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Connecticut Department of Energy and Environmental Protection

Bureau of Air Management

Reasonably Available Control Technology Analysis under the

2008 8-Hour Ozone National Ambient Air Quality Standard

July 17, 2014

The Connecticut Department of Energy and Environmental Protection (DEEP) has prepared this Reasonably 

Available Control Technology (RACT) analysis to demonstrate that the State has met its obligation under the Clean 

Air Act, as amended in 1990 (CAA), for planning related to the 2008 8-hour ozone national ambient air quality 

standard (NAAQS). Most recently, the U.S. Environmental Protection Agency’s (EPA’s) proposed rule 

Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan 

Requirements (78 FR 34178 (2013)) (draft Implementation Rule) set out the requirements for RACT State 

Implementation Plans (SIPs). DEEP used the draft Implementation Rule, as well as earlier EPA guidance concerning 

RACT, as guides to make the determinations necessary to prepare this analysis.

I. Overview

On July 20, 2012, Connecticut’s designation as marginal nonattainment for the 2008 8-hour ozone NAAQS became 

effective. Under CAA Section 182(a)(2)(A), the marginal nonattainment designation obligates the DEEP to correct 

pre-1990 RACT requirements (the RACT fix-up).

1

 RACT is defined 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 (1979)) 

However, Connecticut is a member of the Ozone Transport Region (OTR) and is required under CAA Section 

184(b)(1)(B) to implement statewide RACT for all volatile organic compound (VOC) sources covered by a control 

techniques guideline (CTG). CAA Section 184(b)(2) adds that any stationary source that has the potential to emit at 

least 50 tons per year of VOC is considered a major stationary source and is subject to the requirements that would 

apply to a major stationary source in a moderate nonattainment area.2

 Under CAA Section 182(f), states must apply 

the same requirements to major stationary sources of nitrogen oxides (NOx) as are applied to major stationary sources 

of VOC in ozone nonattainment areas. As a result, DEEP is required to adopt RACT for (1) all VOC sources covered 

by a CTG; and (2) all major non-CTG sources of NOx and VOC. 

Pursuant to the draft Implementation Rule (78 FR 34194; 6 June 2013), DEEP must submit a final RACT SIP to EPA 

by July 20, 2014. As a marginal nonattainment area, Connecticut is required to attain the 2008 ozone NAAQS by 

December 31, 2015. New requirements necessary to update RACT in Connecticut must be effective in the state by 

January 1, 2017 pursuant to the draft Implementation Rule. 

 1 Marginal nonattainment states are not required to submit attainment demonstrations.

2 Section 302(j) of the CAA defines “major stationary source” as any stationary facility or source of air pollutants which directly 

emits, or has the potential to emit, one hundred tons per year or more of any air pollutant.
2

II. RACT implementation history in Connecticut

A. 1-hour ozone NAAQS

The 1990 CAA Amendments established nonattainment areas and attainment deadlines based on the severity of 

violations of the 1-hour ozone NAAQS (0.12 ppm averaged over one hour). The southwest portion of 

Connecticut,

3 as part of the New York-Northern New Jersey-Long Island area, was designated as severe 

nonattainment with a 2007 attainment date. The remainder of the state, the Greater Connecticut nonattainment 

area, was designated as serious nonattainment with a 1999 attainment date. An extension of the attainment date to 

2007 for Greater Connecticut was approved by EPA on January 3, 2001 (66 FR 634).

DEEP submitted ozone attainment demonstrations for the Greater Connecticut serious nonattainment area and the 

Southwest Connecticut severe nonattainment area to EPA on September 16, 1998. These submissions were 

modified by submittals on February 8, 2000; October 15, 2001; June 17, 2003 and December 1, 2004. EPA issued 

the final approval of the 1-hour ozone NAAQS attainment demonstration for Greater Connecticut on January 3, 

2001 (66 FR 634). On December 11, 2001, EPA published final approval of the 1-hour ozone NAAQS attainment 

demonstration for Southwest Connecticut (66 FR 63921). 

 

In its attainment demonstrations, DEEP relied on photochemical grid modeling, air quality trends and other 

corroborating weight of evidence to demonstrate that adopted and mandated control programs within Connecticut 

and upwind areas were sufficient to enable all areas of the State to achieve attainment of the 1-hour ozone NAAQS 

by 2007. In response to comments received on the serious ozone nonattainment area attainment demonstration,

EPA determined that the Greater Connecticut attainment demonstration did not include sufficient documentation 

concerning available Reasonably Available Control Measures (RACM)

4

, and developed an analysis to help address 

this issue (65 FR 61134 (2000)). The analysis demonstrated that the possible emission control measures would not 

advance the attainment date and would therefore not be considered RACM. As RACT is a subset of RACM (see

CAA Section 172(c)(1)), DEEP considered RACT satisfied for Greater Connecticut.

As part of a 1999 conditional approval of DEEP’s ozone attainment demonstration for Southwest Connecticut, EPA 

required that DEEP, among other things, submit a mid-course review of attainment progress. In its 2005 midcourse review, DEEP submitted the control strategies implemented statewide in Connecticut to meet the 1-hour 

ozone NAAQS. These control strategies are listed in Table 1. EPA also required DEEP to submit measures 

achieving additional emission reductions identified by EPA as necessary for attainment by 2007, which are referred 

to as shortfall measures. 

 3 Includes the towns of Bethel, Bridgeport, Bridgewater, Brookfield, Danbury, Darien, Easton, Fairfield, Greenwich, Monroe, 

New Canaan, New Fairfield, New Milford, Newtown, Norwalk, Redding, Ridgefield, Sherman, Stamford, Stratford, Trumbull, 

Weston, Westport and Wilton.

4 Required by subpart 1 of part D of the CAA for states submitting attainment demonstrations. 
3

Table 1. Control Strategies Implemented Statewide in Connecticut to Meet the 1-Hour Ozone NAAQS1

Control Strategy Pollutant Federal

Program

State

Program

Rule

Approval 

Date2

Initial Year of

Implementation3

VOC NOx

Stationary Sources4

Consumer Products ● ● 09/11/98 1999

Architectural & Industrial Maintenance Coatings ● ● 09/11/98 2000

Autobody Refinishing VOC Limits ● ● 09/11/98 1999

Stage I Vapor Recovery at Gasoline Service Stations ● ● 10/18/91 1992

Stage II Vapor Recovery at Gasoline Service Stations ● ● 12/17/93 1994

VOC RACT ● ● 03/21/84 1984

Cutback Asphalt: Increased Rule Effectiveness ● ● 10/24/97 1998

Gasoline Loading Racks: Increased Rule 

Effectiveness

● ● 10/24/97 1998

CT NOx “RACT” Regulation ● ● 10/06/97 1994

OTC Phase II NOx Controls ● ● 09/28/99 1999

NOx Budget Program (EPA NOx SIP Call) ● ● 12/27/00 2003

Municipal Waste Combustor Controls ● ● 04/21/00;

12/06/015

2000, 2003

Mobile Sources

Enhanced I/M (ASM 2525 phase-in cutpoints) ● ● ● 03/10/99 2000

Enhanced I/M (ASM 2525 final cutpoints) ● ● ● 10/27/00 2004

OBD-II Enhanced I/M ● ● ● 6 2004

Reformulated Gasoline - Phase I4 ● ● ● 12/23/917 1995

Reformulated Gasoline - Phase II4 ● ● ● 02/16/947 2000

Tier 1 Motor Vehicle Controls ● ● ● 06/05/91 1994

On-board Refueling Vapor Recovery ● ● 04/06/94 1997-2005

National Low Emission Vehicle Program ● ● ● 03/02/988 1998 (in CT)

Tier 2 Motor Vehicle Controls/Low Sulfur Gasoline ● ● ● 2/10/00 2004-2008

California Low Emission Vehicle Phase 2 (CALEV2) ● ● ● ● 9 2007

Heavy-Duty Diesel Vehicle Controls and Fuels ● ● ● 10/06/00 2004-2005

Non-Road Engine Standards10 ● ● ● 1994-

200011

1996-2008

Footnotes to Table 1

1 Footnotes 2 through 9 are as they appeared in the Mid-Course Review in 2005. 

2 Unless otherwise noted, this is the date of Federal Register publication of either a final federal rule or EPA's approval of a state SIP 

submittal, as appropriate for the indicated control strategy.

3 A range of implementation years is listed for some strategies due to phase-in of standards. In addition, all listed mobile source 

strategies (except enhanced I/M and reformulated gasoline) result in increased levels of emission reductions through and beyond 2007 due to 

the gradual turnover of the affected fleets.

4 Reformulated gasoline requirements also result in a reduction in evaporative VOC emissions throughout the gasoline distribution 

system.

5 These are the approval dates of municipal waste combustor state plan submissions as published in the Federal Register. The 

associated reductions were approved for attainment purposes on 12/1/01.

6 Amendment to incorporate OBD-II adopted 08/25/04. Not submitted to EPA as of the date of this submission.

7 Promulgated statewide under 40 CFR 80.70. Approved for 15% rate-of-progress on 03/10/99.

8 EPA Administrator Browner determined that the NLEV program was in place on 03/02/98. As a result, rules published on 

06/06/97 and 01/07/98 went into effect.

9 Regulation adopted 12/03/04. 

10 The initial implementation date for non-road vehicle standards varies by category (e.g., small gasoline engines, locomotives, 

construction equipment, etc). Does not include EPA’s June 29, 2004 final Tier 4 rule requiring additional reductions from new non-road 

engines beginning in 2008.

11 Federal rule approval dates for on-road engine standards vary by category.
4

The 1-hour ozone NAAQS shortfall measures were identified as the following in the mid-course review: 

• NOx reductions at municipal waste combustor facilities (adopted on October 26, 2000);

• VOC restrictions for automotive refinishing operations (adopted on March 15, 2002);

• Stage II vapor recovery at gasoline pumps (adopted on May 10, 2004); and

• Spillage and permeation controls on portable fuel containers (adopted on May 10, 2004).

The submission of the mid-course review satisfied the final outstanding commitment contained in EPA’s attainment 

demonstration approval, and therefore RACT was satisfied for the Southwest Connecticut nonattainment area, 

although RACT was never explicitly addressed as such by EPA.5

 

B. 1997 8-hour ozone NAAQS

Under the 1997 8-hour ozone NAAQS (0.08 ppm averaged over eight hours), the entire state was designated as 

moderate nonattainment6 with a June 2010 attainment date. EPA revoked the 1-hour ozone NAAQS effective June 

15, 2005. However, under anti-backsliding provisions, Connecticut retained the more stringent major source 

thresholds (25 tpy in the severe nonattainment area and 50 tpy in the serious nonattainment area)7 in implementing 

its current programs.

8

 Such sources remain subject to the more stringent major source thresholds such as 

requirements imposed under new source review permitting and regulatory RACT controls. This practice is 

consistent with EPA’s guidance.9

EPA approved the 1997 8-hour ozone attainment demonstration for Greater Connecticut on December 26, 2013 (78 

FR 78272), after DEEP withdrew the Industrial, Commercial and Institutional (ICI) boiler NOx control strategy 

from the attainment demonstration on April 2, 2013. EPA proposed but has not finalized approval of the attainment 

demonstration for Southwest Connecticut. (78 FR 27161; May 9, 2013) However, EPA published a Clean Data 

Determination (CDD) on June 18, 2012 (77 FR 36163) indicating that, with respect to the NY-NJ-CT 1997 eighthour ozone nonattainment area, the area attained the 1997 eight-hour ozone standard by the applicable deadline, 

June 15, 2010, based on complete, quality-assured and certified ozone monitoring data for 2007-2009. EPA also 

determined at that time that the area was currently attaining the 1997 eight-hour ozone standard based on complete, 

quality-assured and certified ozone monitoring data for both 2008-2010 and 2009-2011. 

On April 7th and 24th , 2014, the EPA Region 2 and Region 1 Administrators, respectively, signed a notice 

proposing to determine that the air quality in the New York-New Jersey-Connecticut 1997 8-hour ozone 

nonattainment area is no longer attaining the 1997 ozone NAAQS based on complete, quality-assured and certified 

ozone monitoring data for 2010-2012 and preliminary data for 2011-2013. On May 17, 2014, EPA further 

proposed to rescind the CDD and issue a SIP call to New York, New Jersey and Connecticut to submit a new 

attainment demonstration to show how the area will re-attain the 1997 8-hour ozone NAAQS as expeditiously as 

practicable (79 FR 27830). 

