Attachment 1 Text of Revision as Proposed State Implementation Plan Revision 

### 8-Hour Ozone Reasonably Available Control Technology State Implementation Plan Analysis for the State of Connecticut September 1, 2006

### 8-Hour Ozone Reasonably Available Control Technology State Implementation Plan Analysis for the State of Connecticut

Connecticut Department of Environmental Protection

Bureau of Air-Management September 1, 2006Table of Contents

Summary. . . . . .. . . . . . . . . . . . . . . . . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 RACT Overview

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2 Regional and State Efforts to Limit Ozone Precursor Emissions. . . . . . . . . . . . . . . . . . . . . . . . . . . . ..3 A . Regional Efforts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... .3 B. State Efforts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5 Connecticut's RACT Analysis for CTGand Major Non-CTGSources. . . . . . . . . . . . . . . . . . . ., .( A . CTGCategory Sources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7 B . MajorNon-CTGSources of NOx and VOC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9 Conclusion. . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12 References. . . . . . . . . . . . . . . . . . . . . . . . .I

. . . . . . . . . . . . . . . . . . . . . . .. . .. . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22 Tables and Figures Table 1. OTCRecommended Control Strategies. . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..4 Table 2 . Connecticut's Ozone Precursor Emissions. . . . . . . . . . . . . . . . . . . . . . ., ., . . . ., . . ,( Table 3. CTGCategories. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14 Table 4. Major Non-CTGSources. . . . . . . . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .19 Figure 1 . Connecticut VOCEmission Trends. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..5 Figure 2 . Connecticut NOx Emission Trends. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...5 Figure 3. Connecticut Ozone Exceedance Day Trends with Control Strategies. . . . . . . . . . . . . 13

### SUMMARY

In satisfaction of the reasonably available control technology (RACT) requirements of Sections 172(c)(1) and 182 of the Clean AirAct (CAA) for the 8-hour ozone national ambient air quality standard (NAAQS), the Connecticut Department of Environmental Protection (CTDEP) has reviewed, and here documents, specific control measures, including those already in place under the 1-hour ozone NAAQS, required of the major nitrogen oxides (NOx) andvolatile organic compound (VOC) emitting sources and of all sources and source categories addressed in control techniques guidelines (CTGs) . As a result of a long andsuccessful history of implementing aggressive local and regional controls to reduce emissions of NOx andVOCs, CTDEPnow applies levels of control that meet or exceed RACT to a broad range of source categories including thoseforwhich RACT is not federally required. Thus, CTDEPconcludes that controls on all relevant stationary sources of NOx andVOCemissions meet or exceed CAA RACT requirements.

### I . RACT OVERVIEW

OnJune 15, 2004, Connecticut's designation as non-attainment for the 8-hour ozone NAAQS became effective. This designation resulted froma change in the standard from0.12 ppm averaged over one hour to 0.08 ppm

averaged over eight hours. The entire statewas classified as moderate nonattainment. Under the 1-hour ozone NAAQS, the southwest portion of Connecticut was classified severe non-attainment whilethe rest of the State was classified serious non-attainment . These prior classifications, established under the 1-hour NAAQS, carried with themmore stringent requirements for reducing emissions of ozone precursors under the CAAthan does the current moderate classification. The Environmental Protection Agency (EPA) revoked the 1-hour ozone NAAQS effective June 15, 2005, prior to Connecticut's projected 1-hour ozoneattainment date of June 2007. Having been designated non-attainment for the 8-hour ozone NAAQS, Connecticut is required to transition its planning efforts to attainment of the 8-hour ozone NAAQS byJune 2010 . The transition is being conducted in accordance with guidance set forth by EPAin the "Final Rule To Implement the 8-Hour Ozone National Ambient Air Quality Standard" [the implementation Rule: 70FR 71612] published on November 29, 2005. The Implementation Rule requires a state to apply all reasonably available control measures (RACM) that will assist the state in timely attainment of the ozone standard. RACM are those readily implemented measures that are economically and technologically feasible andthat contribute to the advancement of attainment. Determining RACM requires an area-specific analysis. The State is required to consider RACM for any source of VOCs or NOx that occur in the state. The plan to implement these RACM is dueJune 15, 2007, together with the demonstration of attainment. Asubset of RACM

are the reasonably available control technology (RACT) requirements. EPAhas defined kACT 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 [44FR53762; September 17, 1979] . Unlike RACM, RACT is limited to sources for which EPA has developed Control Technique Guidelines (CTGs) and the major non-CTGsources. As the analytical work for implementing the CTGs is readily available, and because the RACT sources are a priori asignificant focus for implementing control strategies, EPAexpects requirements limiting emissions fromRACT sources to be addressed mote immediately than the other control options. Under the CAA, Connecticut is to submit a state implementation plan (SIP) demonstrating that RACT levels of control are required of all CTGsources and major non-CTGsources of NOx and VOC . This RACT SIP is due to EPAon September 15, 2006 . Thestate is to require sources to implement RACT no later than May 1, 2009.

### II . REGIONAL ANDSTATE EFFORTS TOLIMIT OZONE PRECURSOR EMISSIONS

This document includes in section III a detailed description and analysis of Connecticut's RACT controls for CTGsources and major non-CTGsources of NOx and VOC . To put that analysis in perspective, we first describe in this section, the regional and state efforts that have established RACT and beyond RACT levels of control for Connecticut sources. 

