# ~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 ConnecticutState Planfor Municipal Waste Combustors in Response to EPA's 5- Year Review of the New

Source PerformanceStandards andEmission Guidelines Dear Mr . Varney: Pursuant to Sections 111 and 129 ofthe Clean Air Act (CAA) and 40 CFRPart 60 Subpart B, I ampleased 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 FR21354) . The Connecticut Department of Environmental Protection (CTDEP) submitted revisions to the Plan on November 28, 2000, October 15, 2001 and September 16, 2004, which EPAsubsequently approved. This submission is areplacement for a nearly identical submission dated August 21, 2008, on which EPAhas not yet acted. This submission differs fromthe 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 reviewof 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. CTDEPrevised section 22a-174-38 ofthe Regulations of Connecticut State Agencies (Section 38) to retain a level of stringency at least equivalent to the requirements of the 5-year review . CTDEPalso used the revision process as an opportunity to make changes outsidethe 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 Bof the Plan, are not submittedfor approval into the Plan and will therefore be state enforceable requirements only. In past Plan submissions, CTDEPhas not submitted its mercury emissions limit of 0.028 mg/dscmfor 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 fromSection 38 during the rule revision process, CTDEPis 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 forthe July 7, 2008 revisions in satisfaction ofthe requirements of 40 CFR60.23. 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 ofAir Management cc: David Conroy, U .S. Environmental Protection Agency Region 1 Ian Cohen, U.S. Environmental Protection Agency Region 1 (Printed on Recycled Paper) 79 ElmStreet " Hartford, CT 06106 - 5127

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