STATEMENT OF REVISION TOTHE CONNECTICUT STATE IMPLEMENTATION PLAN This document has been prepared by the State of Connecticut Department of Environmental Protection (Department) in support of a request to the United States Environmental Protection Agency (EPA) to approve the revision to the Connecticut State Implementation Plan (SIP) described herein. This SIP revision consists of four amendments to the Regulations of Connecticut State Agencies (R.C.S.A.), two new regulations that the Department adopted in 2002, 2003 and 2004 and associated administrative materials necessary for EPAto approve this SIP revision. The amendments and new regulations achieve the purposes and concern the sources as described below . Non-Ozone Specific Regulatory Amendments Submitted as Revisions to the SIP " Amendment of R

.C.S .A . Section 22a-174-4, Source Monitoring, Record Keeping and Reportin,g The amendment to R

.C.S.A. section 22a-174-4 focuses the section on the Department's requirements for operation of continuous emissions monitoring equipment by removing general monitoring equipment operating requirements and incorporating theminto R .C .S.A. section 22a174-7 (see explanation below) . The amendment updates the continuous emissions monitoring equipment requirements to current federal requirements; incorporates relevant portions of the Department's Continuous Emission Monitoring Guideline; clarifies language; and makes revisions for consistency with current practices. " Amendment of R

.C.S .A . Section 22a-174-7, Air Pollution Control Equipment and Monitoring Equipment Operation The amendment to R

.C.S .A. section 22a-174-7 clarifies notification, reporting and compliance requirements for operation of air pollution control equipment and monitoring equipment in conjunction with the amendment of R .C.S .A. section 22a-174-4 ; removes requirements redundant to requirements in R .C.S.A. sections 22a-174-12 and 22a-174-38; and revises language for consistency with current practices. " Amendment of R

.C.S .A. Section 22a-174-18 Control of Particulate Matter and Visible Emissions The amendment to R

.C.S.A section 22a-174-18 updates and clarifies the opacity and visible emissions standards for stationary sources. Specific revisions include: 1) specifying the form and averaging time ofthe existing opacity standards for stationary sources; 2) adding particulate matter standards appropriate to fuel-burning equipment using certain fossil fuels; 3) adding particulate matter emissions standards and requirements for stationary reciprocating internal combustion engines; 4) adding exemptions fromthe visible emissions standards for certain sources during certain periods of operation; 5) adding an exemption fromthe section for municipal waste combustors to recognize the promulgation of R .C.S .A . section 22a-174-38, which includes opacity and particulate matter standards for these sources; and 6) conforming the overall format and language to current practices. Additional Control Measures in Support of 1-Hour Ozone Standard Attainment New R .C.S.A. section 22a-174-3b, the amendment of R .C .S .A . section 22a-174-30 andnew R .C.S.A. Section 22a-174-43 were adopted to satisfy in part the Department's commitment toTable 1 . Estimated emission reduction benefits fromConnecticut's EPA-identified emission reduction shortfall measures .

The first value listed for each level of rule effectiveness assumes no compliant PFCare sold during the allowed 1-year pass-through period (through April 30, 2005) . The second value listed for each level of rule effectiveness assumes all PFCs sold during the pass-through period comply with the new regulation. Actual reductions are likely to be somewhere in between those two extremes. VOCreductions fromPFCs will continue to increase throughout the assumed 10-year product turnover period, with a total reduction of about 13 tons/summer day at full turnover (by 2015) .adopt additional control measures that EPA determined were necessary to attain the one-hour

ozone standard by November 2007. See 66 FR 69321 (December 11, 2001) . In the Update to the Ozone Attainment Demonstration for the Southwest Connecticut Severe Ozone Nonattainment Area dated October 15, 2001, the Department indicated that it would address a portion ofthe EPA-identified emissions reduction shortfall by pursuing the adoption of two control measures based on model rules developed by the Ozone Transport Commission, including: (1) additional restrictions on volatile organic compound (VOC) emissions from automotive equipment refinishing and repair operations and (2) requirements to reduce VOC emissions fromcertain consumer products. Furthermore, the Department reserved the option to pursue other measures producing equivalent emission reductions. Based on experience in other states and on-going evaluation ofthe options available to Connecticut, the Department chose not to pursue emissions restrictions for consumer products and instead chose to adopt enhanced Stage I and Stage II vapor recovery as an amendment to R .C.S .A . section 22a-174-30 and portable fuel container requirements as new R .C.S.A. section 22a-174-43. The automotive equipment VOC emissions restrictions were pursued and adopted in the formof new R .C.S.A. section 22a-174-3b . " New