### A. REGIONAL EFFORTS The 1990CAAamendments recognized the significant role of interstate transport of NOx and VOCs in influencing theability of a downwind state to attain the ozone NAAQS. As part of that recognition, the United States Congress established the OzoneTransport Commission (OTC) to help coordinate control plans for reducing ground-level ozone in the Northeast and Mid-Atlantic states. As a member of the OTC, Connecticut has workedjointly with the other eleven member states and the District of Columbia to assess the nature and magnitude~of the ozone problemin the region, evaluate potential new control approaches and recommend regional control measures to ensure attainment and maintenance of the ozone NAAQS. This regional approach recognizes that all states benefit fromcoordinated attainment planning efforts to reduce ozone precursors. Connecticut has, in part, relied on this regional effort to determine if thecurrent RACT controls implementedto meet our 1-hour ozone NAAQS obligations continue to represent RACT for the 8- hour NAAQS. The regional effort encompassed the goal of attainment with the 8-hour NAAQS together with compliance with the Clean Air Interstate Rule (CAIR), the fine particulate (PM2.5) NAAQS, and the federal regional haze requirements. The regional process therefore considered a broader category of sources than the RACT sources (major and CTG) and anticipated controls more stringent than RACT. The OTCstaff and member states formed several workgroups to identify and evaluate candidate control measures. Initially, the workgroups compiled and reviewed a list of over 1,000candidate control measures. These control measures were identified through published sources such as EPA's Control TechniqueGuidelines, STAPPA/ALAPCO"Menu of Options" documents, the AirControlNET database, emission control initiatives in other states including California, state/regional consultations, andstakeholder input. Theworkgroups developed a preliminary list of approximately fifty candidate control measures to be considered for more detailed analysis with respect to the potential for emissions reductions, cost effectiveness, andease of implementation [MACTEC, 2006] . Thus, these measures were anticipated to be most effective in reducing ozone air quality levels in the Northeastern and Mid-Atlantic States. Based on the analyses presented by the OTCworkgroups, the OTC Commissioners made several recommendations at the June 2006 Commissioner's meeting in Boston [OTC2006a, OTC 2006b, OTC 2006c and OTC2006d] . The Commissioners recommended that States pursue emission reductions from the following source categories:Table 1. Control measures recommended by the OTCto pursue as regional ozone attainment measures and the

status of Connecticut's efforts toward measure implementation. VOCControl Measures Connecticut Status of Control Measure Implementation in regulation (if Connecticut applicable) Reformulation of Consumer New R .C.S .A. The Connecticut regulation adoption process is now Products section 22a-174-40 underway. Apublic hearing was held on a proposed new state reg ulation on June 27, 2006. Design Improvements to Amendment of TheConnecticut regulation amendmentprocess is now Portable Fuel Containers R .C.S.A. section underway. Apublic hearing was held on a proposed 22a-174-43 amendment to an existing regulationon June 27, 2006. Restrictions on Asphalt used Amendment of Amendment ofexisting Connecticutregulation now under for Paving Operations R .C.S .A . section development. 22a-174-20(k) Restrictions on the New R .C.S.A. New Connecticut regulation now under development. Manufacture and Use of section 22a-174-44 Adhesives and Sealants Regional Fuel (Reformulated Not applicable Federal Phase II RFGin place statewide since 2000. Gasoline) NOx Control Measures Reductions in theSulfur Connecticut Public Reduction in heating oil fuel sulfur content will occur when Content of Heating Oil to Act 06-143 such reductions are effective in surrounding states. Improve Combustion and Reduce NOx Emissions Emissions Limitations and Amendment of The Connecticut regulationamendment process is now Operation Practices for R .C.S.A. section underway. Industrial Commercial and 22a-174-22 Institutional Boilers Standards forCement Kilns Notapplicable No applicable sources in Connecticut. Standards for Glass Furnaces Not applicable No applicable sources in Connecticut. Standards for Asphalt Plants TBD OTCoutline of requirements under developm ent. Standards forElectric TBD OTC Model Rule development continuing. Generating Units Diesel Truck Chip Reflash TBD Regional approach under development. Standards forRefineries Not applicable No applicable sources inConnecticut. Standards for Municipal R .C.S .A. section Existing rule consistent with OTCrecommendation and Waste Combustion 22a-174-38 2006 federal MACT revision (71'FR27324, May 10, 2006] with res ect to NOx. NOTE:_Alink to CTDEP's proposed regulations can be found at: http://www .dep .state.ct.us/air2/reQs/index.htm under the heading of "Proposed State Regulations" . The complete final regulations for the abatement ofair pollution can be found at: htt ://www .de .state.ct.us/air2/re s/mainre s.htm . Details of the OTCregional model rules and control measures identified in Table 1 can be found at the OTCwebsite: http://www .otcair.org. Though the goal of the OTCprocess was to find control measures that the states could readily implement andwould result in the greatest regional gains, the OTCprocess encompassed sources and measures that went beyond RACT. Therefore, not all of the selected measures are RACT eligible, either becausethey are not directed at major stationary sources, or at the CTGsources. Thus, for example, diesel chip reflash, the reprogramming of the pollution control module on diesel truck engines, is not RACT eligible because it is directed at a mobile source category which is not a CTG category. -4-Connecticut has already adopted, or is in the process of adopting some of these control measures as

part of its 8-hour ozone attainment plan. Those measures forwhich rule adoption is now proceeding are identified in Table 1 . Table 1 also indicates those control measures with no applicability to Connecticut or for which development at the regional level continues. 