For the purposes of the 1997 8-hour ozone RACT analysis, submitted to EPA on December 8, 2006, DEEP 

addressed only those major sources as required under CAA Section 184, that is, 50 tpy VOC and 100 tpy NOx. In 

its RACT analysis, DEEP determined that Connecticut had no deficiencies under the RACT fix-up to correct. 

DEEP determined that the majority of CTG categories were addressed through Regulations of Connecticut State 

 5

 EPA approved the regulations addressing the attainment shortfall measures on December 6, 2001 (66 FR 63311) (municipal 

waste combustors) and August 31, 2006 (71 FR 51761) (automotive refinishing operations, Stage II vapor recovery and 

portable fuel containers).

6

 As for the 1-hour ozone NAAQS, the state was divided into two nonattainment areas. The southwest Connecticut counties of 

Fairfield, New Haven and Middlesex were included with counties in northern New Jersey and southern New York as part of 

the NY-NJ-CT nonattainment area. The remaining five counties in Connecticut were included in the Greater Connecticut 

nonattainment area.

7 Section 182(c), (d) and (f) of the CAA.

8

 The terms “serious nonattainment area for ozone” and “severe nonattainment area for ozone” are defined in RCSA section 

22a-174-1 and continue to be used in a number of regulations, notably Connecticut’s new source review program requirements 

(RCSA section 22a-174-3a). 9

 See, e.g., the draft Implementation Rule, 78 FR 34192, footnote 36. 
5

Agencies (RCSA) sections 22a-174-20, 22a-174-30 and 22a-174-32. DEEP further determined that two CTG 

categories, cutback asphalt paving and solvent cleaning (metal degreasing) were appropriate to update. DEEP also 

committed to analyze the need to adopt requirements to address EPA’s 2006 CTGs for Lithographic Printing 

Materials, Letterpress Printing Materials, Flexible Packaging Printing Materials, Flat Wood Paneling Coatings, and 

Industrial Cleaning Solvents. DEEP reaffirmed its existing negative declarations for certain CTG sources. 

Regarding major NOx sources, DEEP indicated that it was preparing an amendment to RCSA section 22a-174-38 

to make certain necessary changes based on the federal requirements for municipal waste combustors, but that 

Connecticut’s emission limits at that time represented RACT for the municipal waste combustors. At the time of 

the RACT SIP, DEEP had proposed revisions to RCSA section 22a-174-22 to include more stringent emissions and 

control requirements such that all major NOx sources would meet or exceed RACT.10 The requirements of the 

proposed revisions to RCSA section 22a-174-22 were characterized as “beyond RACT” in the 1997 8-hour ozone 

RACT SIP analysis. 

EPA approved DEEP’s 1997 8-hour ozone RACT submission effective July 29, 2013 (78 FR 38587-38591). That 

approval is not affected by EPA Region 1’s subsequent proposed rule to rescind the CDD. 

C. 2008 8-hour ozone NAAQS

Under the 2008 8-hour ozone NAAQS (75 ppb averaged over eight hours), the entire state is designated as marginal 

nonattainment with a December 2015 attainment date, retaining the same nonattainment boundaries that were 

established for the 1997 ozone NAAQS (see footnote 6). As such, there is no requirement for DEEP to submit an 

attainment plan for either of these areas, nor would such plans be particularly useful given that nonattainment in 

these areas is heavily influenced by interstate pollution transport. 

For this 2008 8-hour ozone RACT SIP analysis, DEEP continues to address only those major sources as required by 

CAA sections 184(b)(2) and 182(f) (i.e., 50 tpy VOC and 100 tpy NOx). Connecticut’s RACT analysis for the 

2008 8-hour ozone NAAQS is set out in Section IV of this document.

III. Update on Federal, state and regional efforts to limit ozone precursor emissions

Connecticut has made significant progress in reducing both NOx and VOC emissions since the 1990 CAA 

Amendments. This section provides an update on the continuing federal, state and regional programs to limit ozone 

precursor emissions, as well as an update on efforts to address interstate air pollution transport.

A. Federal and state efforts

As can be seen in Figure 1, the ozone exceedance day trend has decreased dramatically with the implementation of 

post-1990 CAA federal and state emission control measures. The ozone exceedance day trend is expected to 

decrease further with the finalization of Tier 3 Motor Vehicle Emission and Fuel Standards11 and the anticipated 

proposal of an air transport rule to address the 1997 and 2008 ozone NAAQS and implementation of the Cross State 

Air Pollution Rule.

Projected NOx emissions follow the same trend as the ozone exceedance days, decreasing significantly with time. 

Figure 2 shows the NOx emissions estimated for Connecticut’s portion of the NY-NJ-CT area in 2007, 2017 and 

2025. Statewide NOx emissions would likely follow the same trend. The projected emissions include adopted 

NOx programs through 2012, but do not include Tier 3 motor vehicle emissions standards or post CAIR transport 

rules. 

 10 On February 8, 2008, DEEP indicated that it would suspend efforts to amend RCSA section 22a-174-22. 

http://www.ct.gov/deep/lib/deep/air/regulations/proposed_and_reports/control_of_nitrogen_oxides_emission_letter.pdf

11http://www.gpo.gov/fdsys/pkg/FR-2014-04-28/pdf/2014-06954.pdf
6

Figure 1. Connecticut 8-Hour Ozone NAAQS (75 ppb) Exceedance Day Trends and 

Implemented Control Strategies 1975-2013

Figure 2. Projected NOx Emissions for CT’s Portion of the NY-NJ-CT Area.
7

Despite Connecticut’s success in reducing ozone exceedance days experienced in the summer months in 

Connecticut over the last 30 years,12 it important to recognize the limits of obtaining additional emissions 

reductions from sources in the state as a means 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 2011 National Emissions Inventory (NEI). Note that biogenic sources in Connecticut are 

estimated to emit an additional 48,070 tons of VOC annually. Thus, about 129,670 tons of VOC were emitted 

statewide in 2011. 

Connecticut’s major stationary sources of NOx emitted about 5902 tons of NOx in 2011, according to 

Connecticut’s 2011 emissions statement reporting. These stationary sources account for approximately 7.5% of the 

NOx emissions inventory. Connecticut’s major stationary sources of VOC emitted approximately 880 tons 

according to the 2011 emissions statement reporting. This amounts to approximately 1% of the statewide total 

annual VOC emissions (not including biogenic emissions). Thus, opportunities for Connecticut to reduce ambient 

ozone levels through control of its major stationary sources are severely limited. The impact of mobile and area 

source emissions, and pollution transported from other states, on ozone values in Connecticut, cannot be overstated. 

Significant reductions from sources in upwind states are crucial to Connecticut’s ability to attain and maintain the 

ozone NAAQS.

Table 2. Connecticut State Emissions Summary by Tier 1 Source Category (NEI 2011)

Tier Category VOC 

Annual 

Emissions 

(Tons)

NOx 

Annual 

Emissions 

(Tons)

1 FUEL COMB. ELEC. UTIL. 82 1,277

2 FUEL COMB. INDUSTRIAL 168 3,397

3 FUEL COMB. OTHER 9,607 10,616

4 CHEMICAL & ALLIED 

PRODUCT MFG 48 0

5 METALS PROCESSING 0 0

6 PETROLEUM & RELATED 

INDUSTRIES 1 0

7 OTHER INDUSTRIAL 

PROCESSES 251 0

8 SOLVENT UTILIZATION 26,721 0

9 STORAGE & TRANSPORT 4,433 5

10 WASTE DISPOSAL & 

RECYCLING 317 3,182

11 HIGHWAY VEHICLES 22,676 38,933

12 OFF-HIGHWAY 17,165 21,310

14 MISCELLANEOUS 131 25

Total 81,601 78,744

B. Ozone Transport Commission efforts

One of the processes by which DEEP has worked to address upwind emissions is through the Ozone Transport 

Commission (OTC), of which Connecticut is a member state. Through Section 184 of the 1990 CAA amendments, 

the United States Congress established the OTC as the single ozone transport region (the Ozone Transport Region 

or OTR), comprised of eleven member states and the District of Columbia, to help coordinate plans for reducing 

ground-level ozone in the Northeast and Mid-Atlantic states. Over the years, the OTC has developed 

 12 DEEP acknowledges that Connecticut’s efforts alone are not wholly responsible for the reduction in ozone exceedance days. 

Federal measures and controls in upwind states are also responsible for the improvement. 
8

recommendations for additional ozone control measures well beyond those required by the CAA to be applied 

within the OTR to ensure attainment and maintenance of the ozone NAAQS. Connecticut has, in part, relied on 

this regional effort to determine if current NOx and VOC controls continue to represent RACT for the 2008 8-hour 

ozone NAAQS. 

In its 1997 8-hour ozone RACT SIP analysis, DEEP included a table titled “Control measures recommended by the 

OTC to pursue as regional ozone attainment measures and the status of Connecticut’s efforts toward measure 

implementation.” DEEP indicated that:

• The following VOC control measures were under development: Reformulation of Consumer Products 

(new RCSA section 22a-174-40), Design Improvements to Portable Fuel Containers (amendment of RCSA 

section 22a-174-43), Restrictions on Asphalt and for Paving Operations (amendment of RCSA section 22a174-20(k), and Restrictions on the Manufacture and Use of Adhesives and Sealants (new RCSA section 

22a-174-44). The identified regulations have since been finalized. 

• The following NOx control measures were anticipated to occur: Reductions in the Sulfur Content of 

Heating Oil to Improve Combustion and Reduce NOx Emissions (former Connecticut Public Act 06-143; 

now Connecticut General Statute 16a-21a) and Emissions Limitations and Operation Practices for ICI 

Boilers (amendment of RCSA section 22a-174-22). While the Reductions in the Sulfur Content of Heating 

Oil were finalized in 2013, the amendment of RCSA section 22a-174-22 for Emissions Limitations and 

Operation Practices for ICI Boilers did not occur (see footnote 10).

• Standards for Asphalt Plants and Electric Generating Units were under development by OTC.13

Since the submission of DEEP’s 1997 8-hour ozone RACT SIP in 2006, the OTC has finalized additional Model 

Rules for several source categories. Connecticut’s status on adopting the recently finalized OTC Model Rules is 

indicated in Table 3. Details of the OTC regional model rules identified in Table 3 can be found at the OTC 

website ( http://otcair.org/). DEEP considers the amendments under development for RCSA sections 22a-174-40 

and 22a-174-41, concerning consumer products and architectural coatings, to be RACT and commits to work to 

complete those regulatory amendment processes by December 31, 2016. DEEP also considers the amendment to 

RCSA section 22a-174-20 concerning aboveground storage tanks, which was effective on March 7, 2014, to be 

RACT and has included a reference to this amendment in Table 4. 

 13 OTC did not finalize a model rule for either sector. 
9

Table 3. Control measures recommended by the OTC to pursue as regional ozone attainment measures and the status of 

Connecticut’s efforts toward measure implementation.

VOC Control Measures Connecticut regulation (if applicable) Status of Control Measure 

Implementation in Connecticut

2013 Consumer Product Update Dual 

Purpose Air Freshener/Disinfectant

Amendment of RCSA section 22a-174-

40

Amendment of existing Connecticut 

regulation now under development.

Consumer Products 2012 Update Amendment of RCSA section 22a-174-

40

Amendment of existing Connecticut 

regulation now under development.

Consumer Products (2010) Amendment of RCSA section 22a-174-

40

Amendment of existing Connecticut 

regulation now under development.

Solvent Degreasing RCSA section 22a-174-20(l) Existing regulation satisfies RACT. DEEP 

determined that it is not appropriate 

for CT to adopt OTC Model Rule

because there is no significant air 

quality benefit.

