STATEMENT OF REVISION TO THE 

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 EPA to 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 them into 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 of the 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 from the visible emissions standards for certain 

sources during certain periods of operation; 5) adding an exemption from the 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 to 
Table 1 . Estimated emission reduction benefits from Connecticut's EPA-identified 

emission reduction shortfall measures. 

The first value listed for each level of rule effectiveness assumes no compliant PFC are 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. VOC reductions from PFCs 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 of the 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 from certain 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 of the 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 form of new R.C.S.A. 

section 22a-174-3b . 

" New R.C.S .A. Section 22a-174-3b, Exemptions from Permitting for Construction and 

Operation of Automotive 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 from the permitting process by removing compliant owners and operators 

from the 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 of the 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 from each 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 of the emissions reductions 

associated with the additional control measures. The contributions of these 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 from the 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 of changes made as a result of the comments. The submitted 

attachments include the following: 

Table 1 . Estimated emission reduction benefits from Connecticut'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 . 

Attachment 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 .