### B. STATE EFFORTS Connecticut has a long history of implementing local and regional control measures to reduce NOx and VOCemissions to meet our 1-hour ozoneattainment obligations. Under the 1-hour ozone NAAQS, Connecticut was divided into twonon-attainment areas classified as "serious" and "severe" . Theseclassifications carried more stringent requirements than the 8-hour ozone NAAQS "moderate" non-attainment classification, which applies statewide. Among the more stringent requirements are the lower major source thresholds. Under the 1-hour ozone NAAQS, the major source thresholds for NOx and VOCwere set at 25 tons peryear (tpy) in thesevere area and at 50 tpy in the serious area. Under anti-backsliding provisions, Connecticut is committed to retain these more stringent major source thresholds in implementing its current programs. However, for the purpose of this document anddemonstrating that RACT is satisfied, we address only those major sources as required under the 8-hour "moderate" classification and associated thresholds, namely 50 tpy VOCand 100tpy NOx. Evaluation ofefforts implementedto reduce ozone precursor emissions and their success in meeting that goal is an ordinary and necessary component of the attainment planning cycle. As part of that cycle, for the 1-hour ozone NAAQS, CTDEPprepared a Mid-Course Review to document Connecticut's success in reducing ambient ozone levels. Figures 1 and 2 fromthat Mid-Course Review showthe dramatic reductions in VOCand NOx emissions obtained and projected from1990 through 2007 by control measures already in place. ProjectedAnthropogenicVOCEmission Trends for Connecticut

+e90voc 2007voc Projected NOx Emission Trends for Connecticut

teeo 2007 NOx NOx CI PaiM " Area ON -d OOn- .oad

. I I ©Pant /Amp pNonroad 130 .40" From"Mid-Course Review", CTDEP, January 10, 2005.Despite Connecticut's noteworthy success in reducing emissions of ozone precursors, it important to

recognize the limits of obtaining additional emissions reductions fromthese sources to reduce ambient ozone levels. Acomparison of contributions fromall sources in the Connecticut inventory is instructive. Table 2 shows the total VOCand NOx emissions fromthe thirteen major categories of emissions (Tier 1 Source Categories)

. These categories include all anthropogenic sources included in the 2002 National Emissions Inventory (NEI) . Note that biogenic sources in Connecticut are estimated to emit an additional 55,980tons ofVOCannually. Thus 264,729 tons of VOCwere emitted statewide in 2002. Table 2 . Connecticut State Emissions Summary by Tier 1 Source category (NEI 2002) .

2002 Annual NEI E missions Tier Category t-TPY) VOC NOx 01 Fuel Comb . Elec . Utility 253 02 Fuel Comb . Industrial 167 03 Fuel Comb . other 82,774 04 Chemical & Allied Product Mfg 3,576 05 Metals Processing 0 06 Petroleum & Related Industries 0 07 Other Industrial Processes 1,328 08 Solvent Utilization 53,259 09 Storage & Transport 5,433 10 Waste Disposal & Recycling 2,203 11 Highway Vehicles 30,911 12 Off-Highway 28,534 14 Miscellaneous 309 TOTALS : 'r . : ..it. . . . . . .. 6,225 2,786 13,543 1 28 0 0 26 3 3,973 64,028 23,173 11 208,749 113,796

From : httn ://www

.emissionsonline org/nei2002/state/ct/stcttl htm accessed on June 28, 2006 . Note : According to the Connecticut 2002 inventory an additional 55,980 tons per year of VOC are emitted from biogenic sources . overstated. Significant reductions from sources in to attain and maintain the ozone NAAQS. upwind states Connecticut's major stationary sources of NOx emitted less than 12,000 tons according to the 2002 state inventory. These stationary sources account for approximately ten percent of the NOx emissions inventory. Connecticut's major stationary sources of VOCemitted approximately 1500tons according to the 2002 inventory. This amounts to approximately one percent of the statewide total annual VOCemissions. Thus, opportunities for Connecticut to reduce ambient ozone levels through control of its major stationary sources areseverely limited. The importance of mobile and area source emissions, and, in particular, emissions transported fromother states cannot be arecrucial to Connecticut's ability 

### III . CONNECTICUT'S RACTANALYSIS FOR CTGAND MAJOR NON-CTGSOURCES Section 182 of the CAA sets forth two separate RACT requirements for ozone non-attainment areas. The first requirement, the RACT "fix-up", calls for the state to correct RACT rules for which EPA identified deficiencies before the CAA was amended in 1990 . Connecticut has no such deficiencies to correct. The second requirement calls for the state to implement RACT controls on all major VOC and NOx emission sources and on all sources and source categories covered by an EPApublished CTG, the presumptive normestablishing RACT fofthe covered sources. EPA has also documented alternative control techniques (ACTs) to serve as guidance for controls of VOCand NOx emissions fromstationary sources. The ACTs describe control techniques and their cost effectiveness, but unlike the CTGs, they do not define RACT. A complete list of the CTGs and ACTs can be found at EPA's website: httU://www .epa.Qov/ttn/naaq5/ozone/ctg act/index .htmConnecticut andother states previously designated non-attainment under the 1-hour ozone NAAQS,

already have rules in place to reduce emissions of VOCand NOx for attainment purposes. Recognizing that additional controls may only achieve small incremental emission reductions that are not cost effective, the Implementation Rule allows states to reviewand certify that RACT controls implemented under the 1-hour ozone NAAQS continue to represent RACT under the 8- hour NAAQS. Such a reviewandcertification follows. In addition, in anticipation of the submission of Connecticut's 8-hour ozone NAAQS attainment demonstration in June 2007, an overviewof some of the measures Connecticut has developed, or is considering, to satisfy the CAA's RACM requirement for the 8-hour ozone NAAQS is also provided. 

