connecticut Department of Environmental Protection (CTDEP) has 

reviewed, and here documents, specific control measures, including those already in place under the 

1-hour ozone NAAQS, required of the major nitrogen oxides (NOx) and volatile organic compound 

(VOC) emitting sources and of all sources and source categories addressed in control techniques 

guidelines (CTGs). As a result of a long and successful history of implementing aggressive local and 

regional controls to reduce emissions of NOx and VOCs, CTDEP now applies levels of control that 

meet or exceed RACT to a broad range of source categories including those for which RACT is not 

federally required . Thus, CTDEP concludes that controls on all relevant stationary sources of NOx 

and VOC emissions meet or exceed CAA RACT requirements . 
1. RACT OVERVIEW 

On June 15, 2004, Connecticut's designation as non-attainment for the 8-hour ozone NAAQS became 

effective. This designation resulted from a change in the standard from 0.12 ppm averaged over one 

hour to 0.08 ppm averaged over eight hours . The entire state was classified as moderate nonattainment . Under the 1-hour ozone NAAQS, the southwest portion of Connecticut was classified 

severe non-attainment while the rest of the State was classified serious non-attainment . These prior 

classifications, established under the 1-hour NAAQS, carried with them more stringent requirements 

for reducing emissions of ozone precursors under the CAA than does the current moderate 

classification . 

The Environmental Protection Agency (EPA) revoked the 1-hour ozone NAAQS effective June 15, 

2005, prior to Connecticut's projected 1-hour ozone attainment date of June 2007. Having been 

designated non-attainment for the 8-hour ozone NAAQS, Connecticut is required to transition its 

planning efforts to attainment of the 8-hour ozone NAAQS by June 2010. The transition is being 

conducted in accordance with guidance set forth by EPA in the "Final Rule To Implement the 8-Hour 

Ozone National Ambient Air Quality Standard" [the implementation Rule : 70 FR 716121 published on 

November 29, 2005 . 

The Implementation Rule requires a state to apply all reasonably available control measures 

(RACM) that will assist the state in timely attainment of the ozone standard. RACM are those 

readily implemented measures that are economically and technologically feasible and that contribute 

to the advancement of attainment . Determining RACM requires an area-specific analysis. The State 

is required to consider RACM for any source of VOCs or NOx that occur in the state. The plan to 

implement these RACM is due June 15, 2007, together with the demonstration of attainment . 

A subset of RACM are the reasonably available control technology (RACT) requirements . EPA has 

defined RACT as the lowest emission limitation that a particular source is capable of meeting by the 

application of control technology that is reasonably available considering technological and economic 

feasibility [44 FR 53762; September 17, 19791. Unlike RACM, RACT is limited to sources for which EPA 

has developed Control Technique Guidelines (CTGs) and the major non-CTG sources . As the 

analytical work for implementing the CTGs is readily available, and because the RACT sources are a 

priori a significant focus for implementing control strategies, EPA expects requirements limiting 

emissions from RACT sources to be addressed more immediately than the other control options . 

Under the CAA, Connecticut is to submit a state implementation plan (SIP) demonstrating that 

RACT levels of control are required of all CTG sources and major non-CTG sources of NOx and 

VOC. This RACT SIP is due to EPA on September 15, 2006. The state is to require sources to 

implement RACT no later than May 1, 2009. 

-2- 
II. REGIONAL AND STATE EFFORTS TO LIMIT OZONE PRECURSOR EMISSIONS 

This document includes in section III a detailed description and analysis of Connecticut's RACT 

controls for CTG sources and major non-CTG sources of NOx and VOC. To put that analysis in 

perspective, we first describe in this section, the regional and state efforts that have established 

RACT and beyond RACT levels of control for Connecticut sources. 

A. REGIONAL EFFORTS 

The 1990 CAA amendments recognized the significant role of interstate transport of NOx and VOCs 

in influencing the ability of a downwind state to attain the ozone NAAQS. As part of that 

recognition, the United States Congress established the Ozone Transport Commission (OTC) to help 

coordinate control plans for reducing ground-level ozone in the Northeast and Mid-Atlantic states . 

As a member of the OTC, Connecticut has worked jointly with the other eleven member states and 

the District of Columbia to assess the nature and magnitude of the ozone problem in the region, 

evaluate potential new control approaches and recommend regional control measures to ensure 

attainment and maintenance of the ozone NAAQS. This regional approach recognizes that all states 

benefit from coordinated attainment planning efforts to reduce ozone precursors . 

Connecticut has, in part, relied on this regional effort to determine if the current RACT controls 

implemented to meet our 1-hour ozone NAAQS obligations continue to represent RACT for the 8-

hour NAAQS. The regional effort encompassed the goal of attainment with the 8-hour NAAQS 

together with compliance with the Clean Air Interstate Rule (CAIR), the fine particulate (PM2.5) 

NAAQS, and the federal regional haze requirements . The regional process therefore considered a 

broader category of sources than the RACT sources (major and CTG) and anticipated controls more 

stringent than RACT. 

The OTC staff and member states formed several workgroups to identify and evaluate candidate 

control measures . Initially, the workgroups compiled and reviewed a list of over 1,000 candidate 

control measures . These control measures were identified through published sources such as EPA's 

Control Technique Guidelines, STAPPA/ALAPCO "Menu of Options" documents, the 

AirControlNET database, emission control initiatives in other states including California, 

state/regional consultations, and stakeholder input. The workgroups developed a preliminary list of 

approximately fifty candidate control measures to be considered for more detailed analysis with 

respect to the potential for emissions reductions, cost effectiveness, and ease of implementation 

[MACTEC, 2006] . Thus, these measures were anticipated to be most effective in reducing ozone air 

quality levels in the Northeastern and Mid-Atlantic States . 