Motor Vehicle and Mobile Equipment 

Non-Assembly Line Coating Operations 

(and alternate technical revisions)

RCSA section 22a-174-3b(d) Existing regulation satisfies RACT. DEEP 

determined that it is not appropriate 

for CT to adopt OTC Model Rule 

because there is no significant air 

quality benefit. There is also a 

significant cost to the auto refinishers, 

many of which are small businesses.

AIM Coatings Update Amendment of RCSA section 22a-174-

41

Amendment of existing Connecticut 

regulation now under development.

Large Above Ground VOC Storage Tanks Amendment of RCSA section 22a-174-

20

Requirements adopted on March 7, 

2014 and submitted as a SIP revision.

NOx Control Measures

New Small Boilers Technical Revisions Not applicable, but Connecticut 

General Statutes section 16a-48, 

amended in 2008 contains fuel 

efficiency standards for boilers. 

TBD. DEEP to determine if adoption of 

the model rule is appropriate for 

Connecticut.

Stationary Generators RCSA section 22a-174-22 contains 

provisions for stationary generators. 

RCSA section 22a-174-42 contains 

provisions for distributed generators.

RCSA section 22a-174-22 under 

reevaluation as discussed in Section IV. 

HEDD Turbines RCSA section 22a-174-22 contains 

NOx emission limits for turbines. 

Compliance is determined by three 1-

hour tests.

DEEP submitted a letter to the EPA 

dated July 16, 2009 with a progress 

report demonstrating that the HEDD 

Performance Partnership Agreement 

commitment be considered complete, 

thereby satisfying the OTC HEDD MOU. 

In addition, HEDD will be a 

consideration in the reevaluation of 

RCSA section 22a-174-22 discussed in 

Section IV. 
10

C. Transported emissions

OTC screening modeling , as well as EPA modeling for the Cross State Air Pollution Rule, indicate that 

Connecticut and several other states will struggle to attain the 2008 8-hour ozone NAAQS14 as a result of 

overwhelming air pollution transport. Faced with few alternatives under the 1990 CAA, on December 10, 2013, 

Connecticut and seven other states filed a petition under CAA Section 176A requesting the EPA Administrator to 

add the states of Illinois, Indiana, Kentucky, Michigan, North Carolina, Ohio, Tennessee, Virginia and West 

Virginia to the OTR.15 As EPA has 18 months to act on that petition, any timely action on this petition is unlikely 

to assist Connecticut’s attainment of the 2008 ozone NAAQS by the December 31, 2015 attainment deadline for 

marginal nonattainment areas. Because of the magnitude of the transport problem and the small contribution to 

total NOx and VOC emissions by Connecticut’s major stationary sources, no matter what RACT measures are 

implemented in Connecticut, all regional air quality modeling available to DEEP indicates that Connecticut will not 

attain and maintain the ozone NAAQS without significant additional upwind reductions and the implementation of 

stronger federal measures. 

In addition to the need for strong transport rules to address the 1997 and 2008 ozone NAAQS, federal measures that 

would assist Connecticut and other states to attain and maintain the ozone NAAQS include national rules for 

consumer products and architectural coatings, such as those suggested by the OTC, and NOx emission limits for 

industrial, commercial, and institutional boilers. In addition, as federal and state requirements work to reduce 

stationary and area source emissions, the importance of reductions in the mobile source sector grows. Given the 

limitations on states to reduce mobile source emissions, EPA must take additional bold actions, including non-road 

idling restrictions, to reduce emissions from mobile sources. Finally, EPA must assure that each state with an 

ozone nonattainment area has in place a good neighbor SIP that adequately addresses the state’s contribution to 

nonattainment in downwind states, so that air quality improvement from collective upwind reductions make it 

feasible for downwind states to achieve attainment.

IV. RACT analysis

This section sets out DEEP’s analysis of its RACT adequacies and deficiencies for CTG sources and major sources 

of NOx and VOC. DEEP also identifies specific issues related to RACT controls for major stationary sources of 

NOx and Connecticut’s attainment of the 2008 ozone NAAQS. This section also includes DEEP’s commitments to 

address identified deficiencies. 

A. CTG sources 

For sources for which a CTG has been published, RACT is addressed if a state imposes controls equivalent to the 

CTG for that source or source category. Table 4 lists the current CTG documents and identifies the corresponding 

regulations that Connecticut has adopted to achieve emissions reductions equivalent to the CTGs. Table 4 also 

includes the effective dates of the state regulations and the date of SIP approval. As explained 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.

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

RCSA: 22a-174-20, 22a-174-30 and 22a-174-32. RCSA section 22a-174-20, for the control of organic compound 

emissions, was first promulgated in the early 1970’s and has undergone numerous revisions since, the most recent 

effective on March 7, 2014. RCSA section 22a-174-20 generally contains the requirements for the initial 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 

section 22a-174-32. RCSA section 22a-174-32, entitled “Reasonably Available Control Technology for Volatile 

 14 See second paragraph on page 4 of DEEP’s September 4, 2013 comment letter on the draft Implementation Rule: 

http://www.ct.gov/deep/lib/deep/air/ozone/ozoneplanningefforts/ctdeep_comments_docket_epa-hq-oar-2010-0885.pdf

15 http://www.ct.gov/deep/lib/deep/air/176a/Petition__2013dec10.pdf Pennsylvania joined the petition on December 10, 2013. 
11

Organic Compounds,” includes control measures for additional CTG categories and for major sources of VOC. 

RCSA section 22a-174-32 was first promulgated in 1993 and was revised in 1999 and 2010. The CTG category for 

Stage I Vapor Recovery, as well as for Stage II, is implemented through RCSA section 22a-174-30. RCSA section 

22a-174-30 is entitled “Dispensing of Gasoline/Stage I and Stage II Vapor Recovery” and was implemented in late 

1992 and revised in 2004.16 

Since the submission of DEEP’s 1997 8-hour ozone RACT SIP in 2006, EPA has adopted a number of new or 

revised CTGs, and DEEP has undertaken additional efforts to ensure that its programs are consistent with all the 

published CTGs. 

2006 CTGs

On October 5, 2006, EPA finalized CTGs for the following source categories: Lithographic Printing Materials,17

Letterpress Printing Materials, Flexible Packaging Printing Materials, Flat Wood Paneling Coatings, and Industrial 

Cleaning Solvents (71 FR 58745). On April 29, 2010, DEEP submitted a SIP revision to EPA for nine CTGs, 

including new RCSA section 22a-174-20(gg), “Offset Lithographic Printing and Letterpress Printing”; new RCSA 

section 22a-174-20(ff), “Flexible Package Printing”; and new RCSA sections 22a-174-20(ii), “Industrial Solvent 

Cleaning” and 22a-174-20(jj), “Spray Application Equipment Cleaning.” In its final SIP approval on June 9, 2014

(79 FR 32873), EPA states that DEEP’s newly adopted regulations are consistent with the recommendations for 

RACT found in EPA’s CTGs for Offset Lithographic Printing and Letterpress Printing (EPA-453/R-06-002, 

September 2006), Flexible Package Printing (EPA-453/R-06-003, September 2006) and Industrial Cleaning 

Solvents (EPA-453/R-06-001, September 2006).

2007 CTGs

On October 9, 2007, EPA finalized CTGs for the following source categories: Large Appliance Coatings, Metal 

Furniture Coatings, and Paper, Film and Foil Coatings (72 FR 57215). DEEP’s April 29, 2010 SIP revision 

included new RCSA section 22a-174-20(hh), “Large Appliance Coatings”, revised RCSA section 22a-174-20(q), 

“Paper, Film and Foil Coatings”, and revised RCSA section22a-174-20(p), “Metal Furniture Coating. 

The revised RCSA section 22a-174-20(q) renames the regulation to address film and foil coating as well as paper 

coating; broadens the scope of activities addressed by the emission limit; includes additional VOC emission 

requirements for facilities with a potential to emit 25 tons or more VOCs per year; and updates work practices and 

general record keeping requirements. The revised RCSA section 22a-174-20(p) increases the number of coating 

categories and limits; requires work practices that limit VOC emissions and minimizes spills during material 

application, storage, containment, conveyance, and mixing; and clarifies record keeping requirements. In its 

proposed May 24, 2013 SIP approval, EPA states that DEEP’s newly adopted regulation is consistent with the 

recommendations for RACT found in EPA’s CTG for Large Appliance Coatings (EPA 453/R-07-004, September 

2007), and that DEEP’s revised RCSA sections 22a-174-20(q) and 22a-174-20(p) satisfy the anti-backsliding 

requirements in CAA Section 110(l). EPA issued final approval, and incorporated into the SIP, the changes to 

RCSA sections 22a-174-20(q) and 22a-174-20(p) on June 9, 2014 (79 FR 32873). 

2008 CTGs

On October 7, 2008, EPA finalized CTGs for the following source categories: Miscellaneous Metal Products 

Coatings, Plastic Parts Coatings, Auto and Light-Duty Truck Assembly Coatings, Fiberglass Boat Manufacturing 

Materials,18 and Miscellaneous Industrial Adhesives (73 FR 58481). DEEP’s November 21, 2012 SIP revision

included the revision of RCSA section 22a-174-20(s) to further limit volatile organic compounds (VOC) emissions 

from the coating of metal and plastic parts and the adoption of RCSA section 22a-174-20(kk) to limit VOC 

 16 DEEP is currently developing a proposal to repeal RCSA section 22a-174-30, given that the Connecticut legislature acted in 

2013 to decommission Stage II vapor recovery equipment. DEEP will be submitting the changes to the SIP accompanied by a 

demonstration pursuant to CAA sections 110(l) and 184(b)(2). 17 This CTG was addressed by a negative declaration. 18 The auto and light-duty truck assembly coatings and fiberglass boat manufacturing materials CTGs are addressed by 

negative declarations. 
12

emissions from the coating of pleasure craft. DEEP’s November 18, 2008 PM2.5 Attainment Demonstration SIP 

revision included new RCSA section 22a-174-44, “Adhesives and Sealants.”

DEEP proposed to revise RCSA section 22a-174-20(s) to include plastic parts coating and update the pre-existing 

metal parts coating requirements. EPA included pleasure craft coating operations within the metal and plastic parts 

coatings category in the 2008 CTG. Recognizing the differences in parts coating operations and pleasure craft 

coating, DEEP proposed to address pleasure craft coating through new subsection RCSA section 22a-174-20(kk), 

distinct from the requirements applying to metal and plastic parts coating. DEEP also revised RCSA sections 22a174-20(aa)(1) and (cc)(2) and (3), which was necessary given the revision to subsection (s) and adoption of 

subsection (kk). In its proposed May 24, 2013 SIP approval , EPA states that the revised rule satisfies the antibacksliding requirements in CAA Section 110(l) and is consistent with the EPA guidance memorandum entitled 

“Approving SIP Revisions Addressing VOC RACT Requirements for Certain Coating Categories.” EPA issued 

final approval, and incorporated into the SIP, the changes to RCSA sections 22a-174-20(s), 22a-174-20(aa)(1) and 

22a-174-20(cc)(2) and (3) and new section 22a-174-20(kk) on June 9, 2014. 

 

For the Control Techniques Guidelines for Miscellaneous Industrial Adhesives (EPA 453/R-08-005 2008/09), 

DEEP determined that an equivalent level of control is provided by an existing air quality regulation, RCSA section 

22a-174-44. RCSA section 22a-174-44 is based on an OTC model rule that is, in turn, based on a RACT 

determination prepared by the California Air Resources Board in 1998 and regulations adopted in the California 

local air pollution control districts.

RCSA section 22a-174-44 achieves VOC reductions through two basic components: sale and manufacture 

restrictions that limit the VOC content of specified adhesives, sealants and primers sold in the state; and use 

restrictions that apply primarily to commercial/industrial operations. In addition to the VOC content limits and use 

requirements, RCSA section 22a-174-44 includes requirements for cleanup and preparation solvents and allows for 

compliance through the use of add-on air pollution control equipment. In its proposed May 24, 2013 SIP approval, 

EPA states that while there are differences between the adhesive categories and emission limits in the CTG and 

RCSA section 22a-174-44, those differences are inconsequential compared to the broader applicability of RCSA 

section 22a-174-44. EPA issued final approval, and incorporated into the SIP, section RCSA section 22a-174-44 

on June 9, 2014.