### A. CTGCategory Sources For sources for which a CTGhas been published, RACT is considered met if astate imposes controls equivalent to the CTGfor that source or source category. Table 3 (attached) lists thecurrent CTG documents and identifies the corresponding regulations that'Connecticut has adopted to achieve emissions reductions equivalent to the CTGs. Table 3 also includes theeffective dates of thestate regulations and thedate of SIP approval . As explained further below, Connecticut reasserts that these regulations are consistent with the CTGs, or where appropriate, recertifies that the source category does not exist within the state. CTDEPhas addressed the majority of the CTGsource categories and requirements through three sections of the Regulations of Connecticut State Agencies (R.C.S.A.) : 22a-174-20 (Section 20) ; 22a174-30 (Section 30) and 22a-174-32 (Section 32) . Section 20, for thecontrol of organic compound emissions, was first promulgated in the early 1970's and has undergone numerous revisions since. Section 20 generally contains the requirements for thesource categories covered by the CTGs established prior to 1990 . After the Clean AirAct Amendments of 1990, EPApromulgated additional CTGs and Connecticut updated its VOCRACT rules with the implementation of RCSA §22a-174-32 (Section 32) . Section 32, entitled "Reasonably Available Control Technology for Volatile Organic Compounds", includes control measures for additional CTGcategories andfor major sources of VOC

. Section 32 wasfirst promulgated in 1993 and was revised again in 1999. The CTGcategory for Stage IVapor Recovery, as well as for Stage II, is implemented through RCSA §22a-174-30 (Section 30) . Section 30 is entitled "Dispensing of Gasoline/Stage I and Stage II Vapor Recovery" and was implemented in late 1992 and revised in 2004. The most recent revision to Section 30is currently under EPAreview . Connecticut regulations for the CTGsources areconsistent with the CTGdocuments and therefore meet the RACT requirements. However, individually and through its proceedings with the OTC, Connecticut has concluded that twoof these categories are appropriate to update. Adiscussion of these two categories follows. CutbackAsphalt Paving. The 1977 CTGrecommended substitution ofcutback asphalt, which was expected to contain between 20 and 50 percent VOC, with emulsified asphalts (i .e. asphalt whichis liquefied by being held in a low VOCsuspension) . Emulsified asphalts werejust gaining in acceptability in Connecticut when the asphalt paving CTGwas established in 1977. In Connecticut's original SIPsubmittal for this CTG, it was anticipated that water-based emulsions would largely replace cutback asphalt by 1987 [CTDEP, 1979] . That prediction has proved true; the asphalt industry now widely accepts and uses emulsified asphalt. These emulsified asphalts can entirely replace -7-cutbackasphalt during the ozone season and are available with zero VOCcontent. Therefore,

Connecticut plans to pursue adoption of an amendment to thecurrent Connecticut regulation for asphalt paving, R.C.S.A. section 22a-174-20(k) (see Table 1) . The existing rule, based on the 1977 CTG, allows restricted use of cutback asphalt during the ozone season to that whichemits, under test conditions, less than five percent of the total solvent contained in the asphalt. Theexisting rule also provides exemptions for specific uses such as penetrating primecoats and long-termstorage. Removing these exemptions and providing more stringent VOCcontent limits for cutback and emulsified asphalt will not require equipment retrofits, as other CTGsource category rule updates might. Connecticut projects that theestimated emissions of 234 tons per year fromemulsified asphalt and 177 tons per year from cutback in its 2002 inventory will be significantly reduced by updating this rule. Solvent Cleaning (Metal Degreasing) . This CTGwas originally applicable to units which clean/degrease metal in cold cleaners, open top vapor degreasers andconveyorized degreasers. To address the varied designs of degreasing units, the CTGrequirements are based on operating practices rather than establishment of an emission limit. In 2001, solvent cleaning was identified by the OTCas a control measure forwhich many states in the region could achieve further VOCemission reductions by implementing measures which went beyond theoriginal CTGrequirements. Amodel rule was developedthat includes hardware and operating requirements andalternativecompliance options for vapor cleaning machines used to clean metal parts. These requirements are based on the Federal maximum achievable control technology (MACT) standard for chlorinated solventvapor degreasers. The requirements of the OTCModel Rule for Solvent Cleaning, available at: http://www .otcair.orWinterest .asp?Fview=stationgy#, exceed the CTGby establishing a limitation on the vapor pressure of solvents used in cold cleaning and additional operating practices to further limit VOCemissions frommetal cleaning. Connecticut is now