Based on the analyses presented by the OTC workgroups, the OTC Commissioners made several 

recommendations at the June 2006 Commissioner's meeting in Boston [OTC 2006a, OTC 2006b, OTC 

20o6c and OTC 20o6d] . The Commissioners recommended that States pursue emission reductions from 

the following source categories: 
Table 1. Control measures recommended by the OTC to pursue as regional ozone attainment measures and the 

status of Connecticut's efforts toward measure im lementation. 

VOC Control Measures Connecticut Status of Control Measure Implementation in 

regulation (if Connecticut 

applicable) 

Reformulation of Consumer New R.C .S .A. The Connecticut regulation adoption process is now 

Products section 22a-174-40 underway. A public hearing was held on a proposed new 

state re gulation on June 27, 2006. 

Design Improvements to Amendment of The Connecticut regulation amendment process is now 

Portable Fuel Containers R.C .S .A. section underway. A public hearing was held on a proposed 

22a-174-43 amendment to an existing re gulation on June 27, 2006. 

Restrictions on Asphalt used Amendment of Amendment of existing Connecticut regulation now under 

for Paving Operations R.C .S .A. section development. 

22a-174-20(k) 

Restrictions on the New R.C .S .A . New Connecticut regulation now under development. 

Manufacture and Use of section 22a-174-44 

Adhesives and Sealants 

Regional Fuel (Reformulated Not applicable Federal Phase 11 RFG in place statewide since 2000 . 

Gasoline) 

NOx Control Measures 

Reductions in the Sulfur Connecticut Public Reduction in heating oil fuel sulfur content will occur when 

Content of Heating Oil to Act 06-143 such reductions are effective in surrounding states . 

Improve Combustion and 

Reduce NOx Emissions 

Emissions Limitations and Amendment of The Connecticut regulation amendment process is now 

Operation Practices for R.C .S .A. section underway. A public hearing was held on a proposed 

Industrial Commercial and 22a-174-22 amendment to the existing regulation on October 19, 2006. 

Institutional Boilers 

Standards for Cement Kilns Not applicable No applicable sources in Connecticut. 

Standards for Glass Furnaces Not applicable No applicable sources in Connecticut. 

Standards for Asphalt Plants TBD OTC outline of requirements under development. 

Standards for Electric TBD OTC Model Rule development continuing. 

Generating Units 

Diesel Truck Chip Reflash TBD Regional approach under development. 

Standards for Refineries Not applicable No applicable sources in Connecticut. 

Standards for Municipal R.C .S .A. section Existing rule consistent with OTC recommendation and 

Waste Combustion 22a-174-38 2006 federal MACT revision [7t FR 27324, May lo, 20061 with 

respect to NOx. 

NOTE : A link to CTDEP's proposed regulations can be found at : http ://www.dep~state .ct.us/air2/regs/index .htm 

under the heading of "Proposed State Regulations" . The complete final regulations for the abatement of air pollution can 

be found at : htt ://www.de .state . ct .us/air2/re s/mainre s.htm . 

Details of the OTC regional model rules and control measures identified in Table 1 can be found at 

the OTC website: http://www.otcair.or~. 

Though the goal of the OTC process was to find control measures that the states could readily 

implement and would result in the greatest regional gains, the OTC process encompassed sources and 

measures that went beyond RACT. Therefore, not all of the selected measures are RACT eligible, 

either because they are not directed at major stationary sources, or at the CTG sources. Thus, for 

example, diesel chip reflash, the reprogramming of the pollution control module on diesel truck 

engines, is not RACT eligible because it is directed at a mobile source category which is not a CTG 

category. 

-4- 
Connecticut has already adopted, or is in the process of adopting some of these control measures as 

part of its 8-hour ozone attainment plan . Those measures for which rule adoption is now proceeding 

are identified in Table l . Table 1 also indicates those control measures with no applicability to 

Connecticut or for which development at the regional level continues. 

B. STATE EFFORTS 

Connecticut has a long history of implementing local and regional control measures to reduce NOx 

and VOC emissions to meet our 1-hour ozone attainment obligations. Under the 1-hour ozone 

NAAQS, Connecticut was divided into two non-attainment areas classified as "serious" and "severe". 

These classifications carried more stringent requirements than the 8-hour ozone NAAQS "moderate" 

non-attainment classification, which applies statewide. Among the more stringent requirements are 

the lower major source thresholds. Under the 1-hour ozone NAAQS, the major source thresholds for 

NOx and VOC were set at 25 tons per year (tpy) in the severe area and at 50 tpy in the serious area. 

Under anti-backsliding provisions, Connecticut is committed to retain these more stringent major 

source thresholds in implementing its current programs . However, for the purpose of this document 

and demonstrating that RACT is satisfied, we address only those major sources as required under the 

8-hour "moderate" classification and associated thresholds, namely 50 tpy VOC and 100 tpy NOx. 

Evaluation of efforts implemented to reduce ozone precursor emissions and their success in meeting 

that goal is an ordinary and necessary component of the attainment planning cycle. As part of that 

cycle, for the 1-hour ozone NAAQS, CTDEP prepared a Mid-Course Review to document 

Connecticut's success in reducing ambient ozone levels . Figures 1 and 2 from that Mid-Course 

Review show the dramatic reductions in VOC and NOx emissions obtained and projected from 1990 

through 2007 by control measures already in place. 