Negative declarations

DEEP’s April 29, 2010 SIP revision included negative declarations for three source categories that correspond to 

the sources covered in the Flat Wood Paneling Coatings (EPA-453/R-06-004, September 2006), Fiberglass Boat 

Manufacturing Materials (EPA 453/R-08-004, September 2008), and Automobile and Light-Duty Truck Assembly 

Coatings (EPA 453/R-08-006, September 2008) CTGs. To make this determination, DEEP reviewed the inventory 

of sources for facilities with North American Industrial Classification System codes that correspond to the sources 

covered by the CTGs, interviewed its field staff, and searched telephone directories and Internet Web pages, 

including other state government databases, to identify and evaluate sources that might meet the applicability 

requirements. DEEP ultimately determined that there are no sources covered by these CTGs in Connecticut. In its 

final June 9, 2014 SIP approval, EPA confirms that DEEP’s process for determining the categories for which the 

state should make negative declarations is reasonable. 

Stage I/Stage II vapor recovery

Connecticut addresses Stage I and II vapor recovery under the authority of CGS section 22a-174e and RCSA 

section 22a-174-30. In 2013, CGS section 22a-174e was revised by the Connecticut General Assembly to mandate 

decommissioning of all Stage II vapor recovery systems and require annual pressure decay testing.19 DEEP is 

currently seeking to repeal RCSA section 22a-174-30 to remove the Stage II provisions and adopt a new regulatory 

section that includes test methods and other requirements for Stage I vapor recovery, consistent with CGS section 

22a-174e. When the regulatory revision process is complete, DEEP will submit a SIP revision to demonstrate that 

the requirements of CAA Sections 184(b)(2) and 110(l) are addressed and EPA’s widespread use rule (77 FR 

28772, May 16, 2012) is satisfied. Connecticut may in the future consider enhanced Stage I vapor recovery 

 19 Public Act 13-120, available at: http://www.cga.ct.gov/2013/ACT/PA/2013PA-00120-R00HB-06534-PA.htm
13

requirements, but that action is not included in the regulatory revision in process and is not considered RACT for 

the 2008 ozone NAAQS. 

Aboveground storage tanks

On March 7, 2014, DEEP adopted revisions to subsections (a), (b), and (c) of RCSA section 22a-174-20 primarily

to update requirements concerned with the control of VOC emissions from large aboveground storage tanks (AST). 

These revisions include those elements of the OTC Model Rule for Large Aboveground VOC Storage Tanks that 

are appropriate to Connecticut and meet or exceed control levels established in the applicable CTG.

20 Some of the 

new elements include removal of the option of using an undomed floating roof tank to store VOCs; improved

inspection requirements; new restrictions on roof landing events and degassing and cleaning operations; and timely 

repair of leaks throughout any VOC storage and transfer facility. Based on the 2007 Connecticut emissions 

inventory, there are 45 AST in the state that are subject to the new AST requirements. All 45 AST are floating roof 

tanks. As a group, these tanks emit approximately 150 tons of VOC per year. 

 20 Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks. EPA-450/2-78-

047 1978/12. 
Table 4. List of Issued CTGs and Connecticut Regulatory Requirements Corresponding to Each Listed CTG. 

CTG Category CTG Document Applicable Connecticut 

Regulation.

SIP Approval of Connecticut 

Regulation or Negative 

Declaration

Adopted by State/ Approved by EPA/ 

FR Cite/ 52.370

Comments

Aerospace Aerospace (CTG & MACT) (see 59 FR 29216, 

June 6, 1994); CTG (Final), EPA-453/R-97-004, 

December 1997.

22a-174-32 Reasonably Available 

Control Technology (RACT) for volatile 

organic compounds.

22a-174-20(s)Miscellaneous Metal and 

Plastic Parts Coating

11/18/93 3/10/99 64 FR 12024 ..... (c)(76) 

8/27/99 10/19/00 65 FR 62624 ..... (c)(84) 

4/29/10

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Automobile Coating Control Techniques Guidelines for Automobile 

and Light-Duty Truck Assembly Coatings (PDF 

44 pp, 2.64MB) EPA 453/R-08-006-2008/09

And

Protocol for Determining the Daily Volatile 

Organic Compound Emission Rate of 

Automobile and Light-Duty Truck PrimerSurfacer and Topcoat Operations (PDF 129 pp, 

450KB) EPA 453/R-08-002-2008/09

Not Applicable Negative declaration for coating of 

automobile and light-duty trucks

Connecticut reaffirms that no sources 

meeting the description of this CTG 

category are operating within the State.

Cutback Asphalt Control of Volatile Organic Compounds from 

Use of Cutback Asphalt, EPA-450/2-77-037, 

December 1977

22a-174-20(k) Restrictions on cutback 

asphalt

10/10/80 1/17/82 47 FR 762 ......... (c) 20 

12/13/84 7/18/85 50 FR 29229 ..... (c) 34 

10/31/89 10/18/91 56 FR 52205 ..... (c) 58 

8/22/12; 77 FR 50595; ...(c)100

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Dry Cleaning (Large 

Petroleum)

Control of Volatile Organic Compound 

Emissions from Large Petroleum Dry Cleaners, 

EPA-450/3-82-009, September 1982

Not Applicable 40 CFR § 52.375 (a) Certification of 

no large petroleum dry cleaner

sources.

Connecticut reaffirms that no sources 

meeting the description of this CTG 

category are operating within the State.

Fabric Coating Control of Volatile Organic Emissions from 

Existing Stationary Sources, Volume II: 

Surface Coating of Cans, Coils, Paper, Fabrics, 

Automobiles, and Light-Duty Trucks, EPA450/2-77-008, May 1977.

22a-174-20(o) Fabric and vinyl coating; 8/31/79 12/23/80 45 FR 84769 ..... (c) 11 

10/31/89 10/18/91 56 FR 52205 ..... (c) 58 

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Fiberglass Boat Control Techniques Guidelines for Fiberglass 

Boat Manufacturing Materials (PDF 41 pp, 

336KB) EPA 453/R-08-004-2008/09

Not Applicable Negative Declaration for fiberglass 

boat manufacturers

Connecticut reaffirms that no sources 

meeting the description of this CTG 

category are operating within the State.

Flexible Package Printing Control Techniques Guidelines for Flexible 

Package Printing (PDF 33 pp, 216KB) EPA22a-174-20(ff) 4/29/10

6/9/14 79 FR 32873

Regulatory requirements are consistent 

with the CTG and represent RACT under 
15

CTG Category CTG Document Applicable Connecticut 

Regulation.

SIP Approval of Connecticut 

Regulation or Negative 

Declaration

Adopted by State/ Approved by EPA/ 

FR Cite/ 52.370

Comments

453/R-06-003-2006/09 the 2008 8-Hour Ozone NAAQS. 

Bulk Gasoline Plants Control of Volatile Organic Emissions from 

Bulk Gasoline Plants, EPA-450/2-77- 035, 

December 1977

22a-174-20(b) Loading of gasoline and 

other volatile organic compounds.

4/4/72 5/31/72 37 FR 23085 ..... (b).

8/31/79 12/23/80 45 FR 84769 ..... (c) 11 

10/10/80 2/17/82 47 FR 6827 ....... (c) 25 

4/1/98 10/19/00 65 FR 62624 ..... (c)(84) 

9/24/83 3/21/84 49 FR 10542 ..... (c) 32 

12/13/84 7/18/85 50 FR 29229 ..... (c) 34 

10/31/89 10/18/91 56 FR 52205 ..... (c) 58 

4/1/98 10/19/00 65 FR 62624 ..... (c)(84)

3/07/2014

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Graphic Arts Control of Volatile Organic Emissions from 

Existing Stationary Sources, Volume VIII: 

Graphic Arts - Rotogravure and Flexography, 

EPA-450/2-78-033, December 1978.

22a-174-20(v) Graphic arts 

rotogravures and flexography.

10/10/80 2/17/82 47 FR 6827 ....... (c) 25 

10/31/89 10/18/91 56 FR 52205 ..... (c) 58 

11/18/93 3/10/99 64 FR 12024 ..... (c)(75) 

8/1/95 10/19/00 65 FR 62624 ..... (c)(84) 

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Industrial Adhesives Control Techniques Guidelines for 

Miscellaneous Industrial Adhesives (PDF 47 

pp, 350KB) EPA 453/R-08-005-2008/09

22a-174-44 11/18/08

6/9/14 79 FR 32873

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Large Appliances Control Techniques Guidelines for Large 

Appliance Coatings (PDF 44 pp, 374KB) EPA 

453/R-07-004-2007/09

22a-174-20(hh) 4/29/10

6/9/14 79 FR 32873

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Magnet Wire Control of Volatile Organic Emissions from 

Existing Stationary Sources, Volume IV: 

Surface Coating for Insulation of Magnet 

Wire, EPA-450/2-77-033, December 1977

22a-174-20(r) Wire coating. 8/31/79 12/23/80 45 FR 84769 ..... (c) 11

10/31/89 10/18/91 56 FR 52205 ..... (c) 58

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Metal Coil, Container and 

Closure

Control of Volatile Organic Emissions from 

Existing Stationary Sources, Volume II: 

Surface Coating of Cans, Coils, Paper, Fabrics, 

Automobiles, and Light-Duty Trucks, EPA450/2-77-008, May 1977.

22a-174-20(m) Can coating;

22a-174-20(n) Coil coating.

8/31/79 12/23/80 45 FR 84769 ..... (c) 11

10/31/89 10/18/91 56 FR 52205 ..... (c) 58

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Metal Furniture Control Techniques Guidelines for Metal 22a-174-20(p) Metal furniture coating. 8/31/79 12/23/80 45 FR 84769 ..... (c) 11 Regulatory requirements are consistent 
16

CTG Category CTG Document Applicable Connecticut 

Regulation.

SIP Approval of Connecticut 

Regulation or Negative 

Declaration

Adopted by State/ Approved by EPA/ 

FR Cite/ 52.370

Comments

Furniture Coatings (PDF 100 pp, 293KB) EPA 

453/R-07-005-2007/09

10/31/89 10/18/91 56 FR 52205 ..... (c) 58 

4/29/10 6/9/14 79 FR 32873

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Metal & Plastic Parts Coating Control Techniques Guidelines for 

Miscellaneous Metal and Plastic Parts 

Coatings (PDF 143 pp, 897KB) EPA 453/R-08-

003-2008/09

22a-174-20(s) Miscellaneous metal 

and plastic parts coating

22a-174-20(k) Pleasure craft coating

10/10/80 2/17/82 47 FR 6827 ....... (c) 25 

10/31/89 10/18/91 56 FR 52205 ..... (c) 58 

11/18/93 3/10/99 64 FR 12024 ..... (c)(75)

8/1/95 10/19/00 65 FR 62624 ..... (c)(84)

11/21/12 6/9/14 79 FR 32873

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Natural Gas / Gasoline Control of Volatile Organic Compound 

Equipment Leaks from Natural 

Gas/Gasoline Processing Plants, EPA-450/2-

83-007, December 1983.

Not Applicable

.

40 CFR § 52.375(b) Certification of 

no Natural Gas/Gasoline Processing 

Plant sources.

Connecticut reaffirms that no sources 

meeting the description of this CTG 

category are operating within the State.

Paper, Film & Foil Control Techniques Guidelines for Paper, Film, 

and Foil Coatings (PDF 102 pp, 488KB) EPA 

453/R-07-003-2007/09

22a-174-20(q) Paper coating; 8/31/79 12/23/80 45 FR 84769 ..... (c) 11 

10/31/89 10/18/91 56 FR 52205 (c) 58 

4/29/10 6/9/14 79 FR 32873

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Pharmaceutical Products Control of Volatile Organic Emissions from 

Manufacture of Synthesized Pharmaceutical 

Products, 450/2-78-029, December 1978. 

22a-174-20(t) Manufacture of 

synthesized pharmaceutical products.