in the process of pursuing the adoption of an amendment to R .C.S.A. section 22a174-20(l) that includes the vapor pressure limitation for solvents used in cold cleaning plus additional operating requirements recommended by the OTCModel Rule. Acopy of that amendment as proposed is available at htt ://www .de .state.ct.us/air2/re s/index.htmunder the headingof "ProposedState Regulations" . Thecomplete final regulations for the abatement of air pollution can be found at: http://www .dep.state.ct.us/air2/reas/mainregs.htm . Upon completion ofthis rule amendment process, the requirements of R .C.S.A. section 22a-174-20(l) will represent at least a RACT level,of control for this source category. New CTGRequirements. EPAis currently in the process of adopting new CTGrequirements. On August 4, 2006, EPApublished proposed CTGs for thefollowing source categories: Lithographic Printing Materials, Letterpress Printing Materials, Flexible Packaging Printing Materials, Flat Wood Paneling Coatings, and Industrial Cleaning Solvents. EPAexpects to proposeseveral more CTG categories later this year. EPAhas proposed that the states address these CTGs within one year of promulgation [71 FR44522] . When the CTGs for thdse categories are published in final form, Connecticut will analyze the need to adopt requirements to address these CTGs for sources in the state and pursue adoption of such requirements anda subsequent SIPsubmittal, as appropriate. Negative Declarations. Connecticut reviewed its inventory of sources and interviewed its field staff to determine if any CTGsources, which were previously determined not to be located in thestate, have since located in the state. Searches of telephone directories and Internet web pages (including -8-other state government databases) were used to supplement this determination. All known operating

stationary sources for which a CTGhas been issued are subject to an appropriate formofregulation. Therefore, Connecticut reaffirms its negative declarations for thecategories so designated in Table 3. B . Major Non-CTGSources of NOxand VOC Accordingto the Implementation Rule, theState is required to conduct a RACT analysis for each major stationary source of VOCandfor each major stationary source of NOx. Major stationary source is as defined in section 302of the Clean AirAct, as modified by sections 182(b), (c), (d) or (e) ofthe CAA, as applicable to the classification of the attainment areas in which a stationary source is located . Additionally, Connecticut is in an OzoneTransport Region and subject to CAAsection 184 . Therefore, the term"major source" for the purposes of this reviewis limited to facilities that have the potential to emit 100tons peryear or more of NOx or 50 tons per year or more of VOC . The guidance in the Implementation Rule gives states the discretion either to conduct individual source-specific RACT determinations or to performRACT determinations or certifications collectively for groups of sources. Therefore, emissions averaging or controls applied throughout a group of sources can be used to showthat the source group meets RACT. In addition to RACT, individual sources mayalso be subject to more stringent technology control measures such as LAER, BACT and MACT. LAER, applicable to new and modified major sources located in non-attainment areas, is the lowest achievable emission rate of the non-attainment pollutant that can be achieved by the source without respect to cost. BACT, or best available control technology, is applicable to new and modified sources located in attainment areas. BACT may be less stringent than LAER becauseconsideration is given to energy, environmental and economic impacts, as well as other costs when evaluating the lowest emission rate. MACT, or maximum achievable control technology, is generally applicable to major sources of hazardous air pollutants. MACT is the control achieved by the best performing twelve percent of sources in a source group. For sources emitting volatile organic hazardous air pollutants subject to MACT, the control device employed by the MACT rule is equally effective in controlling VOCemissions. Each of these control requirements, LAER, BACT and MACT, at the time ofreview, would necessarily be more stringent than RACT. These control requirements would also be applied at thresholds, at least in Connecticut, lower than the major source threshold required for this RACT analysis. As these controls are generally more stringent, it is unlikely that anysource that has recently undergone oneof these control technology reviews would not meet RACT. Furthermore, to theextent that a source had already undergoneone of these reviews, it is generally unlikely that the marginal reductions achievable throughfurther control measures will be cost effective. Only in cases where the technology review is significantly outdated and the source has sufficient actual emissions and useful life remaining, is it plausible that RACT, thecontrol measure with the least associated burden, will be warranted. Note, however, that such asource might still warrant controls as part of an attainment plan or through future, necessarily more stringent, BACT, LAER, or MACT determinations as may become applicable. Table 4(attached) lists the major sources of NOx andVOClocated in Connecticut. In general, all major sources of NOx are regulated under Section 22 while stationary sources of VOCare regulated by Sections 20 and 32. Section 32 explicitly regulates major sources of VOCfor the purpose of -9-implementing RACT, andallows the Department to conduct individual RACT analyses for sources.

