~ TATE OF CONNECTI ~,,UT 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

OrtrI:eT 22, 2008 

Robert W. Varney 

Regional Administrator 

United States Environmental Protection Agency Region I 

One Congress Street, Suite 1100 

Boston, Massachusetts 02114-2023 

Re: Revision to Connecticut State Plan for Municipal Waste Combustors in Response to 

EPA's 5- Year Review of the New Source Performance Standards and Emission Guidelines 

Dear Mr. Varney : 

Pursuant to Sections 111 and 129 of the Clean Air Act (CAA) and 40 CFR Part 60 Subpart B, I am pleased to 

submit a revision to the Connecticut State Plan for Implementing the Large and Small Municipal Waste Combustor 

Emission Guidelines (the Plan). The U.S . Environmental Protection Agency (EPA) originally approved the Plan by 

direct final rule on April 21, 2000 (65 FR 21354) . The Connecticut Department of Environmental Protection 

(CTDEP) submitted revisions to the Plan on November 28, 2000, October 15, 2001 and September 16, 2004, which 

EPA subsequently approved . This submission is a replacement for a nearly identical submission dated August 21, 

2008, on which EPA has not yet acted. This submission differs from the August 21, 2008 submission by the 

inclusion of Connecticut's stringent mercury emissions limitation, to allow for full Plan approval. 

This fourth revision to the Plan is prompted by EPA's 5-year review of the municipal waste combustor emission 

guidelines and new source performance standards (NSPS) promulgated on May 10, 2006. The 5-year review 

resulted in reductions in certain emissions limits and revisions to compliance testing requirements . CTDEP revised 

section 22a-174-38 of the Regulations of Connecticut State Agencies (Section 38) to retain a level of stringency at 

least equivalent to the requirements of the 5-year review. 

CTDEP also used the revision process as an opportunity to make changes outside the scope of EPA's 5-year review. 

One such change was the addition of record keeping requirements that exceed the scope of the emissions guidelines 

and NSPS. Those requirements, identified in Exhibit B of the Plan, are not submitted for approval into the Plan and 

will therefore be state enforceable requirements only . In past Plan submissions, CTDEP has not submitted its 

mercury emissions limit of 0 .028 mg/dscm for approval . EPA approved the Plan for mercury based on the inclusion 

in Section 38 of an additional mercury emissions limit, with a level consistent with the emission guidelines and 

NSPS. As the less stringent mercury emissions limit was deleted from Section 38 during the rule revision process, 

CTDEP is submitting the more stringent mercury limit into the Plan to obtain EPA's full approval of the Plan . 

This Plan revision package includes (1) a statement of the changes made by the July 7, 2008 revision of Section 38; 

(2) Section 38 as revised on July 7, 2008; and (3) documentation of the public participation process for the 

July 7, 2008 revisions in satisfaction of the requirements of 40 CFR 60.23 . 

If you have any questions or comments regarding this submission, please get in touch with Gary Rose at 

(860) 424-4152 . 

Yours truly, 

I 

Anne R. Gobin, Chief 

Bureau of Air Management 

cc : David Conroy, U.S . Environmental Protection Agency Region 1 

Ian Cohen, U.S . Environmental Protection Agency Region 1 

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