Connecticut Department of Energy & Environmental Protection

Requesting Approval of Additional Polluting Substances and Alternative Criteria

When a contaminant is not one of the 88 substances with criteria in the Release-Based Cleanup Regulations (RBCRs), it is called an Additional Polluting Substance. Unless background concentrations are met, numeric criteria must be requested and approved by the Commissioner.

Separately, when the RBCRs contain criteria for a substance but a party believes different numeric criteria are appropriate for a specific site or release area, they may request approval of Alternative Criteria. If the requested Alternative Criteria are approved by the Commissioner, they may use those criteria for that specific site or release.

Fast-Track APS Approval
Petroleum Hydrocarbons
Technical Support Documents 

Request Process

Upload requests into the REACT portal.  Please see instructions at Transmittal of Documents. 

Fast-Track Approval

DEEP, in consultation with DPH, has evaluated available scientific information and has published numeric criteria for many substances, which may be requested by submitting the APS Request Form.  The criteria on the APS Request Form can only be used if DEEP issues a written approval for use for a specific site or release area.

Petroleum Hydrocarbons

The RBCRs do not include the analytical methodology or associated criteria for Extractable Petroleum Hydrocarbons (EPH), Volatile Petroleum Hydrocarbons (VPH), or Air-Phase Petroleum Hydrocarbons (APH). Compliance with the RBCRs for petroleum releases can be demonstrated with those analytical methods by using the EPH/VPH/APH Form, which can only be used if DEEP issues a written approval for use for a specific site or release area.

Calculators

DEEP has developed calculators that may be used to determine APS or alternative exposure criteria. A Technical Support Memorandum should be provided with any criteria request to identify the toxicological information evaluated and the rationale for selection of the parameters used.

Individual Request

Proposed APS and/or Alternative Criteria requests not using the DEEP forms or calculators must be submitted for the Commissioner’s approval through development of site-specific criteria, as outlined in the RBCRs, 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.
 

Technical Support Documents

Release-Based Cleanup Program 

Content Last Updated March 12, 2026