These regulations apply to major sources as that term was defined for the 1-hour ozone NAAQS nonattainment classifications, namely 25 tons peryear in Connecticut's southwestern "severe" section and 50 tons per year in the remainder of the state. These thresholds apply to both VOCand NOx sources and are more stringent that the respective 50 and 100tpy thresholds that apply under the current classification of moderate 8-hour ozone non-attainment for Connecticut and for the purpose of conducting this RACT analysis. Dueto EPA's anti-backsliding requirements, and Connecticut's desire to come into attainment with the 8-hour ozone NAAQS as expeditiously as practical, the more stringent 25 and 50 tpy thresholds will not be relaxed for applicability and other requirements in existing rules even though the non-attainment area classification has changed. SIP-Approved NOx Trading and CAIR Sources. Connecticut has participated in two distinct NOx Budget Programs (NBPs) : the OTCNBPand the Federal NBP . Both programs are market-based emission cap-and-trade plans created to reduce emissions of NOx frompower plants and other large combustion sources in the eastern United States. Connecticut and seven other states in the OTC implemented the original OTCNBPfrom1999 through 2002 and the Federal NBPbeginning in 2003; eleven non-OTCstates began compliance with the Federal NBPin 2004. Abrief summary of theevolution of Connecticut's programis provided in the following paragraphs. The Federal NBPoriginated fromEPA's determination in the late 1990s that NOx emissions from large stationary sources in twenty-threejurisdictions significantly contribute to non-attainment of the 1-hour ozone NAAQS in one or more downwind states in the eastern portions of the United States. [62 FR60317: November 7, 1997; 63 FR25902: May 11, 1998; and 63 FR57356: October 27, 1998] EPAissued the NOx SIPCall in 1998, requiring affected states to amend their SIPs and limit NOx emissions during each ozone season beginning in 2003. Connecticut and most of the other OTCstates implemented the Federal NBP on May 1, 2003. Connecticut's NOx Budget Program was modified slightly to reflect the Federal NBPrequirements. The underlying regulation, R .C.S.A. section 22a-174-22b, was approved by EPAas a SIPstrengthening measure on December 27, 2000 [65 FR81743] . R .C.S.A. section 22a-174-22b established astatewide NOx budget and NOx allowance trading program for large electric generators andother industrial sources beginning with the 2003 ozone season. The budget cap is consistent with EPA's NOx SIP Call and the September 1994 OTCMemorandum ofUnderstanding establishing the OTCNOx Budget Program . In Connecticut, the OTCprogram was conducted pursuant to R.C.S.A. section 22a-174-22a. As a result of the OTCNBP, theAcid Rain programandother CAA requirements, by 2000 the OTCstates had already reduced NOx emissions by approximately 55% from1990 levels, thereby reducing the level of reductions necessary to meet the Federal NBPtargets. [EPA, 2004a: the EPANBPReport] With thefurther implementation of the Federal NBPin 2003, the OTCstates' ozoneseason NOxemissions fromsubject sources were reduced 30% from2002levels and were 18%less than the number of NBPallowances allocated in 2003.[EPA, 2004b] In addition, NOx highest daily emissions and average daily emissions in the OTCstates have decreased approximately 25%

and 35%, respectively, from1997 to 2003.1 On May 12, 2005, EPA promulgated the Clean Air Interstate Rule (CAIR) . EPAhas determined that NOx emissions fromelectric generating units in 25 eastern states and the District of Columbia contribute to unhealthy levels of 8-hour ozone in other downwind states. Based on an assessment of

1997 and 1998 data fromthe Acid Rain Program ; 1999-2002data fromthe OTCtrading program ; 2003 data fromthe NBP

. -10-the emissions contributing to interstate transport of air pollution and available control measures, EPA

has determined that achieving required reductions in the identified states by controlling emissions frompower plants is highly cost effective. States must achieve the required emission reductions usingone of two compliance options: 1) meet the state's emission budget by requiring power plants to participate in either an annual or ozone-season EPA-administered interstate cap-and-trade system, as applicable, that caps emissions in two stages, or 2) meet an individual state emissions budget through measures ofthe state's choosing. Connecticut plans to comply with CAIR by participating in the federal CAIR ozone-season NOx trading program

. CTDEPcurrent proposed draft regulation, R .C.S.A. section 22a-174-22c, to implement that CAIR trading program, arescheduled for public hearing on October 19, 2006. When that programbecomes effective on May 1, 2009, shortly thereafter the current NBP implemented under R .C.S.A. section 22a-174-22b will be repealed. All the sources that now participate in the R .C.S.A. section 22a-174-22b NBPwill be subject to Connecticut's CAIR ozone season NOx trading program . EPAbelieves [70FR71652] those CAIR sources and sources subject to the State's emission cap and trade programwhere the program has been adopted by thestate and approved by EPAas meeting the NOx SIP Call requirements, meet the NOx RACT requirement. Those major sources subject to CAIRrequirements and the trading program are listed in Table 4