Projected Antfiropogenic VOC Emission 

Trends for Connecticut 

- Figure 2. I 

Projected NOx Emission Trends for Connecticut 

®POint "Area ONan road Odn-ro:d~ 

1990 2o©z 

Nox Nox 

L®PaiN "Araa ONonromd Ootntoed 7 

.-.-.-. . ---J 

From "Mid-Course Review", CTDEP, January 10, 2005 . 
Despite Connecticut's noteworthy success in reducing emissions of ozone precursors, it important to 

recognize the limits of obtaining additional emissions reductions from these sources to reduce 

ambient ozone levels . A comparison of contributions from all sources in the Connecticut inventory is 

instructive . Table 2 shows the total VOC and NOx emissions from the thirteen major categories of 

emissions (Tier 1 Source Categories). These categories include all anthropogenic sources included in 

the 2002 National Emissions Inventory (NEI) . Note that biogenic sources in Connecticut are 

estimated to emit an additional 55,980 tons of VOC annually . Thus 264,729 tons of VOC were 

emitted statewide in 2002. 

Table 2. Connecticut State Emissions Summary 

by Tier 1 Source Category (NEI 2002) . 

2002 Annual NEI Emissions 

Tier category 

01 Fuel Comb. Elec . Utility 

02 Fuel Comb . Industrial 

03 Fuel Comb . Other 

04 Chemical & Allied Product Mfg 

05 Metals Processing 

06 Petroleum & Related Industries 

07 Other Industrial Processes 

08 Solvent Utilization 

09 Storage & Transport 

10 Waste Disposal & Recycling 

11 Highway Vehicles 

12 Off-Highway 

14 Miscellaneous 

TOTALS : 

VOC 

253 

167 

82,774 

3,576 

0 

0 

1,328 

53,259 

5,433 

2,203 

30,911 

28,534 

309 

208,749 

(TPY1 

NOx 

Connecticut's major stationary 

sources of NOx emitted less than 

12,000 tons according to the 2002 

state inventory. These stationary 

sources account for approximately 

ten percent of the NOx emissions 

inventory. Connecticut's major 

stationary sources of VOC emitted 

approximately 1500 tons according 

to the 2002 inventory. This 

amounts to approximately one 

percent of the statewide total annual 

VOC emissions. Thus, 

opportunities for Connecticut to 

reduce ambient ozone levels 

through control of its major 

stationary sources are severely 

limited. The importance of mobile 

and area source emissions, and, in 

particular, emissions transported 

from other states cannot be 

6,225 

2,786 

13,543 

1 

28 

0 

0 

26 

3 

3,973 

64,028 

23,173 

11 

113,796 

From: 

http ://www.emissionsonline .ora/nei2002/state/ct/stcttl .htm 

accessed on June 28, 2006 . 

Note : According to the Connecticut 

additional 55,980 tons per year of 

biogenic sources . 

overstated. 

2002 inventory an 

VOC are emitted from 

Significant reductions from sources in 

to attain and maintain the ozone NAAQS. 

upwind states are crucial to Connecticut's ability 

III. CONNECTICUT'S RACT ANALYSIS FOR CTG AND MAJOR NON-CTG SOURCES 

Section 182 of the CAA sets forth two separate RACT requirements for ozone non-attainment areas. 

The first requirement, the RACT "fix-up", calls for the state to correct RACT rules for which EPA 

identified deficiencies before the CAA was amended in 1990 . Connecticut has no such deficiencies 

to correct. The second requirement calls for the state to implement RACT controls on all major VOC 

and NOx emission sources and on all sources and source categories covered by an EPA published 

CTG, the presumptive norm establishing RACT for the covered sources . EPA has also documented 

alternative control techniques (ACTs) to serve as guidance for controls of VOC and NOx emissions 

from stationary sources. The ACTs describe control techniques and their cost effectiveness, but 

unlike the CTGs, they do not define RACT. A complete list of the CTGs and ACTs can be found at 

EPA's website: http ://www .epa .gov/ttn/naags/ozone/ctg act/index.htm 

-6- 
Connecticut and other states previously designated non-attainment under the 1-hour ozone NAAQS, 

already have rules in place to reduce emissions of VOC and NOx for attainment purposes. 

Recognizing that additional controls may only achieve small incremental emission reductions that are 

not cost effective, the Implementation Rule allows states to review and certify that RACT controls 

implemented under the 1-hour ozone NAAQS continue to represent RACT under the 8- hour 

NAAQS. Such a review and certification follows. In addition, in anticipation of the submission of 

Connecticut's 8-hour ozone NAAQS attainment demonstration in June 2007, an overview of some of 

the measures Connecticut has developed, or is considering, to satisfy the CAA's RACM requirement 

for the 8-hour ozone NAAQS is also provided. 

A. CTG Category Sources 

For sources for which a CTG has been published, RACT is considered met if a state imposes controls 

equivalent to the CTG for that source or source category . Table 3 (attached) lists the current CTG 

documents and identifies the corresponding regulations that Connecticut has adopted to achieve 

emissions reductions equivalent to the CTGs. Table 3 also includes the effective dates of the state 

regulations and the date of SIP approval. As explained further below, Connecticut reasserts that these 

regulations are consistent with the CTGs, or where appropriate, recertifies that the source category 

does not exist within the state. 

CTDEP has addressed the majority of the CTG source categories and requirements through three 

sections of the Regulations of Connecticut State Agencies (R.C.S .A.) : 22a-174-20 (Section 20); 22a174-30 (Section 30) and 22a-174-32 (Section 32). Section 20, for the control of organic compound 

emissions, was first promulgated in the early 1970's and has undergone numerous revisions since . 