10/10/80 2/17/82 47 FR 6827 ....... (c) 25 

10/31/89 10/18/91 56 FR 52205 ..... (c) 58 

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Polyester Resin Control of Volatile Organic Compound 

Emissions from Manufacture of High-Density 

Polyethylene, Polypropylene, and Polystyrene 

Resins, EPA-450/3-83-008, November 1983

AND

Control of Volatile Organic Compound 

Fugitive Emissions from Synthetic Organic 

Chemical Polymer and Resin Manufacturing 

Equipment, EPA-450/3-83-006, March 1984

22a-174-20(y) Manufacture of 

polystyrene resins.

2/2/87 5/19/88 53 FR 17934 ..... (c) 38 

10/31/89 10/18/91 56 FR 52205 ..... (c) 58 

AND 

40 CFR § 52.375 (d) Certification of 

no manufacturers of high-density

polyethylene and polypropylene 

resins.

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Printing Industries - offset 

lithographic and letterpress

Control Techniques Guidelines for Offset 

Lithographic Printing and Letterpress Printing

(PDF 52 pp, 349KB) EPA-453/R-06-002-

2006/09

22a-174-20(gg) 4/29/10 6/9/14 79 FR 32873 Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 
17

CTG Category CTG Document Applicable Connecticut 

Regulation.

SIP Approval of Connecticut 

Regulation or Negative 

Declaration

Adopted by State/ Approved by EPA/ 

FR Cite/ 52.370

Comments

Refineries Control of Refinery Vacuum Producing 

Systems, Wastewater Separators, and Process 

Unit Turnarounds, EPA-450/2-77-025, 

October 1977. 

AND

Control of Volatile Organic Compound Leaks 

from Petroleum Refinery

Equipment, EPA-450/2-78-036, June 1978. 

22a-174-20(c) “Volatile organic 

compound” water separation. Negative Declaration for refineries. Connecticut reaffirms that no sources 

meeting the description of this CTG 

category are operating within the State.

Rubber Tires Control of Volatile Organic Emissions from 

Manufacture of Pneumatic Rubber Tires, EPA450/2-78-030, December 1978.

22a-174-20(u) Manufacture of 

pneumatic rubber tires.

10/10/80 2/17/82 47 FR 6827 ....... (c) 25

10/31/89 10/18/91 56 FR 52205 ..... (c) 58 

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Service Stations Design Criteria for Stage I Vapor Control 

Systems - Gasoline Service Stations, 

November 1975. 

22a-174-30 Dispensing of 

Gasoline/Stage I and Stage II Vapor 

Recovery.

1/12/93 12/17/93 58 FR 65930 ..... (c) 62 

1/12/93 1/18/94 59 FR 2649 ....... (c) 62 

05/10/04 8/31/06 71 FR 51761 ....... (c) 95

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Ships Shipbuilding/repair ACT (EPA 453/R-94-032, 

April 1994) and CTG, see 61 FR 44050, August 

27, 1996

22a-174-32 Reasonably Available 

Control Technology (RACT) for volatile 

organic compounds.

11/18/93 3/10/99 64 FR 12024 ..... (c)(76) 

8/27/99 10/19/00 65 FR 62624 ..... (c)(84) 

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Solvent Cleaning Control Techniques Guidelines for Industrial 

Cleaning Solvents (PDF 290 pp, 7.6MB) EPA453/R-06-001-2006/09

22a-174-20(l) Metal cleaning

22a-174-20(ii)

22a-174-20(jj)

8/31/79 12/23/80 45 FR 84769 ..... (c) 11

10/10/80 6/7/82 47 FR 24452 ..... (c) 23

12/10/82 2/1/84 49 FR 3989 ....... (c) 29 

9/24/83 2/1/84 49 FR 3989 ....... (c) 29 

9/24/83 3/21/84 49 FR 10542 ..... (c) 32 

8/31/79 3/21/84 49 FR 10542 ..... (c) 32 

10/31/89 10/18/91 56 FR 52205 ..... (c) 58

8/23/96 10/19/00 65 FR 62624 ..... (c)(84) 

8/22/12 77 FR 50595 ....(c)(100)

4/29/10 6/9/14 79 FR 32873

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Synthetic Organic Chemical Control of Volatile Organic Compound 22a-174-20(x) Control of Volatile Regulatory requirements are consistent 
18

CTG Category CTG Document Applicable Connecticut 

Regulation.

SIP Approval of Connecticut 

Regulation or Negative 

Declaration

Adopted by State/ Approved by EPA/ 

FR Cite/ 52.370

Comments

Emissions from Air Oxidation

Processes in Synthetic Organic 

Chemical Manufacturing Industry, 

EPA-450/3-84-015, December 1984. 

AND

SOCMI Distillation and Reactor Processes CTG 

(EPA 450/4-91-031, August 1993).

Organic Compound Leaks from 

Synthetic Organic Chemical & Polymer 

Manufacturing Equipment.

2/2/87 5/19/88 53 FR 17934 ..... (c) 38

10/31/89 10/18/91 56 FR 52205 ..... (c) 58 

AND

40 CFR § 52.375 (c) Certification of 

no Air Oxidation 

Processes/SOCMI.sources

40 CFR § 52.375 (e) Certification of 

no sources of Synthetic Organic 

Chemical Manufacturing Industry 

(SOCMI) distillation. 

40 CFR § 52.375 (f) Certification of 

no sources of Synthetic organic 

chemical manufacturing industry 

(SOCMI) reactor vessels

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Tanks Control of Volatile Organic Emissions from 

Storage of Petroleum Liquids in Fixed Roof 

Tanks, EPA-450/2-77-036, December 1977

AND

Control of Volatile Organic Emissions from 

Petroleum Liquid Storage in External Floating 

Roof Tanks, EPA-450/2-78-047, December 

1978. 

22a-174-20(a) Storage of “volatile 

organic compounds” and restrictions 

for the Reid Vapor Pressure of 

gasoline.

22a-174-20(c) “Volatile organic 

compound” water separation.

8/31/79 12/23/80 45 FR 84769 ...(c) 11 

9/24/83 3/21/84 49 FR 10542 .... (c) 32 

12/13/84 7/18/85 50 FR 29229 .. (c) 34 

12/30/88 6/2/89 54 FR 23650 .... (c) 50 

10/31/89 10/18/91 56 FR 52205 (c) 58 

03/07/2014

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 

Tank Trucks Control of Hydrocarbons from Tank Truck 

Gasoline Loading Terminals, EPA-450/2-77-

026, December 1977.

AND

Control of Volatile Organic Compound Leaks 

from Gasoline Tank Trucks and Vapor 

22a-174-20(b) Loading of gasoline and 

other volatile organic compounds.

8/31/79 12/23/80 45 FR 84769 ..... (c) 11

9/24/83 3/21/84 49 FR 10542 ..... (c) 32 

12/13/84 7/18/85 50 FR 29229 ..... (c) 34 

10/31/89 10/18/91 56 FR 52205 ..... (c) 58

4/1/98 10/19/00 65 FR 62624 ..... (c)(84)

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 
19

CTG Category CTG Document Applicable Connecticut 

Regulation.

SIP Approval of Connecticut 

Regulation or Negative 

Declaration

Adopted by State/ Approved by EPA/ 

FR Cite/ 52.370

Comments

Collection Systems, EPA-450/2-78-051, 

December 1978. 

Wood Coating Control Techniques Guidelines for Flat Wood 

Paneling Coatings (PDF 27 pp, 212KB) EPA453/R-06-004-2006/09

Not Applicable Negative declaration of sources of 

surface coating of flat wood 

paneling.

Connecticut reaffirms that no sources 

meeting the description of this CTG 

category are operating within the State.

Wood Furniture Wood Furniture (CTG-MACT) - draft MACT out 

5-94; Final CTG, EPA-453/R-96-007, April 

1996; see also 61 FR 25223, and, 61 FR 50823, 

September 27, 1996.

22a-174-32 Reasonably Available 

Control Technology (RACT) for volatile 

organic compounds.

11/18/93 3/10/99 64 FR 12024 ..... (c)(76)

8/27/99 10/19/00 65 FR 62624 ..... (c)(84) 

Regulatory requirements are consistent 

with the CTG and represent RACT under 

the 2008 8-Hour Ozone NAAQS. 
B. Major non-CTG sources of NOx and VOC

According to the draft 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 defined in 

CAA Section 302, as modified by Sections 182(b), (c), (d) or (e) of the CAA, as applicable to the classification of 

the nonattainment areas in which a stationary source is located. Additionally, Connecticut is in the OTR and 

subject to CAA Section 184. Therefore, because Connecticut is in the OTR and classified as marginal 

nonattainment for the 2008 ozone NAAQS, the term “major source” for the purposes of this review is limited to 

facilities that have the potential to emit (PTE) 100 tons per year or more of NOx or 50 tons per year or more of 

VOC.

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

lowest achievable emissions rate (LAER), best available control technology (BACT) and maximum achievable 

control technology (MACT). LAER, applicable to new and modified major sources located in nonattainment areas, 

is the lowest achievable emission rate of the nonattainment 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, EPA has historically allowed states to rely on MACT standards 

for the purpose of showing that a source has met VOC RACT.21 BACT and LAER determinations are made prior 

to construction as part of the new source review (NSR) permitting process. Under the federal National Emissions 

Standards for Hazardous Air Pollutants, the requirement to implement MACT-based controls applies directly to 

owners of major sources of hazardous air pollutants. 

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, 

equal to or 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 has undergone one of these reviews, it is generally 

unlikely that the marginal reductions achievable through further control measures will be cost effective, unless 

existing control equipment may be optimized to meet a lower emission limit that has become RACT since the 

installation of the control equipment. Otherwise, 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 a reevaluation 

of 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 5 lists the major sources of NOx and VOC located in Connecticut. The list was obtained by reviewing the 

list of sources for which a Title V permit has been issued.22 Because the Title V major source thresholds are based 

on the more stringent attainment designations under the 1-hour ozone NAAQS, namely 25 tons per year PTE in 

Southwest Connecticut and 50 tons per year PTE in Greater Connecticut, the active Title V sources were reduced to 

only those sources with a potential to emit more than 50 tons per year of VOC or 100 tons per year of NOx.

Sources that are covered by a General Permit to Limit Potential to Emit (GPLPE) are not included on the list 

because the potential emissions of GPLPE sources are limited below 25 tons per year in Southwest Connecticut and 

50 tons per year in Greater Connecticut. In general, all major sources of NOx are regulated under RCSA section 

22a-174-22 while stationary sources of VOC are regulated by RCSA sections 22a-174-20 and 22a-174-32. RCSA 

section 22a-174-32 explicitly regulates major sources of VOC for the purpose of implementing RACT, and allows 

DEEP to conduct individual RACT analyses for sources. These regulations apply to major sources as that term was 

 21 Draft Implementation Rule at 34193. 22 The list of active title V permits is available on DEEP’s website: 

http://www.ct.gov/deep/cwp/view.asp?a=2684&q=322176&deepNav_GID=1997
21

defined for the 1-hour ozone NAAQS non-attainment classifications. These thresholds apply to both VOC and 

NOx sources and are at least as stringent as the respective 50 and 100 tpy thresholds that apply under the current 

classification of marginal 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. 

In addition, many of the sources listed in Table 5 are subject to a NSR permit and have therefore been required to 

implement BACT or LAER levels of control, as appropriate to the source at the time of determination. 

Furthermore, Connecticut requires top-down BACT in its minor NSR program, thereby requiring even minor 

sources to be held to a control level that is at least equivalent to RACT. While some facilities listed in Table 5 

include older equipment that is subject to a registration rather than a NSR permit, RCSA sections 22a-174-20, -22 

and -32 apply to sources independent of the permitting status, thus ensuring that each source in Table 5 is subject to 

a level of control that was RACT at the time the requirements were adopted. 

EPA provides some guidance to states in the draft Implementation Rule for determining whether current 

requirements are still RACT for major stationary sources under the 2008 ozone NAAQS. EPA cautions states not 

to rely on older technical information when more recent information is available. The clearest instruction is as 

follows: “EPA generally considers controls that have been achieved in practice by other existing sources in the 

same source category to be technologically and economically feasible.”23 From this, DEEP understands that 

standards and NOx or VOC controls required by other states establish a presumptive RACT unless DEEP has 

information to establish that such standards or controls are not economically or technically feasible in Connecticut. 