R .C.S .A . Section 22a-174-3b, Exemptions fromPermitting for Construction and Operation ofAutomotive Refinishing Operations New R .C.S .A. section 22a-174-3b establishes emissions limitations, operating practices and record keeping requirements for automotive refinishing operations as well as other source categories to restrict emissions to levels that are not significant contributions to air pollution; and exempts such sources fromthe permitting process by removing compliant owners and operators fromthe duty to apply for and obtain individual operating permits. R .C.S .A . section 22a-174-3b is submitted only to obtain credit for the emissions reductions associated with the requirements for automotive refinishing operations in subsection (d) . Provisions for sources other than automotive refinishing operations are not proposed for inclusion in the SIP and are stricken from the text ofthe regulation in Attachment C . Following the adoption of R .C.S.A. section 22a-174- 3b, the Department sent a letter to every known owner or operator of an automotive refinishing operation in the state indicating the need to either comply with the new section or obtain an individual permit under R .C.S .A. section 22a-174-3a. A copy of that letter and a list of the recipients are included in Attachment C . " Amendment of R

.C .S.A. Section 22a-174-30, Dispensing of Gasoline/Stage I and Stage II Vapor Recovery The amendment to R

.C.S .A . section 22a-174-30 reduces emissions of VOCs by requiring the use of "pressure-vacuum

vent caps" on gasoline pumps that are subject to the Stage II vapor control regulation. The amendment also requires the use of a two-point closed system for the transfer of gasoline from

a gasoline tanker truck to an underground storage tank; improves Stage II system maintenance; clarifies testing requirements and increases testing frequency. " New

R .C.S .A . Section 22a-174-43, Portable Fuel Container Spillage Control New R .C.S.A. section 22a-174-43 reduces emissions of VOCs by requiring the sale of portable fuel containers designed to minimize spillage and fugitive evaporative emissions.Response to EPA Comments

In comments submitted during the public comment period on the amendment of R .C.S .A . section 22a-174-30 and new

R .C.S.A. section 22a-174-43, EPA indicated that the Department should state the expected emission reductions fromeach measure being used to meet the EPA-identified shortfall and any assumptions that were made in calculating these reductions . Thus, this submission includes in Attachments C-4, D-4 and D-5 calculations ofthe emissions reductions associated with the additional control measures. The contributions ofthese and previously adopted and submitted measures to attaining the federal 1-hour ozone standard are summarized in Table 1 and will be highlighted in the Department's mid-course review report, which is scheduled to be submitted to your agency by the end of this year . See 66 FR 69321 (December 11, 2001) . As indicated in Table 1, the expected emissions reductions fromthe included measures exceeds the EPA-identified shortfall of 5.4 tpsd for VOCs and 0 .5 tpsd for nitrogen oxides. Administrative Materials For each amendment or new regulation, all required state and federal procedures for public participation were followed as evidenced in the attachments listed below . Such attachments are included in satisfaction of the requirements of 40 CFR 51, Appendix V, Section 2 . For each amendment or new

regulation, the public notice and certification of public hearing demonstrate that the Department held a public hearing in accordance with the public notice and that the Department followed appropriate state and federal procedures for public participation. The hearing report provided for each new section or amendment includes a summary of comments received and a description ofchanges made as a result ofthe comments. The submitted attachments include the following: Table 1 . Estimated emission reduction benefits fromConnecticut's EPA-identified emission reduction shortfall measures Attachment A

: Amendment of R

.C.S.A. Sections 22a-174-4 and 22a-174-7 A-1 . Notice of public hearing . A-2. Certification of public hearing. A-3 . Hearing report . A ttachment B: Amendment of R .C.S .A . Section 22a-174-18 B-1 . Notice of public hearing. B-2 . Certification of public hearing. B-3 . Hearing report . Attachment C

: New R .C.S.A. Section 22a-174-3b C-1 . Notice of public hearing . C-2. Certification of public hearing . C-3 . Hearing report . (Incorporation by reference of the hearing report submitted in the June 14, 2002 SIP revision regarding the new source review

program .) C-4 . Emission reduction calculations . C-5 . Sample letter to owners and operators of automotive refinishing operations regarding the duty to comply and list of recipients .Attachment D : Amendment of R

.C.S.A. Section 22a-174-30 and New R .C.S.A. Section 22a-174-43 D-1 . Notice of public hearing . D-2 . Certification of public hearing . D-3. Hearing report . D-4 . Emission reduction calculations for R .C.S.A. Section 22a-174-30 . D-5 . Emission reduction calculations for R .C.S.A. Section 22a-174-43.