. .No further RACT analysis is required for these sources. Municipal Waste Combustors (MWCs) . Connecticut has six facilities that burn municipal waste to create electricity. These six facilities account for approximately thirty percent of the actual annual NOx emissions from the major NOx emitters in the state and are regulated by RCSA §22a-174-38 (Section 38) . Section 38 became effective on June 28, 1999 and included NOx emission limits that were equivalent to the emission limits established in the federal emissions guidelines for MWCs. An October 26, 2000amendment to Section 38 reduced the NOx emission limits beyond the 1999 levels. The amended regulation and associated emissions reductions were approved by EPA on December 6, 2001 [66 FR63311] . EPArecently promulgated amendments to thefederal MACT-based emissions [71 FR27324, May 10, 2006] . While CTDEPis currently preparing an amendment to Section 38 to make certain necessary changes based on the federal requirements, Connecticut's existing requirements with respect to NOx andVOCemissions limits are now as stringent as the 2006 revisions to the federal standards. Therefore, Connecticut's emissions limits represent RACT for the MWCs. State Restrictions on Major NOxSources. Any facility in Connecticut that has the potential to emit at least fifty tons peryear of NOx is regulated by RCSA §22a-174-22 (Section 22) . Section 22 also applies to sources in the southwestern part of theState, the "severe" area, that have the potential to emit at least twenty-five tons per year of NOx. Therefore, all major NOx RACT sources (i .e. potential emissions of at least 100tpy) are regulated by this section. Section 22 was approved as part of Connecticut's 1-hour ozone attainment demonstration. Consistent with OTCmodel rule already developed, CTDEP has proposed for public hearing on October 19, 2006, an amendedSection 22to include more stringent emission andcontrol requirements such that all major NOx sources will meet or exceed RACT. Additionally, CTDEPis committed to continue to work with the OTCto further develop this model rule and will pursue rulemaking as needed and appropriate. -11-VOCEmissions From Fuel BurningSources. Section 32 excludes fuel burning sources from consideration for VOCRACT. Generally, good combustion practices, rather than add-on control technology, is considered the appropriate control measure for VOCfrom fuel burning sources. Good combustion practices also help reduce other pollutants such as COand NOx. Connecticut's proposed amended NOx control regulations, Section 22, scheduled for public hearing on October 19, 2006, include tune-up requirements to promote good combustion practices. VOCSources Subject to Maximum Achievable Control Technology (MACT) Standards. The MACT standards were developedfollowing the 1990 amendments to the CAAand are generally contained in Part 63 ofTitle 40of the Code ofFederal Regulations. EPAdeveloped the MACT standards for categories of sources which emit large amounts of hazardous air pollutants. The standards represent the controls achieved by the best performing twelve percent of sources in a source category. Thesources listed in Table 4under the MACT category are sources with VOCemissions that are subject to the MACTs for gasoline distribution, halogenated solvents, andaerospace. Where these standards are designed to control volatile organic hazardous air pollutants, CTDEPconsiders these controls sufficient to satisfy RACT for the sources so designated in Table 4. Additional VOCSources and Sourceswith VOCRACT Orders. Section 32requires certain major sources of VOCto undergo individual RACT review . In those cases VOCRACT Orders, which are federally enforceable, have been issued to the source. Thesesources are also subject to requirements that limit VOCemissions pursuant to various provisions of Section 20. Overall the major non-CTGsources of VOC, which account for approximately one percent of the entire state inventory, currently meet RACT. Nevertheless, we recognize that certain major non-CTG VOCsources whichdepend on reformulation to limit emissions, rather than application of control technology, may yield further reductions as a result of more stringent generic VOCrules. Therefore, CTDEPis evaluating the feasibility of rule changes affecting these sources as part of its attainment planning efforts. 

### IV . CONCLUSION Connecticut has implemented all emission control programs mandated by the 1990 CAA, as well as other measures necessary to ensure adequate progress toward compliance with the 1-hour ozone standard. Additional emissions control measures have also been adopted andsubmitted to EPAas part ofour Mid-Course Review[CTDEP, 2005] . These additional control measures were required to offset the EPA-identified shortfall in emissions reductions necessary to attain the 1-hour ozone standard by November 2007. In addition to the shortfall measures, other strategies that have been adopted but not fully implemented (such as vehicle turnover) will provide substantial further emissions reductions andcontinued improvements in ambient ozone levels through 2007 and beyond. Federal, regional and state rules have been generally successful in helping to bring Connecticut closer to its original goal of meeting the 1-hour ozone NAAQS by 2007. This is clearly demonstrated in Figure 3 . These measures remain in place, and air quality improvements continue to accrue, as Connecticut implements additional attainment measures to reach the goal of attainment with the 8- hour ozone NAAQS.Figure 3 . Connecticut 1-Hour Ozone Exceedance Day Trend and Implemented Control Strategies 1975 - 2005 70 ------ ._.._.__ .__ .-`----- ._. . --- Various VOC RACT measures adopted miJ-19"70's through mtd-1990's ---'t Fed Motor Vehicle Stds MYs 1975+ so Portable Fuel Coniemers 2004+ 'P FuJ Tier 1 motor vehicles 1994+'! stage II Gas Enhancoments :005'>

Phase 1 RFG 1995 't " 5o NOx RACT 1995 '1 Non-road Engine Stds 199G+v ad. Consumer Products, AIM d'c Autobody 1997-98 9 40 CT NLEV 1993 7 e Enhanced 1/M I99A '1 OTC NOx Budget 1999 1 30 tnCt:-~~s

VgPors .1982-83 .! - Ph n~a ll RF Motor Vehicle 1/M 1987 I NO . SIP Cull Phase 12002 ? Muntcipal Waste Combustor NOx 2007 't 20 NO -'S IP 7 lederul Ticr 2 motor vehicle, 2004+ 't He- Duty Diesel Phase 2004+ 7 lo Gasoline RVP (9 opsi) 19A9'1 - - o Stage IIGuolme Vapor I992-1994 't a w ~a w a 3 8 3 3 d 3 3 $ 3 3 S - 3 S 8 - S - e S te F ~ R ~ .~ YEAR Substantial further emissions reductions are projected to occur as the result of currently mandated controls as well as recently proposed and promulgated Federal controls and measures being developed by the OTCfor state implementation. Some of these adopted measures represent RACT. Others, due to factors such as cost of implementation, time necessary to implement, or the category of sources to which thecontrol measure is applicable, are more representative of RACK Amore detailed description of these RACM measures will be included in the State's attainment plan due in June of 2007. Connecticut's planning and regulatory efforts to reduce NOx andVOCemissions are being implemented successfully, resulting in reduced ambient ozone levels throughout the state and downwind. These reductions were expected to result in attainment of the 1-hour ozone NAAQS. CTDEPcontinues to take aggressive action to develop local and regional control measures and influence national strategies to further reduce ozone levels as necessary to attain the 8-hour ozone NAAQS. As a result all Connecticut's CTGsources and major non-CTGsources are controlled by RACT or better standards, and Connecticut's RACT requirement has been satisfied for the 8-hour ozone NAAQS.U

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### H 3 3Table 4

. Listing of the non-CTGmajor sources of nitrogen oxides (NOx) and/or volatile organic compounds (VOC) located in Connecticut. Majorsources are those with the potential to emit 100 tons per year or more of NOx or 50tons per year or more of VOC . The sources are grouped by RACT category. 