Section 20 generally contains the requirements for the source categories covered by the CTGs 

established prior to 1990. After the Clean Air Act Amendments of 1990, EPA promulgated 

additional CTGs and Connecticut updated its VOC RACT rules with the implementation of RCSA 

§22a-174-32 (Section 32). Section 32, entitled "Reasonably Available Control Technology for 

Volatile Organic Compounds", includes control measures for additional CTG categories and for 

major sources of VOC. Section 32 was first promulgated in 1993 and was revised again in 1999. 

The CTG category for Stage I Vapor Recovery, as well as for Stage II, is implemented through 

RCSA §22a-174-30 (Section 30) . Section 30 is entitled "Dispensing of Gasoline/Stage I and Stage II 

Vapor Recovery" and was implemented in late 1992 and revised in 2004. 

Connecticut regulations for the CTG sources are consistent with the CTG documents and therefore 

meet the RACT requirements . However, individually and through its proceedings with the OTC, 

Connecticut has concluded that two of these categories are appropriate to update . A discussion of 

these two categories follows. 

Cutback Asphalt Paving. The 1977 CTG recommended substitution of cutback asphalt, which was 

expected to contain between 20 and 50 percent VOC, with emulsified asphalts (i .e . asphalt which is 

liquefied by being held in a low VOC suspension) . Emulsified asphalts were just gaining in 

acceptability in Connecticut when the asphalt paving CTG was established in 1977 . In Connecticut's 

original SIP submittal for this CTG, it was anticipated that water-based emulsions would largely 

replace cutback asphalt by 1987 [CTDEP, 1979]. That prediction has proved true ; the asphalt industry 

now widely accepts and uses emulsified asphalt. These emulsified asphalts can entirely replace 

cutback asphalt during the ozone season and are available with zero VOC content. Therefore, 

-7- 
Connecticut plans to pursue adoption of an amendment to the current Connecticut regulation for 

asphalt paving, R.C .S .A. section 22a-174-20(k) (see Table 1) . The existing rule, based on the 1977 

CTG, allows restricted use of cutback asphalt during the ozone season to that which emits, under test 

conditions, less than five percent of the total solvent contained in the asphalt. The existing rule also 

provides exemptions for specific uses such as penetrating prime coats and long-term storage. 

Removing these exemptions and providing more stringent VOC content limits for cutback and 

emulsified asphalt will not require equipment retrofits, as other CTG source category rule updates 

might. Connecticut projects that the estimated emissions of 234 tons per year from emulsified 

asphalt and 177 tons per year from cutback in its 2002 inventory will be significantly reduced by 

updating this rule . 

Solvent Cleaning (Metal Degreasing). This CTG was originally applicable to units which 

clean/degrease metal in cold cleaners, open top vapor degreasers and conveyorized degreasers . To 

address the varied designs of degreasing units, the CTG requirements are based on operating 

practices rather than establishment of an emission limit. 

In 2001, solvent cleaning was identified by the OTC as a control measure for which many states in 

the region could achieve further VOC emission reductions by implementing measures which went 

beyond the original CTG requirements . A model rule was developed that includes hardware and 

operating requirements and alternative compliance options for vapor cleaning machines used to clean 

metal parts. These requirements are based on the Federal maximum achievable control technology 

(MACT) standard for chlorinated solvent vapor degreasers . The requirements of the OTC Model 

Rule for Solvent Cleaning, available at : http ://www .otcair.org/interest.asp?Fview=stationary# , exceed 

the CTG by establishing a limitation on the vapor pressure of solvents used in cold cleaning and 

additional operating practices to further limit VOC emissions from metal cleaning . 

Connecticut is now in the process of pursuing the adoption of an amendment to R.C .S .A. section 22a174-20(l) that includes the vapor pressure limitation for solvents used in cold cleaning plus additional 

operating requirements recommended by the OTC Model Rule. A copy of that amendment as 

proposed is available at http ://www .dep.state .ct.us/air2/regs/index .htm under the heading of 

"Proposed State Regulations". The complete final regulations for the abatement of air pollution can 

be found at : http://www.dep .state .ct.us/air2/regs/mainre s .g htm. Upon completion of this rule 

amendment process, the requirements of R.C .S .A. section 22a-174-20(l) will represent at least a 

RACT level of control for this source category. 

New CTG Requirements. EPA is currently in the process of adopting new CTG requirements . On 

August 4, 2006, EPA published proposed CTGs for the following source categories: Lithographic 

Printing Materials, Letterpress Printing Materials, Flexible Packaging Printing Materials, Flat Wood 

Paneling Coatings, and Industrial Cleaning Solvents. These were made final by publication in the 

federal register on October 5, 2006 [71 Flt 58745] . SIP revisions for these CTGs are due by October 4, 

2007 . EPA expects to propose several more CTG categories in the near future . As appropriate, 

Connecticut will analyze the need to adopt requirements to address these CTGs for sources in the 

state and pursue adoption of such requirements in subsequent SIP submittals. 

Negative Declarations. Connecticut reviewed its inventory of sources and interviewed its field staff 

to determine if any CTG sources, which were previously determined not to be located in the state, 

have since located in the state. Searches of telephone directories and Internet web pages (including 

other state government databases) were used to supplement this determination. All known operating 

-8- 
stationary sources for which a CTG has been issued are subject to an appropriate form of regulation . 

Therefore, Connecticut reaffirms its negative declarations for the categories so designated in Table 3 . 

