Requesting APS and Alternative Criteria

Requesting the Commissioner's Approval of
Additional Polluting Substances (APS) and/or Alternative Criteria

The Remediation Standard Regulations (RSRs), contain numeric cleanup standards for 88 substances. When a contaminant is not one of those 88 substances, , it is called an Additional Polluting Substance. Numeric criteria must be requested and approved by the Commissioner in order to complete cleanup at the site under the RSRs, unless background concentrations are met.

Separately, when the RSRs contain criteria for a substance but a party believes different numeric criteria are appropriate for a specific site, that party may request approval of Alternative Criteria. If the requested Alternative Criteria are approved by the Commissioner, the party may use those criteria at that specific site in lieu of the RSR criteria. The following instructions describe the process for requesting both APS and Alternative Criteria.

Optional, Fast-Track APS Approval
Petroleum Hydrocarbons
Technical Support Documents

Request Process

The Electronic Document Transmittal Form must be the cover page for all APS and Alternative Criteria requests uploaded into the Connecticut Secure File Transfer (SFT) website.

Proposed APS and Alternative Criteria must be submitted for the Commissioner’s approval either:

through development of site-specific criteria, as outlined in the RSRs, and submittal of technical supporting documentation to demonstrate how the proposed criteria are protective and how they were derived (calculated), including input values, sources of information and methodology,
OR
through the use of the DEEP’s pre-evaluated numeric criteria (the “fast-track option”), using the Request Form for Approval of Criteria for Additional Polluting Substances (APS Form) and/or Request for Approval for Use of EPH/VPH/APH Analytical Methods and Associated Criteria (EPH/VPH/APH Form).

Optional, Fast-Track Approval

DEEP, in consultation with DPH, has evaluated available scientific information and has published numeric criteria for many substances. Those numeric criteria may be requested by submitting the APS form, which requires no additional documentation. Please note that criteria on the APS Form can only be used if DEEP issues a written approval for use at a specific site. DEEP may change or amend these numeric criteria at any time, so always download a new form.

Request Form for Approval of Criteria for Additional Polluting Substances (4/20/23)

Petroleum Hydrocarbons

The RSRs do not include the analytical methodology or associated criteria for Extractable Petroleum Hydrocarbons (EPH), Volatile Petroleum Hydrocarbons (VPH), or Air-Phase Petroleum Hydrocarbons (APH). However, compliance with the RSRs for releases of petroleum products can be demonstrated by using those analytical methods and associated site-specific cleanup criteria using the EPH/VPH/APH Form.

Request for Approval for Use of EPH/VPH/APH Analytical Methods and Associated Criteria (4/20/23)

These requests are treated the same way as other APS and Alternative Criteria requests. A party may elect to request the numeric criteria identified on the EPH/VPH/APH Form or may elect to propose its own numeric criteria.

As of June 27, 2013, the RSRs include criteria for the analytical method and associated criteria for Extractable Total Petroleum Hydrocarbons (ETPH), except for Volatilization Criteria (VolC) and Surface Water Protection Criteria (SWPC). Pre-evaluated numeric criteria for ETPH SWPC can be found in the APS Form.