EXHIBIT E ADDENDUM 

HEARING REPORT ADDENDUM 

REGARDING THE RECOMMENDED FINAL MINIMUM DATA AVAILABILITY OF 

PROPOSED SUBSECTION (c)(6)(A) OF R.C.S.A. SECTION 22a-174-4 

OCTOBER 22, 2003 

Pronosed R.C.S.A. Section 22a-174-4(c)(6)(A) minimum data availabilitY 

In the final wording of amended R.C.S.A. section 22a-174-4 ("Section 4") as recommended in 

the response to Comment 14 of this report, the proposed minimum data availability of 90% for 

gaseous continuous emissions monitoring ("CEM") equipment was increased to 95%. The 

Department proposed adoption of the 95% standard based on comments submitted by the U.S. 

Environmental Protection Agency ("EPA") and an extensive analysis of CEM data submitted by 

source owners and operators in calendar years 2000, 2001 and 2002, which showed a 97% 

compliance rate with a 95% minimum data availability for gaseous CEM equipment. A copy of 

this analysis is attached (Memorandum from K. Hill, 10/02/03). 

Since issuing the Notice of Availability for the final wording of amended Section 4, source 

owners and operators disagreed with the conclusion of the Department's analysis and commented 

that the 95% minimum data availability was overly burdensome and inconsistent with 

Department guidance, regulation and permits. The Department met with the owners and 

operators who had commented regarding the minimum data availability to discuss these concerns 

and discussed this provision with staff at EPA. Specifically, owners and operators indicated that 

the calculated 97% compliance rate was a higher rate than their calculated compliance because 

the owners and operators use different assumptions' that are more indicative of actual source 

operation. The owners and operators commented that a 95% minimum data availability was 

inconsistent with the 90% minimum data availability included in the Department's CEM 

guidance, the 90% minimum data availability required of municipal waste combustors in Section 

38 and a 90% minimum data availability included in recently issued permits for certain boilers 

and other equipment. Owners and operators found the 95% level exceeded the Department's 

stated intent : to codify the Department's CEM guidance in regulation. Furthermore, the 

amendment followed a multi-year SIPRAC process at which a CEM data availability minimum 

increase from the draft 90% was never discussed. 

In light of these considerations, the Department should revise the recommendation to increase 

the minimum data availability explained in the response to Comment 14 by reverting to the 

proposed 90% minimum data availability for gaseous CEM equipment in the final wording of the 

proposed amended section, as follows: 

(6)(5) DATA AVAILABILITY. 

(A) THE OWNER OR OPERATOR OF ANY SOURCE REQUIRED TO 

INSTALL, OPERATE AND MAINTAIN OPACITY CE M EQUIPMENT 

PURSUANT rTO SUBSECTION (b) OF IN ACCORDANCE WITH 

THIS SECTION, 

' Assumptions differ in rounding methods and the use of the facility rather than each monitor as the basic 

unit of comPliance. 
, PERMIT 

OR ORDER SHALL MEET THE FOLLOWING DATA 

AVAILABILITY REQUIREMENTS 

ON AN EMISSION LIMITATION-SPECIFIC 

BASIS: 

(i) WHILE THE SOURCE IS OPERATING, THE OWNER OR 

OPERATOR SHALL OPERATE REQUIRED CEM 

EQUIPMENT PURSUANT TO SECTION 22a-174-7(b) OF 

THE REGULATIONS OF CONNECTICUT STATE 

AGENCIES, AND ALLOWABLE PERIODS OF MISSING 

DATA SHALL APPLY ONLY TO PERIODS OF 

DELIBERATE SHUTDOWN ALLOWED BY SECTION 22a174-7(b) OF THE REGULATIONS OF CONNECTICUT 

STATE AGENCIES, UNAVOIDABLE SYSTEM 

MALFUNCTION OR AS OTHERWISE PROVIDED UNDER 

THIS SUBDIVISION, 

(i) (ii) OMCITY EMISSIONS EXCEPT AS PROVIDED IN 

SUBPARAGRAPHS (B) AND (C) OF THIS SUBDIVISION, 

FOR OPACITY EMISSIONS, DATA SHALL BE AVAILABLE 

FOR NO LESS THAN NINETY-FIVE PERCENT (95%) OF TBE 

TOTAL OPERATING HOURS OF THE SOURCE IN ANY 

CALENDAR QUARTER, 

(ii)(iii) EXCEPT AS PROVIDED IN SUBPARAGRAPHS (B) AND (C) 

OF THIS SUBDIVISION, FOR AIR POLLUTANT EMISSIONS 

OTHER THAN OPACITY, DATA SHALL BE AVAILABLE FOR 

NO LESS THAN NINETY PERCENT (90%) OF THE TOTAL 

OPERATING HOURS OF THE SOURCE IN ANY CALENDAR 

QUARTER, AND 

(iii)(iv)PERCENT DATA AVAILABILITY SHALL BE CALCULATED 

USING THE FOLLOWING EQUATION: 

Data Availability _( Unit Operating Time--Monitoring Downtime ~ Il *100 

Unit Operating Time 

VWHERE: 

UNIT OPERATING TIME = TOTAL HOURS OF SOURCE OPERATION AT 

ANY LEVEL DURING THE CALENDAR 

QUARTER. 

MONITORING DOWNTIME = TOTAL HOURS OF SOURCE OPERATION AT 

ANY LEVEL DURING THE CALENDAR 
QUARTER WHERE EITHER NO CEM 

EQUIPMENT DATA WAS COLLECTED OR THE 

CEM EQUIPMENT DATA WAS INVALID . SUCH 

PERIODS INCLUDE, BUT ARE NOT LIMITED 

TO, QUALITY ASSURANCE ACTIVITIES SUCH 

AS CALIBRATION, PREVENTATIVE 

MAINTENANCE, AND CALIBRATION DRIFT 

EXCEEDANCES OR QUALITY ASSURANCE 

AUDITS THAT RESULT IN INVALID DATA. 

Internal references to subsection (c)(6)(A) in subsections (c)(6)(B) and (C) should also be 

revised a follows : 

) THE COMIVIISSIONER, IN WRITING, MAY EXEMPT THE OWNER OR 

OPERATOR OF A SOURCE FROM THE MINIMUM DATA AVAILABILITY 

REQUIREMENTS OF SUBPARAGRAPHS (A)(ii) AND (A)(iii) (A)(iv) OF 

THIS SUBDIVISION IF SUCH SOURCE IS EQUIPPED WITH PROPERLY 

OPERATING OPACITY CEM EQUIPMENT, AND THE SOURCE IS 

OPERATED LESS THAN OR EQUAL TO FIVE HUNDRED FOUR (504) 

HOURS IN TIE CALENDAR QUARTER. 

(C) THE COMMISSIONER, IN WRITING, MAY EXEMPT THE OWNER OR 

OPERATOR OF A SOURCE FROM THE MINIMUM DATA AVAILABILITY 

REQUIREMENTS OF SUBPARAGRAPHS (A)(ii) AND-(A)(iii) AND (A)(iv) 

OF THIS SUBDIVISION IF SUCH SOURCE IS EQUIPPED WITH 

PROPERLY OPERATING GASEOUS CEM EQUIPMENT, AND THE 

SOURCE IS OPERATED LESS THAN OR EQUAL TO THREE HUNDRED 

THIRTY-SIX (336) HOURS IN THE CALENDAR QUARTER.