B. Major Non-CTG Sources of NOx and VOC 

According to the Implementation Rule, the State is required to conduct a RACT analysis for each 

major stationary source of VOC and for each major stationary source of NOx. Major stationary 

source is as defined in section 302 of the Clean Air Act, as modified by sections 182(b), (c), (d) or (e) 

of the CAA, as applicable to the classification of the attainment areas in which a stationary source is 

located. Additionally, Connecticut is in an Ozone Transport Region and subject to CAA section 184. 

Therefore, the term "major source" for the purposes of this review is limited to facilities that have the 

potential to emit 100 tons per year or more of NOx or 50 tons per year or more of VOC. 

The guidance in the Implementation Rule gives states the discretion either to conduct individual 

source-specific RACT determinations or to perform RACT determinations or certifications 

collectively for groups of sources. Therefore, emissions averaging or controls applied throughout a 

group of sources can be used to show that the source group meets RACT. 

In addition to RACT, individual sources may also be subject to more stringent technology control 

measures such as LAER, BACT and MACT . LAER, applicable to new and modified major sources 

located in non-attainment areas, is the lowest achievable emission rate of the non-attainment pollutant 

that can be achieved by the source without respect to cost. BACT, or best available control 

technology, is applicable to new and modified sources located in attainment areas. BACT may be 

less stringent than LAER because consideration is given to energy, environmental and economic 

impacts, as well as other costs when evaluating the lowest emission rate . MACT, or maximum 

achievable control technology, is generally applicable to major sources of hazardous air pollutants . 

MACT is the control achieved by the best performing twelve percent of sources in a source group. 

For sources emitting volatile organic hazardous air pollutants subject to MACT, the control device 

employed by the MACT rule is equally effective in controlling VOC emissions . 

Each of these control requirements, LAER, BACT and MACT, at the time of review, would 

necessarily be more stringent than RACT. These control requirements would also be applied at 

thresholds, at least in Connecticut, lower than the major source threshold required for this RACT 

analysis . As these controls are generally more stringent, it is unlikely that any source that has 

recently undergone one of these control technology reviews would not meet RACT. Furthermore; to 

the extent that a source had already undergone one of these reviews, it is generally unlikely that the 

marginal reductions achievable through further control measures will be cost effective. Only in cases 

where the technology review is significantly outdated and the source has sufficient actual emissions 

and useful life remaining, is it plausible that RACT, the control measure with the least associated 

burden, will be warranted. Note, however, that such a source might still warrant controls as part of 

an attainment plan or through future, necessarily more stringent, BACT, LAER, or MACT 

determinations as may become applicable. 

Table 4 (attached) lists the major sources of NOx and VOC located in Connecticut. In general, all 

major sources of NOx are regulated under Section 22 while stationary sources of VOC are regulated 

by Sections 20 and 32. Section 32 explicitly regulates major sources of VOC for the purpose of 

implementing RACT, and allows the Department to conduct individual RACT analyses for sources . 

-9- 
These regulations apply to major sources as that term was defined for the 1-hour ozone NAAQS nonattainment classifications, namely 25 tons per year in Connecticut's southwestern "severe" section 

and 50 tons per year in the remainder of the state. These thresholds apply to both VOC and NOx 

sources and are more stringent that the respective 50 and 100 tpy thresholds that apply under the 

current classification of moderate 8-hour ozone non-attainment for Connecticut and for the purpose 

of conducting this RACT analysis. Due to EPA's anti-backsliding requirements, and Connecticut's 

desire to come into attainment with the 8-hour ozone NAAQS as expeditiously as practical, the more 

stringent 25 and 50 tpy thresholds will not be relaxed for applicability and other requirements in 

existing rules even though the non-attainment area classification has changed. 

SIP-Approved NOx Trading and CAIR Sources. Connecticut has participated in two distinct NOx 

Budget Programs (NBPs) : the OTC NBP and the Federal NBP. Both programs are market-based 

emission cap-and-trade plans created to reduce emissions of NOx from power plants and other large 

combustion sources in the eastern United States . Connecticut and seven other states in the OTC 

implemented the original OTC NBP from 1999 through 2002 and the Federal NBP beginning in 

2003 ; eleven non-OTC states began compliance with the Federal NBP in 2004. A brief summary of 

the evolution of Connecticut's program is provided in the following paragraphs. 

The Federal NBP originated from EPA's determination in the late 1990s that NOx emissions from 

large stationary sources in twenty-three jurisdictions significantly contribute to non-attainment of the 

1-hour ozone NAAQS in one or more downwind states in the eastern portions of the United States . 

[62 FR 60317: November 7, 1997 ; 63 FR 25902: May 11, 1998; and 63 FR 57356: October 27, 1998] EPA issued the 

NOx SIP Call in 1998, requiring affected states to amend their SIPs and limit NOx emissions during 

each ozone season beginning in 2003. Connecticut and most of the other OTC states implemented 

the Federal NBP on May 1, 2003. 

Connecticut's NOx Budget Program was modified slightly to reflect the Federal NBP requirements . 

The underlying regulation, R.C .S .A. section 22a-174-22b, was approved by EPA as a SIPstrengthening measure on December 27, 2000 [65 FR 81743] . R.C.S.A. section 22a-174-22b 

established a statewide NOx budget and NOx allowance trading program for large electric generators 

and other industrial sources beginning with the 2003 ozone season . The budget cap is consistent with 

EPA's NOx SIP Call and the September 1994 OTC Memorandum of Understanding establishing the 

OTC NOx Budget Program. In Connecticut, the OTC program was conducted pursuant to R.C .S .A. 

section 22a-174-22a. As a result of the OTC NBP, the Acid Rain program and other CAA 

requirements, by 2000 the OTC states had already reduced NOx emissions by approximately 55% 

from 1990 levels, thereby reducing the level of reductions necessary to meet the Federal NBP targets . 