EPA also notes that states have the discretion to require sources to meet requirements that are “beyond RACT.” A 

valid reason for beyond RACT requirements is that the resulting emissions reductions are necessary to provide for 

timely attainment of the ozone NAAQS. “Timely” means as expeditiously as practicable.24 

 23 Draft Implementation Rule at 34192. 24 Draft Implementation Rule at 34193. 
22

Table 5. Listing of the major sources of nitrogen oxides (NOx) and/or volatile organic compounds (VOC) located in 

Connecticut. 

MUNICIPAL WASTE COMBUSTOR SOURCES (MAJOR for 

NOx)

MAJOR SOURCES OF VOC DUE TO FUEL BURNING

Covanta Bristol, Inc. Algonquin Windsor Locks LLC

Covanta Projects of Wallingford, L.P. (formerly CRRA/Wallingford) Bridgeport Energy

CRRA/Mid-Connecticut Capitol District Energy Center

Covanta Southeastern Connecticut Company (formerly American RefFuel of Southeast Connecticut)CRRA/Mid Connecticut

Wheelabrator Bridgeport, L.P. Devon Power, LLC

Wheelabrator Lisbon Inc. Lake Road Generating

MDC

MAJOR SOURCES OF NOx (RCSA section 22a-174-22) Middletown Power LLC

Algonquin Gas Transmission Company, Cromwell Montville Power LLC

Allnex USA, Inc. (formerly Cytec Industries, Inc.) PSEG Power Connecticut LLC, Bridgeport Harbor Station

Bridgeport Energy LLC PSEG Power Connecticut LLC, New Haven Harbor Station

Connecticut Natural Gas Corporation University of Connecticut, Storrs

Electric Boat Corporation Wheelabrator Bridgeport, L.P.

Frito Lay Yale University/Central Power Plant

Hamilton Sundstrand

Kleen Energy Systems, LLC MAJOR SOURCES OF VOC SUBJECT TO MACT 

STANDARDS

Kimberly Clark Magellan Terminals Holdings, L.P. (Forbes Avenue Terminal)

Lake Road Generating Co, L.P. Magellan Terminals Holdings, L.P. (Waterfront Terminal)

MDC Motiva Enterprises, LLC, New Haven

Milford Power Co, LLC New Haven Terminal, Inc., East Haven

Norwalk Hospital New Haven Terminal, Inc., New Haven

Plainfield Renewable Energy LLC Sprague Operating Resources, LLC (formerly Motiva 

Enterprises, LLC), Bridgeport

Pratt & Whitney Div UTC, East Hartford

Pratt & Whitney, Middletown SOURCES SUBJECT TO VOC RACT ORDERS

PSEG Power Connecticut LLC, New Haven Harbor Station Evonik Cyro, LLC

ReEnergy Sterling Limited Partnership (formerly Exeter Energy) Kimberly-Clark

RockTenn CP, LLC (formerly Smurfit-Stone Container Corp.) Sikorsky Aircraft

Sikorsky Aircraft Corporation Hamilton-Sundstrand

University of Connecticut, Storrs Pratt & Whitney, East Hartford

U.S. Navy Sub Base

Yale University/Central Power Plant ADDITIONAL MAJOR VOC SOURCES

Yale School of Medicine aka Sterling Allnex USA, Inc. (formerly Cytec Industries, Inc.)

Bridgeport Insulated Wire Company

MAJOR SOURCES OF NOx CONDUCTING NOx TRADING 

UNDER A SIP-APPROVED PROGRAM (RCSA section 22a-174-

22)

Cray Valley USA, LLC (formerly Sartomer Company Inc.)

Algonquin Windsor Locks LLC Electric Boat Corporation

Capitol District Energy Center Gilman Brothers Company

Connecticut Jet Power, LLC Gulf Oil Limited Partnership

CRRA South Meadows Kingswood Kitchens

Devon Power, LLC RockTenn CP, LLC (formerly Smurfit-Stone Container Corp.)

Dominion Nuclear Connecticut, Incorporated Sikorsky Aircraft Corporation

Fusion Paperboard (formerly Cascades Boxboard) Stanley Works

Middletown Power, LLC Tegrant Diversified Brands, Inc.

Montville Power, LLC United Aluminum Corporation

Pfizer Inc. U.S. Navy Sub Base

PSEG Power Connecticut LLC, Bridgeport Harbor
23

Several federal rules apply to Connecticut’s major sources of NOx and VOC and require limitations on NOx or 

VOC. A few key programs are described below.

Clean Air Interstate Rule (CAIR)

Connecticut has participated in two distinct NOx Budget Programs (NBPs): the OTC NBP and the Federal NBP. 

Both programs were 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. 

Connecticut transitioned from the Federal NBP to the Clean Air Interstate Rule (CAIR) trading program as of the 

2009 ozone season. Although CAIR was vacated and remanded to EPA after a successful challenge heard by the 

D.C. Circuit Court of Appeals (North Carolina v. EPA, 531 F.3d. 896 (D.C. Cir. 2008)), EPA and others 

successfully petitioned the D.C. Circuit Court to revise the remedy and remand CAIR without vacatur. North 

Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. Dec. 23, 2008). EPA subsequently adopted the Cross State Air 

Pollution Rule (CSAPR) (76 FR 48208) but that program has not been implemented due to challenges in federal 

court. The Supreme Court of the United States heard oral arguments on December 10, 2013 regarding three issues 

in CSAPR and issued a decision validating CSAPR on April 29, 2014. How the Supreme Court decision will be 

implemented by EPA is not clear at this time. 

DEEP intends to maintain the emissions reductions from implementation of CAIR via state regulation, if necessary, 

if CSAPR is implemented, as Connecticut is not subject to the CSAPR. Many of Connecticut’s major sources of 

NOx are included in CAIR. 

Major Source Industrial, Commercial, Institutional (ICI) Boiler and Process Heater National Emission Standards 

for Hazardous Air Pollutants (NESHAP)

In December 2012, EPA finalized changes to the National Emission Standards for Hazardous Air Pollutants for 

Area Sources: Industrial, Commercial, and Institutional Boilers (subpart JJJJJJ), as well as the National Emission 

Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and 

Process Heaters (subpart DDDDD). EPA intends to grant petitions for reconsideration of certain issues for both 

major and area sources. EPA has indicated that the notice will be published in the Federal Register by September 

2014. There is no schedule, at this time, for completing reconsideration of the issues. 

The proposed revisions should have a minor impact on boilers located in Connecticut. There are forty-two 

boilers/process heaters located at eleven Connecticut facilities that are major sources of hazardous air pollutants 

(HAP) and subject to this rule. Six of these units are small boilers (capacities <10 MMBtu/hr) and five burn clean 

gaseous fuels only. These eleven boilers are only subject to work practice requirements. One boiler is designed to 

burn #2 oil only and would be subject to the emission limits for light liquid fuel under the proposal. The remaining 

major source boilers are capable of burning both liquid and gaseous fuel. Those boilers that burn only gaseous 

fuels are subject only to work practice requirements. Those major source boilers that burn any liquid fuel (with 

exceptions for periods of maintenance, operator training, testing of liquid fuel, gas curtailment or gas supply 

emergencies and units defined as solid-fuel burners), either alone or in combination with gaseous fuels, are 

considered liquid-fuel boilers and are subject to numeric limits. As such standards are MACT-based, VOC RACT 

is presumed to be met for such boilers.

Mercury and Air Toxics Standard (MATS)

The final MATS was published in the Federal Register on February 16, 2012 (77 FR 9304). One coal-fired boiler

and six oil-fired boilers are subject to MATS in Connecticut. Unless the oil-fired boilers increase operations such 

that the annual capacity factor exceeds 8% over a consecutive 24-month period after April, 2015, these oil-fired 

boilers will likely qualify for the limited use liquid oil-fired subcategory and not be subject to the HAP emission 

standards of MATS. However, Connecticut’s MATS subject coal-fired boiler and oil-fired boilers are subject to 

NOx emission limits in RCSA section 22a-174-22 and would be subject to any amended requirements in RCSA 

section 22a-174-22, as explained below. 
24

C. Issues for major sources of NOx

As a result of the review provided in Sections IV.A and IV.B of this document, DEEP has determined that the 

requirements for Connecticut’s CTG sources are established at a RACT level, and no further action is required. For 

the major non-CTG sources of VOC, DEEP has also determined that the current requirements are RACT, and no 

further action is required. For the major non-CTG sources of NOx, DEEP has determined that the requirements of 

two programs are no longer RACT, requiring further analysis of the options to revise the NOx control requirements 

to a RACT level. 

In the next section of this document, DEEP commits to perform the evaluation of Connecticut’s municipal waste 

combustor and fuel-burning source NOx requirements and to seek any regulatory revisions necessary to revise the 

control requirements to a RACT level. Before reviewing the two programs and the current control requirements 

established by the two programs, we identify concerns relevant to controlling NOx emissions from Connecticut’s 

major stationary sources, namely high electric demand days and planning timeframes. These concerns are related 

to Connecticut’s ability to attain the 2008 ozone NAAQS as expeditiously as practicable. 

High electric demand days

In the eastern United States, high electric demand days (HEDD) occur on the hottest days in summer. The demand 

for electricity increases primarily as a result of air conditioning. To meet the peak demand, the regional system 

operators call on additional electric generating units to operate. Both as a result of the operation of additional 

electric generating units, and due to the nature of the typical peak day generating unit, NOx emissions increase. 

This elevation in NOx emissions is a significant concern because the HEDD coincide with the highest monitored 

ozone levels, which often exceed the ozone NAAQS. The additional NOx emissions on these days exacerbate the 

ozone problem and are one of the keys, in conjunction with limitations on upwind state emissions, to solving 

Connecticut’s resistant ozone problem. 

A typical HEDD unit operates less than 50%, often much less, of the available time and typically emits at an 

uncontrolled level higher than 0.15 lbs/mmBTU. In Connecticut, HEDD units are comprised of aeroderivative 

turbines (FT4), simple cycle combustion turbines and load-following boilers (LFBs). All of the simple cycle 

combustion turbines have NOx emissions control equipment (i.e., water injection), while only a few of the 

aeroderivative turbines are controlled. In Connecticut, the load-following boilers emit significantly more NOx on 

HEDD than the turbines. 

DEEP reviewed the NOx emissions of the NOx Budget Program/CAIR units for 2005-2013, and the percent of the 

total NOx Budget Program/CAIR unit NOx from the load-following boilers and combustion turbines on the four 

highest HEDD in Connecticut for each year. This information is summarized in Figure 3. The load-following 

boilers were the highest emitters of NOx on the HEDD in each year. The load-following boilers’ contribution to 

total NOx ranged from 40.3% to 71.1% while the combustion turbines’25 contribution ranged from 1.2% to 24.6%. 

The traditional cost effectiveness ($/ton of NOx emitted) evaluation of controlling NOx emissions from the loadfollowing boilers and uncontrolled turbines will not address HEDD emissions because the addition of controls on 

existing units that operate infrequently will nearly always result in a cost of control that is not reasonable. For 

example, in 2010, sources using emission credit trading to comply with RCSA section 22a-174-22 were required to 

submit control technology evaluations including detailed descriptions of controls that are capable of reducing 

emissions to a rate or concentration that complies with the applicable limits of RCSA section 22a-174-22 without 

using NOx allowances or credits. The control technology evaluations included detailed cost information and an 

estimated schedule for installation and operation of controls. A summary of the results of the control technology 

evaluations is provided in Attachment 1. The resulting cost/ton figures indicate that these units may not be further 

controlled at a reasonable cost at this time.

 25 Turbines, for the sake of the percent contributions, means controlled aeroderivative turbines, controlled simple cycle 

turbines and uncontrolled aeroderivative turbines. 
25

Figure 3. NOx emissions from load-following boilers and uncontrolled FT4 aeroderivative turbines on the 

four highest HEDD in each year from 2005 to 2013. 