### Municipal Waste Combustor Sources: American RefFuel Co. of Southeast Connecticut Covanta Bristol, Inc. CRRA/ Mid-Connecticut CRRA/ Wallingford Wheelabrator Lisbon Inc. Wheelabrator Bridgeport LP Clean Air Interstate Rule Sources: 

### AE S Thames, LLC Algonquin Windsor Locks LLC Bridgeport Energy LLC Capitol District Energy Center Connecticut Jet Power, LLC Devon Power, LLC Exeter Energy LP Lake Road Generating Co, L.P. Milford Power Co, LLC NRGMiddletown Operations, Inc NRGMontville Operations, Inc NRGNorwalk Harbor Operations Pfizer Inc Pratt &Whitney Div UTC, East Hartford PSEGFossil LLC/ Power CT LLC PSEGPower CT LLC/Bridgeport Harbor Station Sprague Paperboard Inc Sources Conducting NOx Trading under a SIP-Approved Program(NOx Budget Sources) : Algonquin Windsor Locks LLC Capitol District Energy Center Connecticut Jet Power, LLC Devon Power, LLC - Pfizer Inc Pratt & Whitney Div UTC, East Hartford PSEG Fossil LLC/ Power Ct LLC PSEG Power CT LLC/Bridgeport Harbor Station Sprague Paperboard Inc AlgonquinGas Transmission Co -19-Cytec Industries Inc / Cyro Industries Inc

Dominion Nuclear Ct., Inc. Hamilton Sundstrand Corp Pratt & Whitney Div UTC, Willgoos Pratt &Whitney Div UTC, Middletown Sikorsky Aircraft Stone Container Corp US Naval Submarine Base/Power Plant University Of CT / Storrs Yale University, School Of Medicine aka Sterling Other Major Sources of NOx (RCSA 22a-174-22) : Allegheny Ludlum

Corp Connecticut Natural Gas Corp Connecticut Valley Hospital Electric Boat Corp Frito-Lay Inc Hartford SteamCompany Kimberly-Clark Corp M DC/Hartford WPCF Norwalk Hospital Association Pratt & Whitney Div UTC, North Haven Simkins Industries Inc Somers Thin Strip WhycoFinishing Tech., Inc. Yale University /Central Power Plant Major Sources of VOCdue to Fuel Burning: AE S Thames, LLC Algonquin WindsorLocks LLC Bridgeport Energy LLC CRRA/ Mid-Connecticut Capitol District Energy Center Covanta Bristol, Inc Devon Power, LLC Lake Road Generating Co, L .P. NRGMiddletown Operations, Inc NRGMontville Operations, Inc NRGNorwalk Harbor Operations - Pratt &Whitney Div UTC, Willgoos PSEG Fossil LLC/ Power CT LLC PSEG Power CT LLC/Bridgeport Harbor Station University Of CT / Storrs Wheelabrator Bridgeport LP Yale University /Central Power Plant -20-Major Sources ofVOCSubject to MACT Standards:

GulfOil L.P. Hamilton Sundstrand Corp Motiva Enterprises LLC, New Haven Motiva Enterprises LLC, Bridgeport Pratt &Whitney Div UTC, Middletown Vishay Vitramon,Inc WhycoFinishing Tech, Inc. 

### Additional VOCSources and Sources Subject to VOCRACT Orders: Bic Consumer Products Manufacturing Co. Cytec Industries Inc/Cyro Industries Inc Electric Boat Corp Kimberly-Clark Corp M DC/Hartford WPCF Pfizer Inc Quebecor, Northeast Graphic Inc Ross &Roberts Inc Sartomer Co Inc SCAPackaging North America Inc Sikorsky Aircraft Spongex Corporation StanleyTools Division Stone Container Corp Wasley Products Inc

### REFERENCES

CTDEP, 1979. "State Implementation Plan forAir Quality", Connecticut Department of Environmental Protection,June 22, 1979. CTDEP, 2005. "Mid-Course Review, Progress Towards Attainment of the 1-Hour OzoneStandard for the Connecticut Portion of the New York-Northern New

Jersey-Long Island Area and the Greater Connecticut 1-Hour Ozone Nonattainment Area", Connecticut Department of Environmental Protection, January 10, 2005. EPA, 1988. "Issues Relating to VOCRegulation Cutpoints, Deficiencies, and Deviations, Clarification toAppendix DofNovember 24, 1987 Federal Register" (aka "The VOCBlue Book"), Ozone/Carbon Monoxide ProgramBranch, Air Quality Management Division, OAQPS, EPA, May 25, 1988. EPA, 2004a

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