[EPA, 2004a: the EPA NBP Report] With the further implementation of the Federal NBP in 2003, the 

OTC states' ozone season NOx emissions from subject sources were reduced 30% from 2002 levels 

and were 18% less than the number of NBP allowances allocated in 2003 .[EPA, 2004b] In addition, 

NOx highest daily emissions and average daily emissions in the OTC states have decreased 

approximately 25% and 35%, respectively, from 1997 to 2003.1 

On May 12, 2005, EPA promulgated the Clean Air Interstate Rule (CAIR) . EPA has determined that 

NOx emissions from electric generating units in 25 eastern states and the District of Columbia 

contribute to unhealthy levels of 8-hour ozone in other downwind states . Based on an assessment of 

the emissions contributing to interstate transport of air pollution and available control measures, EPA 

1997 and 1998 data from the Acid Rain Program; 1999-2002 data from the OTC trading program; 2003 data 

from the NBP. 

-10- 
has determined that achieving required reductions in the identified states by controlling emissions 

from power plants is highly cost effective. States must achieve the required emission reductions 

using one of two compliance options: 1) meet the state's emission budget by requiring power plants 

to participate in either an annual or ozone-season EPA-administered interstate cap-and-trade system, 

as applicable, that caps emissions in two stages, or 2) meet an individual state emissions budget 

through measures of the state's choosing . 

Connecticut plans to comply with CAIR by participating in the federal CAIR ozone-season NOx 

trading program. Public hearing was held on October 19, 2006 for CTDEP's current proposed draft 

regulation, R.C.S .A. section 22a-174-22c, to implement that CAIR trading program. When that 

program becomes effective on May 1, 2009, shortly thereafter the current NBP implemented under 

R.C.S .A. section 22a-174-22b will be repealed . All the sources that now participate in the R.C .S .A. 

section 22a-174-22b NBP will be subject to Connecticut's CAIR ozone season NOx trading program. 

EPA believes [7o FR 71652] those CAIR sources and sources subject to the State's emission cap and 

trade program where the program has been adopted by the state and approved by EPA as meeting the 

NOx SIP Call requirements, meet the NOx RACT requirement . Those major sources subject to 

CAIR requirements and the trading program are listed in Table 4. No further RACT analysis is 

required for these sources. 

Municipal Waste Combustors (MWCs) . Connecticut has six facilities that burn municipal waste to 

create electricity . These six facilities account for approximately thirty percent of the actual annual 

NOx emissions from the major NOx emitters in the state and are regulated by RCSA §22a-174-38 

(Section 38). Section 38 became effective on June 28, 1999 and included NOx emission limits that 

were equivalent to the emission limits established in the federal emissions guidelines for MWCs. An 

October 26, 2000 amendment to Section 38 reduced the NOx emission limits beyond the 1999 levels. 

The amended regulation and associated emissions reductions were approved by EPA on December 6, 

2001 [66 FR 63311] . 

EPA recently promulgated amendments to the federal MACT-based emissions [71 FR 27324, May lo, 

2006] . While CTDEP is currently preparing an amendment to Section 38 to make certain necessary 

changes based on the federal requirements, Connecticut's existing requirements with respect to NOx 

and VOC emissions limits are now as stringent as the 2006 revisions to the federal standards . 

Therefore, Connecticut's emissions limits represent RACT for the MWCs . 

State Restrictions on Major NOx Sources. Any facility in Connecticut that has the potential to 

emit at least fifty tons per year of NOx is regulated by RCSA §22a-174-22 (Section 22) . Section 22 

also applies to sources in the southwestern part of the State, the "severe" area, that have the potential 

to emit at least twenty-five tons per year of NOx. Therefore, all major NOx RACT sources (i .e . 

potential emissions of at least 100 tpy) are regulated by this section. Section 22 was approved as part 

of Connecticut's 1-hour ozone attainment demonstration . Consistent with OTC model rule already 

developed, CTDEP has proposed for public hearing on October 19, 2006, an amended Section 22 to 

include more stringent emission and control requirements such that all major NOx sources will meet 

or exceed RACT. Additionally, CTDEP is committed to continue to work with the OTC to further 

develop this model rule and will pursue rulemaking as needed and appropriate. 

VOC Emissions From Fuel Burning Sources. Section 32 excludes fuel burning sources from 

consideration for VOC RACT. Generally, good combustion practices, rather than add-on control 

-11- 
technology, is considered the appropriate control measure for VOC from fuel burning sources. Good 

combustion practices also help reduce other pollutants such as CO and NOx. Connecticut's 

proposed amended NOx control regulations, Section 22, scheduled for public hearing on October 19, 

2006, include tune-up requirements to promote good combustion practices . 

VOC Sources Subject to Maximum Achievable Control Technology (MACT) Standards. 

The MACT standards were developed following the 1990 amendments to the CAA and are generally 

contained in Part 63 of Title 40 of the Code of Federal Regulations. EPA developed the MACT 

standards for categories of sources which emit large amounts of hazardous air pollutants . The 

standards represent the controls achieved by the best performing twelve percent of sources in a source 

category. The sources listed in Table 4 under the MACT category are sources with VOC emissions 

that are subject to the MACTs for gasoline distribution, halogenated solvents, and aerospace. Where 

these standards are designed to control volatile organic hazardous air pollutants, CTDEP considers 

these controls sufficient to satisfy RACT for the sources so designated in Table 4. 