0

5

10

15

20

25

30

35

40

45

50

NOx Tons

LFB and Uncontrolled FT4 NOx Emissions on Highest 

Demand Days from 2005-2013

Uncontrolled 

FT4 Emissions

LFB Emissions

To reach attainment in the NY-NJ-CT nonattainment area, HEDD emissions need to be addressed in all three state 

portions of the area. DEEP recognizes that the appropriate approach to addressing HEDD emissions may differ in 

each state because the magnitude of emissions and type of units responsible for the emissions differs in each state’s 

portion of the area. Figures 4, 5 and 6 show the unit types emitting in each of the three states during a HEDD 

episode. New York is represented by 14 southern counties while Connecticut and New Jersey emissions are 

presented statewide. The magnitude of emissions differs from state to state: Connecticut averaged 18 tons of NOx 

per day, New Jersey averaged 52 tons per day and New York (downstate) averaged 126 tons per day. Among the 

peaking units in each state (Figures 4, 5, and 6 include all units that operate during the HEDD), Connecticut’s 

emissions are dominated by the load-following boilers, as explained above. New York and New Jersey’s emissions 

are dominated by turbines with an emission rate greater than 0.15 lbs/MMBtu, which are labeled as “dirty” turbines 

in Figures 4, 5 and 6. 
26

Coal (>0.2)

5%

Coal

(0.1-0.2)

0%

Coal

(<0.1)

0%

Combined

Cycle

3%

Dirty NG Boilers

(>0.15)

0%

Clean NG

Boilers

(<=0.15)

10%

Dirty

Residual/Other Oil,

Other Solid

(>0.15)

7%

Clean

Residual/Other Oil,

Other Solid

(<=0.15)

23%

Dirty Turbines

(>0.15)

51%

Clean Turbines

(<=0.15)

1%

Figure 4. Downstate NY CAMD NOx: June 20-21, 2012 Ozone Episode

(CAMD average of 126 tons each day)

Coal

(>0.2)

13%

Coal

(0.1-0.2)

14%

Coal

(<0.1)

13%

Comb Cycle

23%

Dirty NG Boilers

(>0.15)

6% Clean NG

Boilers

(<=0.15)

0%

Dirty Residual Oil

Boilers

(>0.15)

0%

Clean

Residual Oil

Boilers

(<=0.15)

5%

Dirty Turbines

(>0.15)

18%

Clean Turbines

(<=0.15)

7%

Petroleum

DryBott & Heater

Process Gas

1%

Figure 5. Statewide NJ CAMD NOx: June 20-21, 2012 Ozone Episode

(CAMD average of 52 tons each day)
27

Coal

(>0.2)

2%

Coal

(0.1-0.2)

29%

Coal

(<0.1)

0%

Combined

Cycle

10%

Dirty NG Boilers

(>0.15)

12%

Clean NG

Boilers

(<=0.15)

7%

Dirty Residual Oil

Boilers

(>0.15)

12%

Clean

Residual Oil

Boilers

(<=0.15)

23%

Dirty Turbines

(>0.15)

1%

Clean 

Turbines

(<=0.15)

2%

Tire-Fueled

Boilers

2%

Figure 6. Statewide CT CAMD NOx: June 20-21, 2012 Ozone Episode

(CAMD average of 18 tons each day)

In sum, to address Connecticut’s ozone nonattainment, and Connecticut’s good neighbor obligations to downwind 

states, peak day emissions must be reduced. Thus, “beyond RACT” measures may be warranted for HEDD units

on HEDD to meet the state obligation of attainment of the ozone NAAQS as expeditiously as possible. 

Planning 

Adequate timeframes for new emissions limitations are important to an orderly transition that takes into account 

regional electric reliability planning concerns and business budgeting and planning cycles. This consideration is 

another factor that may result in DEEP’s adoption of requirements that are beyond RACT for the 2008 ozone 

NAAQS, so that those requirements may represent mere RACT at the time of implementation. 

When reviewing requirements for categories of EGUs, DEEP understands that regional electric system reliability 

planning cycles must be taken into account. For instance, the owner of an older, inefficient, high emitting EGU 

may choose to shut down rather than add controls to comply with a new air quality limitation. However, if the 

regional system operator requires the EGU in question to continue to operate to meet system reliability 

requirements, the EGU owner will then need to also consider the cost of obtaining replacement power to meet its 

capacity commitment. Each year ISO New England Inc. conducts the Forward Capacity Auction (FCA) setting the 

capacity commitments three years in the future. The most recent FCA was held in February 2014 and set the 

capacity commitments for 2017-2018. DEEP must take this iterative commitment cycle into account in developing 

new requirements that regulate EGUs. Furthermore, an adopted regulation is necessary to provide certainty so that 

EGU and industrial source owners may plan for compliance. Mere discussions or plans for future control 

requirements do not provide the certainty necessary for businesses to budget and schedule the installation of 

controls or replacement of a unit, particularly in difficult economic times. 

While DEEP is now addressing the 2008 ozone NAAQS, DEEP is well aware that EPA intends to propose a new 

iteration of the ozone NAAQS in 2014 and finalize that new NAAQS in 2015. Regardless of Connecticut’s future 

ozone attainment status, as an OTR state Connecticut will again be required to review RACT and address any 

shortcomings in the 2020-2023 timeframe. Because DEEP prefers to allow for a thorough stakeholder process in 

the development of RACT requirements and given that the regulatory process in Connecticut is lengthy, it makes 

good sense for Connecticut to take a long view when seeking to adopt RACT emissions limitations, even if it 
28

means predicting what level of control will constitute RACT for a future ozone NAAQS. Thus, DEEP may take a 

phased approach to new standards, with an initial phase that is RACT followed by a beyond RACT future phase. 

D. Commitments for major sources of NOx

DEEP commits to perform further evaluation of Connecticut’s municipal waste combustor and fuel-burning source 

NOx requirements and to seek any regulatory revisions necessary to revise the control requirements to a RACT 

level for the 2008 ozone NAAQS. The main basis for the determination that these source categories are no longer 

subject to RACT is that other states now have in place emissions limitations that are more stringent than those 

required in Connecticut, so the more stringent emission limits, and the controls necessary to meet those emission 

limits, are technically and economically feasible. Furthermore, DEEP’s concern about HEDD and planning 

timeframes may also result in DEEP’s consideration of beyond RACT requirements, which DEEP would seek to 

establish in a regulation to meet the 2008 ozone NAAQS RACT requirement yet assign a future compliance date to 

such requirements. As DEEP intends to perform further analysis and work with stakeholders to develop such 

RACT or beyond RACT requirements, DEEP is not setting out precise emissions limitations or other requirements 

in this document. 

Municipal Waste Combustors

Connecticut has six facilities that burn municipal waste to create electricity and are comprised of a total of 15 units. 

Only three of the units are small municipal waste combustors, as defined by EPA in 40 CFR 60 Subpart AAAA and 

the associated emissions guidelines. Together, these 15 units are one of the most significant sources of NOx 

emissions in Connecticut. In 2011, the municipal waste combustor NOx emissions exceeded those of Connecticut’s 

electric generating sector to become the largest stationary source category of NOx emissions in Connecticut. These 

six facilities are regulated by RCSA section 22a-174-38, which is based on EPA’s emissions guidelines for 

municipal waste combustors promulgated under Sections 129 and 111(d) of the CAA. RCSA section 22a-174-38

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 municipal waste combustors. An October 26, 2000 amendment 

to RCSA section 22a-174-38 reduced the NOx emission limits beyond the 1999 levels for the purposes of attaining 

the 1-hour ozone NAAQS. The amended regulation and associated emissions reductions were approved by EPA on 

December 6, 2001 (66 FR 63311). 

In 2006, EPA promulgated amendments to the federal MACT-based emissions (71 FR 27324, May 10, 2006), and 

Connecticut’s revisions to RCSA section 22a-174-38 in response to the amendments were effective on July 7, 2008. 

The amended regulation was approved by EPA effective June 11, 2013 (78 FR 38587; April 12, 2013). When 

Connecticut’s most recent RACT SIP was submitted in 2006, DEEP indicated that the municipal waste combustor 

NOx limits were as stringent as the MACT-based 2006 EPA amendments to the emissions guidelines. 

Connecticut’s 2008 revisions to RCSA section 22a-174-38 designated an end to creation and use of emission 

reduction credits and updated the regulation in accordance with revisions to the large municipal waste combustor 

emissions guidelines promulgated on May 10, 2006.

To meet the current NOx emissions limits of RCSA section 22a-174-38, the owners of all of the large municipal 

waste combustors have installed selective non-catalytic reduction (SNCR). However, the current emissions limits 

do not require that the SNCR be operated at an optimal level. Improved boiler modeling to predict combustion 

temperature profiles, monitoring and computerized controls available since the initial use of this control technology 

to meet the 1995 40 CFR 60 Subpart Cb NOx emissions limits have made SNCR potentially more effective today.

In addition to SNCR optimization, Covanta has developed a Low NOx (LNTM) technology that, either alone or as 

an augmentation to SNCR, substantially reduces NOx emissions for traditional grate-based municipal waste 

combustor facilities. This system extends the combustion zone to effect staged combustion. The LNTM technology

involves no new reagents or materials that would potentially pose an adverse impact to the environment or a 

facility’s air emissions. Covanta first installed a test version of this system at the Bristol, Connecticut facility in 

2006, and that combustor has, since April of 2009, been operating continuously and achieving NOx emission rates 

of about 100 to 120 ppmvd @ 7% O2. Covanta Bristol has made the emission reduction at unit no. 1 enforceable 
29

by incorporating a NOx emission limit of 120 ppmvd into its air quality permits.26 Since developing the LNTM 

technology, Covanta has installed the process in more than 20 units in North America. 

Based on these observations, DEEP believes that it may be both technically and economically reasonable to reduce 

NOx emissions from the Connecticut municipal waste combustor facilities. The municipal waste combustor units 

at the Bristol facility, at which the LNTM technology has been installed, are mass burn waterwall units, which are 

the dominant combustor type in Connecticut.27 New Jersey has adopted, and Massachusetts has proposed to adopt, 

a NOx emissions limit for mass burn waterwall units that is more stringent than Connecticut’s emissions limit (see

Table 6). In addition, Massachusetts has proposed to adopt a NOx emissions limit for mass burn refractory units 

that is more stringent than Connecticut’s emissions limit (see Table 6). DEEP commits to investigate the cost and 

emissions reductions available from the municipal waste combustors and, if appropriate, initiate a stakeholder 

process to develop a regulatory amendment. DEEP would seek to move such an amendment through the regulatory 

adoption process to allow for adoption by December 31, 2016. 

 26 See NSR permit number 026-0026 as modified on August 29, 2010 and Title V operating permit number 026-0055-TV 

(August 4, 2010). 

27 Nine of Connecticut’s 15 municipal waste combustor units are mass burn waterwall units. Three units are refuse-derived 

fuel combustors. The three small municipal waste combustor units at the Wallingford facility are mass burn refractory units. 
30

Table 6. Federal and Several State Municipal Waste Combustor NOx Emissions Limits (24-hour average 

parts per million by volume dry basis (ppmvd) corrected to 7% oxygen)

Combustor type

40 CFR 60 

Subpart Cb

Large 

Municipal 

Waste 

Combustors

40 CFR 62

Subpart JJJ

Small 

Municipal 

Waste 

Combustors

RCSA 

section 

22a-174-38

New Jersey 

Admin. 

Code 

7:27-19.12

Massachusetts

310 CMR 

7.08(2) 

(Proposed)

Mass burn waterwall

constructed on or before 

December 31, 1985

205 No units in 

Connecticut

200 150 150

Mass burn waterwall 

constructed after 

December 31, 1985

205 No units in 

Connecticut

177 150 150

Refuse-derived fuel 

stoker

250 No units in 

Connecticut

146 n/a 146

Mass burn refractory No limit 350 177 n/a 125 (See 

proposed 310 

CMR 7.19)

Fuel-Burning Sources (Boilers, Turbines, Engines)

Revisions to the NOx emissions control requirements for boilers, turbines and engines in RCSA section 22a-174-22

are necessary to establish a RACT level of control under the 2008 ozone NAAQS. Several nearby states, including 

New York and New Jersey, have updated NOx RACT regulations, and other states, including Maryland, are 

currently reviewing existing NOx RACT requirements with respect to boilers, turbines and engines. The Ozone 

Transport Commission (OTC) has also recently reviewed the short-term NOx emissions limitations for fuel-burning 

equipment throughout the Ozone Transport Region in part to allow states to address emissions from demand 

response units and other units that operate intermittently to meet electric demand, particularly in the summer 

months. 