Additional VOC Sources and Sources with VOC RACT Orders. Section 32 requires certain 

major sources of VOC to undergo individual RACT review . In those cases VOC RACT Orders, 

which are federally enforceable, have been issued to the source . These sources are also subject to 

requirements that limit VOC emissions pursuant to various provisions of Section 20. 

Overall the major non-CTG sources of VOC, which account for approximately one percent of the 

entire state inventory, currently meet RACT. Nevertheless, we recognize that certain major non-CTG 

VOC sources which depend on reformulation to limit emissions, rather than application of control 

technology, may yield further reductions as a result of more stringent generic VOC rules. Therefore, 

CTDEP is evaluating the feasibility of rule changes affecting these sources as part of its attainment 

planning efforts. 

IV. CONCLUSION 

Connecticut has implemented all emission control programs mandated by the 1990 CAA, as well as 

other measures necessary to ensure adequate progress toward compliance with the 1-hour ozone 

standard . Additional emissions control measures have also been adopted and submitted to EPA as 

part of our Mid-Course Review [CTDEP, 20051 . These additional control measures were required to 

offset the EPA-identified shortfall in emissions reductions necessary to attain the 1-hour ozone 

standard by November 2007 . In addition to the shortfall measures, other strategies that have been 

adopted but not fully implemented (such as vehicle turnover) will provide substantial further 

emissions reductions and continued improvements in ambient ozone levels through 2007 and beyond. 

Federal, regional and state rules have been generally successful in helping to bring Connecticut closer 

to its original goal of meeting the 1-hour ozone NAAQS by 2007. This is clearly demonstrated in 

Figure 3 . These measures remain in place, and air quality improvements continue to accrue, as 

Connecticut implements additional attainment measures to reach the goal of attainment with the 8-

hour ozone NAAQS. 
Figure 3. Connecticut 1-Hour Ozone Exceedance Day Trend and 

Implemented Control Strategies 1975 - 2006 

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T -----Various VOC RACTmeasures adopted from mid-1970's through mid1990's------- T 

1 Fed Motor Vehicle Stds MYs 1975+ 

Fed Tier l motorvehicles 1994+ " 

Phase I R FG 1995 V 

NOx FACT 1995 1 

Non-road Engine Stds 1996+1 

Fed Consumer Products, NM Autobody Refinishing 1997-1998 " 

Stage I Gasoline Vapors, 1982-83 1 

NOxSIP Call Phase II 2004 " 

Federal Tier 2 motor vehicles 2004+ " 

Heavy Duty Diesel Phase 1 2004+ t 

Motor Vehicle (IM 1983r 

CT NLEV1998 V 

Phase II RFG 2000 " 

NOxSIP Call Phase 1 2002 T 

Municipal Waste Combuster NOx2003 T 

Stage II Vapor Recovery phase-in 1992-1994 " 

YEAR 

Substantial further emissions reductions are projected to occur as the result of currently mandated 

controls as well as recently proposed and promulgated Federal controls and measures being 

developed by the OTC for state implementation . Some of these adopted measures represent RACT . 

Others, due to factors such as cost of implementation, time necessary to implement, or the category of 

sources to which the control measure is applicable, are more representative of RACM. A more 

detailed description of these RACM measures will be included in the State's attainment plan due in 

June of 2007. 

Connecticut's planning and regulatory efforts to reduce NOx and VOC emissions are being 

implemented successfully, resulting in reduced ambient ozone levels throughout the state and 

downwind. These reductions were expected to result in attainment of the 1-hour ozone NAAQS. 

CTDEP continues to take aggressive action to develop local and regional control measures and 

influence national strategies to further reduce ozone levels as necessary to attain the 8-hour ozone 

NAAQS. As a result all Connecticut's CTG sources and major non-CTG sources are controlled by 

RACT or better standards, and Connecticut's RACT requirement has been satisfied for the 8-hour 

ozone NAAQS. 
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Table 4. Listing of the non-CTG major sources of nitrogen oxides (NOx) and/or volatile organic 

compounds (VOC) located in Connecticut. Major sources are those with the potential to emit 100 

tons per year or more of NOx or 50 tons per year or more of VOC. The sources are grouped by 

RACT category . 

Municipal Waste Combustor Sources: 

American Ref Fuel Co . of Southeast Connecticut 

Covanta Bristol, Inc. 

CRRA / Mid-Connecticut 

CRRA/ Wallingford 

Wheelabrator Lisbon Inc . 

Wheelabrator Bridgeport LP 

Clean Air Interstate Rule Sources: 

A E S Thames, LLC 

Algonquin Windsor Locks LLC 

Bridgeport Energy LLC 

Capitol District Energy Center 

Connecticut Jet Power, LLC 

Devon Power, LLC 

Exeter Energy LP 

Lake Road Generating Co, L.P . 

Milford Power Co, LLC 

NRG Middletown Operations, Inc 

NRG Montville Operations, Inc 

NRG Norwalk Harbor Operations 

Pfizer Inc 

Pratt & Whitney Div UTC, East Hartford 

PSEG Fossil LLC/ Power CT LLC 

PSEG Power CT LLC/Bridgeport Harbor Station 

Sprague Paperboard Inc 

Sources Conducting NOx Trading under a SIP-Approved Program (NOx Budget Sources): 

Algonquin Windsor Locks LLC 

Capitol District Energy Center 

Connecticut Jet Power, LLC 

Devon Power, LLC 

Pfizer Inc 

Pratt & Whitney Div UTC, East Hartford 

PSEG Fossil LLC/ Power Ct LLC 

PSEG Power CT LLC/Bridgeport Harbor Station 

Sprague Paperboard Inc 

Algonquin Gas Transmission Co 

-19- 
Cytec Industries Inc / Cyro Industries Inc 

Dominion Nuclear Ct., Inc. 

Hamilton Sundstrand Corp 

Pratt & Whitney Div UTC, Willgoos 

Pratt & Whitney Div UTC, Middletown 

Sikorsky Aircraft 

Stone Container Corp 

U S Naval Submarine Base/Power Plant 

University Of CT / Storrs 

Yale University, School Of Medicine aka Sterling 

Other Major Sources of NOx (RCSA 22a-174-22): 

Allegheny Ludlum Corp 

Connecticut Natural Gas Corp 

Connecticut Valley Hospital 

Electric Boat Corp 

Frito-Lay Inc 

Hartford Steam Company 

Kimberly-Clark Corp 

M D C /Hartford WPCF 

Norwalk Hospital Association 

Pratt & Whitney Div UTC, North Haven 

Simkins Industries Inc 

Somers Thin Strip 

Whyco Finishing Tech ., Inc. 

Yale University /Central Power Plant 

Major Sources of VOC due to Fuel Burning: 

A E S Thames, LLC 

Algonquin Windsor Locks LLC 

Bridgeport Energy LLC 

C R R A / Mid-Connecticut 

Capitol District Energy Center 

Covanta Bristol, Inc 

Devon Power, LLC 

Lake Road Generating Co, L.P. 

NRG Middletown Operations, Inc 

NRG Montville Operations, Inc 

NRG Norwalk Harbor Operations 

Pratt & Whitney Div UTC, Willgoos 

PSEG Fossil LLC/ Power CT LLC 

PSEG Power CT LLC/Bridgeport Harbor Station 

University Of CT / Storrs 

Wheelabrator Bridgeport LP 

Yale University /Central Power Plant 

-20- 
Major Sources of VOC Subject to MACT Standards: 

Gulf Oil L.P. 

Hamilton Sundstrand Corp 

Motiva Enterprises LLC, New Haven 

Motiva Enterprises LLC, Bridgeport 

Pratt & Whitney Div UTC, Middletown 

Vishay Vitramon,Inc 

Whyco Finishing Tech, Inc. 

Additional VOC Sources and Sources Subject to VOC RACT Orders: 

Bic Consumer Products Manufacturing Co. 

Cytec Industries Inc /Cyro Industries Inc 

Electric Boat Corp 

Kimberly-Clark Corp 

M D C /Hartford WPCF 

Pfizer Inc 

Quebecor, Northeast Graphic Inc 

Ross & Roberts Inc 

S artomer Co Inc 

SCA Packaging North America Inc 

Sikorsky Aircraft 

Spongex Corporation 

Stanley Tools Division 

Stone Container Corp 

Wasley Products Inc 
REFERENCES 

CTDEP, 1979. "State Implementation Plan for Air Quality", Connecticut Department of 

Environmental Protection, June 22, 1979. 

CTDEP, 2005. "Mid-Course Review, Progress Towards Attainment of the 1-Hour Ozone Standard 

for the Connecticut Portion of the New York-Northern New Jersey-Long Island Area and the Greater Connecticut 1-Hour Ozone Nonattainment Area", Connecticut Department of 

Environmental Protection, January 10, 2005. 

EPA, 1988 . "Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, 

Clarification to Appendix D of November 24, 1987 Federal Register" (aka "The VOC Blue Book"), Ozone/Carbon Monoxide Program Branch, Air Quality Management Division, 

OAQPS, EPA, May 25, 1988 . 

EPA, 2004a. "NOx Budget Trading Program 2003 Progress and Compliance Report ." (aka "The EPA NBP Report") U.S . Environmental Protection Agency Office of Air and Radiation. 2004. 

Available at : http ://www.epa. .gov/airmarkets/cmpr~t/nox03/noxreport03 pdf. 

EPA, 2004b. "NOx Budget Trading Program -- 2003 Progress and Compliance Report", EPA-430-R- 04-010. 

Harnett, 2006. Memo "RACT Qs & As - Reasonably Available Control Technology (RACT) : Questions and Answers, William T. Harnett, Director, Air Quality Policy Division to USEPA Regional Air Directors, May 18, 2006. 

MACTEC, 2006. "Ozone Transport Commission (OTC) Identification and Evaluation of Candidate Control Measures" Prepared for the OTC -- DRAFT, MACTEC Federal Programs, Inc ., May 30, 2006 . 

OTC, 2006a. "Statement of the Ozone Transport Commission Concerning Multi-Pollutant Emission Control of Electrical Generating Units", OTC, June 7, 2006. Available at : 

http ://www .otcair.org/document asn?fview-Formal%20Actions 

OTC, 2006b. "Resolution 06-02 of the Ozone Transport Commission Concerning Coordination and Implementation of Regional Ozone Control Strategies for Certain Source Categories", OTC, June 7, 2006. Available at : http ://www.otcair.org/document asp?fview-Formal °k~20Actions 

OTC, 2006c. "Resolution 06-03 of the Ozone Transport Commission Concerning Federal Guidance and Rulemaking for Nationally Relevant Ozone Control Measures", OTC, June 7, 2006 . Available at : http ://www.otcair.org/document asp?fview-Formal%20Actions 

OTC, 2006d. "Memorandum of Understanding Among the States of the Ozone Transport 

Commission on a Regional Strategy Concerning the Integrated Control of Ozone Precursors from Various Sources", OTC, June 7, 2006. Available at : 

http ://www.otcair org/document asp?fview-Formal%20Actions