Table 7 provides some examples of current NOx emission limits in OTC states for general unit/fuel types. The 

most stringent limit in each general unit/fuel type category is included; the table is not comprehensive and the unit 

sizes/specific unit types amongst states may not be comparable. When assessing the stringency of emission limits, 

averaging times should be taken into consideration. All other factors being equal, if there are two emission limits 

with the same numerical value, but different averaging times, the emission limit with the shorter averaging time 

would be considered more stringent. 
31

Table 7. Examples of NOx Emission Limits in Some OTC States for the Identified Fuel and Unit Type.

General 

fuel/unit 

type

CT

5/31/95, 12/28/00 non-ozone 

season average lb/MMBtu 

unless noted

DE

1/1/2012 

(coal/residual 

oil boilers), 

11/24/93 all 

others

lb/MMBtu 

unless noted

MD

11/9/08

lb/MMBtu unless 

noted

ME

1/1/05

lb/MMBtu 

unless noted

NJ

On and after 5/1/15 (coal and residual oil 

boilers and turbines), 5/1/10 (distillate oil 

and natural gas boilers), 3/7/07 (engines)

lb/MMBtu unless noted

NY

On and after 7/1/14 

(boilers), 7/8/10 

(turbines and engines)

lb/MMBtu unless noted

PA

5/1/05 lb/MMBtu unless noted

RI

5/31/95

lb/MMBtu 

unless noted

Coal 

boilers 

0.38 (24-hr average by CEMS; 

average of three 1-hr tests by 

stack test); 0.15 (non-ozone 

season average), (RCSA section 

22a-174-22(e) Table 22-1, -

22(e)(3), -22(k)(1), -22(k)(4))

0.125 (rolling 

24-hr average),

(Regulation 

1146 4.3)

0.38 (30-day rolling 

average or averages of 

stack test duration),

(Regulation 

26.11.09.08B.(1)(c), 

26.11.09.08B.(2)(d) 

and (e))

0.15 (90 day 

rolling 

average),

(Chapter 145 

3.B.(2)(b))

1.50 lb/MWh (Calendar day over ozone 

season, 30-day over non-ozone season if 

CEMS, average of three 1-hr stack tests if no 

CEMS), (7:27-19.4 TABLE 3, 7:27-19.15(a))

0.12 (not including 

fluidized bed) (1-hr 

average unless CEMS 

(24-hr average)), (227-

2.4(a))

0.17 (1 year average emission rate

or maximum hourly permit rate if 

no CEMS), (129.201(c)(2), 

129.204(b))

No limit 

identified

Residual 

Oil 

boilers 

0.25 (24-hr average by CEMS; 

average of three 1-hr tests by

stack test); 0.15 (non-ozone 

season average), (RCSA section 

22a-174-22(e) Table 22-1, -

22(e)(3), -22(k)(1), -22(k)(4))

0.125 (rolling 

24-hr average),

(Regulation 

1146 4.3)

0.25 (30-day rolling 

average or averages of 

stack test duration),

(Regulation 

26.11.09.08B.(1)(c), 

26.11.09.08B.(2)(d) 

and (e))

0.15 (90 day 

rolling 

average),

(Chapter 145 

3.B.(2)(b))

2.00 lb/MWh (Calendar day over ozone 

season, 30-day over non-ozone season if 

CEMS, average of three 1-hr stack tests if no 

CEMS), (7:27-19.4 TABLE 3, 7:27-19.15(a))

0.20 (1-hr average 

unless CEMS (24-hr 

average)), (227-2.4(c))

0.17 (1 year average emission rate

or maximum hourly permit rate if 

no CEMS), (129.201(c)(2), 

129.204(b))

0.25 (24-hr 

average),

(Regulation 

27.4.1, 27.5.4)

Distillate 

Oil 

boilers 

0.20 (24-hr average by CEMS; 

average of three 1-hr tests by 

stack test); 0.15 (non-ozone 

season average), (RCSA section 

22a-174-22(e) Table 22-1, -

22(e)(3), -22(k)(1), -22(k)(4))

0.25 (rolling 

24-hr average),

(Regulation 12 

Table I)

0.25 (30-day rolling 

average or averages of 

stack test duration),

(Regulation 

26.11.09.08B.(1)(c), 

26.11.09.08B.(2)(d) 

and (e))

0.15 (90 day 

rolling 

average),

(Chapter 145 

3.B.(2)(b))

0.08 (Calendar day over ozone season, 30-

day over non-ozone season if CEMS, average 

of three 1-hr stack tests if no CEMS), (7:27-

19.7 TABLE 9, 7:27-19.15(a))

0.08 (1-hr average 

unless CEMS (24-hr 

average)), (227-2.4(c))

0.17 (1 year average emission rate

or maximum hourly permit rate if 

no CEMS), (129.201(c))(2), 

129.204(b))

0.12 (1-hr 

average),

(Regulation 

27.4.2, 27.5.5)

Natural 

gas 

boilers 

0.20 (24-hr average by CEMS; 

average of three 1-hr tests by 

stack test); 0.15 (non-ozone 

season average), (RCSA section 

22a-174-22(e) Table 22-1, -

22(e)(3), -22(k)(1), -22(k)(4))

0.20 (rolling 

24-hr average),

(Regulation 12 

Table I)

0.20 (30-day rolling 

average or averages of 

stack test duration),

(Regulation 

26.11.09.08B.(1)(c), 

26.11.09.08B.(2)(d) 

and (e))

0.15 (90 day 

rolling 

average),

(Chapter 145 

3.B.(2)(b))

0.05 (Calendar day over ozone season, 30-

day over non-ozone season if CEMS, average 

of three 1-hr stack tests if no CEMS), (7:27-

19.7 TABLE 9, 7.27-19.15(a))

0.05 (1-hr average 

unless CEMS (24-hr 

average)), (227-2.4(c))

0.10 (1 year average emission rate

or maximum hourly permit rate if 

no CEMS), (129.201(c)(1), 

129.204(b))

0.10 (1-hr 

average),

(Regulation 

27.4.2, 27.5.5)

Oil-fired 

Simple 

Cycle 

Turbines

75 ppmvd (24-hr average by 

CEMS; average of three 1-hr 

tests by stack test); 0.15 (nonozone season average), (RCSA 

section 22a-174-22(e) Table 22-

1, -22(e)(3), -22(k)(1), -22(k)(4))

88 ppm (1-hr 

average),

(Regulation 12 

Table II)

No limit identified No limit 

identified

1.60 lb/MWh (Calendar day over ozone 

season, 30-day over non-ozone season if 

CEMS, average of three 1-hr stack tests if no 

CEMS), (7:27-19.5 TABLE 7, 7:27-19.15(a))

100 ppmvd (1-hr 

average unless CEMS 

(24-hr average)), (227-

2.4(e))

0.17 (1 year average emission 

rate or maximum hourly permit 

rate if no CEMS), (129.202(c)(2), 

129.204(b))

No limit 

identified

Gas-fired 

Simple 

Cycle 

Turbines

55 ppmvd (24-hr average by 

CEMS; average of three 1-hr 

tests by stack test); 0.15 (nonozone season average), (RCSA 

section 22a-174-22(e) Table 22-

1, -22(e)(3), -22(k)(1), -22(k)(4))

42 ppm (1-hr 

average),

(Regulation 12 

Table II)

No limit identified No limit 

identified

1.00 lb/MWh (Calendar day over ozone 

season, 30-day over non-ozone season if 

CEMS, average of three 1-hr stack tests if no 

CEMS), (7:27-19.5 TABLE 7, 7:27-19.15(a))

50 ppmvd (1-hr average 

unless CEMS (24-hr 

average)), 227-2.4(e))

0.17 (1 year average emission rate

or maximum hourly permit rate if 

no CEMS), (129.202(c)(2), 

129.204(b))

No limit 

identified

Lean 

burn oilfired 

engines

8 gm/bk hp-hr (24-hr average 

by CEMS; average of three 1-hr 

tests by stack test), (RCSA 

section 22a-174-22(e) Table 22-

1, -22(k)(1), -22(k)(4))

No limit 

identified

No limit identified No limit 

identified

2.3 grams/Bhp-hr (Calendar day over ozone 

season, 30-day over non-ozone season if 

CEMS, average of three 1-hr stack tests if no 

CEMS), (7:27-19.8 TABLE 10, 7:27-19.15(a)) 

2.3 grams/Bhp-hr (1-hr 

average unless CEMS 

(24-hr average)), (227-

2.4(f))

2.3 grams/Bhp-hr (1 year average 

emission rate or maximum hourly 

permit rate if no CEMS), 

(129.203(c)(2), 129.204(b))

9.0 grams/bhphr (1-hr 

average),

(Regulation 

27.4.3, 27.5.5)
32

Based on the comparison of Connecticut’s NOx emissions limitations with those in other states as set out in Table 

7, reductions in the emissions limitations of RCSA section 22a-174-22 are necessary, likely in conjunction with an 

elimination or adjustment of the NOx credit trading program, so that Connecticut’s boilers, turbines and engines are 

controlled to a RACT level with respect to the 2008 ozone NAAQS. 

The use of emissions trading to comply with RCSA section 22a-174-22 initially allowed for more stringent 

emission limits that resulted in significant system-wide reductions. Recognizing this benefit, DEEP offered 

emissions trading as a compliance mechanism in RCSA section 22a-174-22 beginning in 1995. Some emissions 

units use credits to comply with the emissions limitations because the units cannot operate in compliance. 

However, several units at Bridgeport Harbor Station, Middletown Power LLC, Montville Power LLC and Pfizer

Inc. have over-controlled and/or burn lower emitting fuels, which allows these sources to generate credits. While 

the combination of emissions limits and trading initially lead to significant system-wide emission reductions 

throughout Connecticut in 1995, the efforts to “over-control” to generate credits are now merely RACT in many 

other states. DEEP must therefore consider elimination of the single source emissions trading program, as well as 

more stringent emission limits, to meet current RACT levels and realize additional reductions in Connecticut 

emissions. 

DEEP commits to begin a review of NOx emissions and emissions controls for the sources now subject to RCSA 

section 22a-174-22 with the goal of developing changes to RCSA section 22a-174-22 sufficient to satisfy RACT 

under the 2008 ozone NAAQS. The evaluation and regulation development will be performed in conjunction with 

a stakeholder workgroup and will commence in 2014. To address emissions on HEDD and to provide a long 

planning horizon, DEEP may also consider beyond RACT requirements, particularly to address emissions over 

short timeframes as opposed to a 30-day average or ozone season average requirement. DEEP would seek to move 

such an amendment or replacement regulation adoption through the regulatory adoption process to allow for 

adoption by December 31, 2016. 

V. Conclusion

Connecticut’s programs to reduce NOx and VOC emissions are being implemented successfully, resulting in 

reduced emissions throughout the state and available to be transported downwind. DEEP continues to take action 

to develop local and regional control measures and influence national strategies to further reduce ozone levels as 

necessary to attain and maintain the 2008 8-hour ozone NAAQS and to address the ozone NAAQS expected in 

2015. 

Based on emissions statements submitted by Connecticut’s Title V sources in 2013, municipal waste combustors 

and EGUs together are responsible for more than 70% of the stationary source NOx emissions in Connecticut. 

DEEP acknowledges that emissions limitations required of these sources in other states are more stringent than 

those now required in Connecticut. DEEP has committed in this document to evaluate additional NOx reductions 

appropriate to fuel-burning sources now regulated under RCSA section 22a-174-22 and additional NOx emissions 

reductions from the municipal waste combustors regulated by RCSA section 22a-174-38, and to work to adopt 

regulatory requirements, as may be appropriate, based on the results of the evaluation. With regard to the control of 

VOC emissions, all of Connecticut’s CTG sources and major non-CTG sources are now controlled by RACT or 

better controls, and Connecticut’s RACT requirement has been satisfied for these source categories for the 8-hour 

ozone NAAQS.