'" 1 A. 1.c V l' \..., V j**j~** .IeA.- 11'-- U .l 

## DEPARTMENT OF ENVIRONMENTAL PROTECTION

In the matter of The State ofConnecticut ) and I ) TRADING AGREEMENT AND ORDER No. 8134 United Technologies**Corpqr~tlOn** Whereas, the Commissioner ofEnvironmental Protection ("Commissioner") and The United Technologies Corporation, through its Pratt and Whitney Division ("P&W") agree that

### it is 

### in the public interest that th.ey work cooperatively to improve the air quality within the State of Cormecticut and that the use ofemission reduction credit ("ERe") trading to reduce nitrogen oxide (UNOx") emissions will achieve this result in atimely and cost-effective manner: A At the request and with the agreement ofP&W, the Commissioner finds the following: 1. P&W is a company which owns and operatesjet engine manufacturing facilities at 400 Main Street, East Hartford, Connecticut ("facility 1") and Aircraft Road, Middletown, Connecticut ("facility 2") and ajet engine research facility at Pent Road, East Hartford, Connecticut ("facility 3"). 2. At facility 1, P&W owns and operates three (3) dual-fuel burning boilers, no. 6, 8, and 9 ("facility 1 boilers"), capable ofburning natural gas or No.6 fuel oil. At facility 2, P&W owns and operates four (4) No.6 fuel oil burning boilers, number 1, 2, 3 and 4 ("facility 2 boilers") andjet fuel burning production GO-8**g~** turbine engines ("facility 2 engines"). At facility 3, P&W ovms and operates production GG-8 gas turbine engines, capable cfbuming either natural gas or jet fuel ("facility 3 engines"). At facility 2 and facility 3, similar production GG8 gas turbine engines are tested in test cells. The facility 1 boilers, facility 2 boilers, facility 2 engines and facility 3 engines are subject to Section 22a-174- 22 ofthe Regulations'ofConnecticut StateAgencies ("Regulations"), pertaining to the control ofNOx emissions. 3. Official U.S. Environmental Protection Agency Reference Method 7 stack testing performed on February 6, 7 and 9, 1996 on facility 1 boilers, January 10

.through January 12, 1996 on facility 2 boilers, May 1, 1996 on a facility 2 engine, and July 28,1998 on a facility 3 engine (for natural gas only), resulted 

### in NOx**~mission** rates as shown in Table 1below:

Initials: 

# 0'"-";../
(Printed On Recyelec! hper) 79 El::n Street • Hanford, CT 06106·**~127** hltp:11c!ep.stlie. Ct.llS An Eq

..al Opporluniry rrc:ployu Dale:UNITED TECHNOLOGIES CORPOR",TlON 

### 2

TABLE! TR".DING AGREEMENT AND ORDER NO. 8!34



# • F:lciIiIJI DEP Fuel He:! St:lck Test RACTo r::lte Equipment Rezistration Intut Rate: (lb/MMBtll IPermit no. (l\ MBrul (lbMMBtu except where h,) except otherwise where: noted) otherwise noted)

, 

# I Facility I

- R39 " Nat gas 168 0.150 0.20 Boilerno. 6 #60i] 0.321 u 0.15. Facility I- 

# I R'I NaLga.s 

# I ISO 0.293-- 

# I 0.20 Boilerno. 8 #6 oil 0.438" • 0.15 Facility I

- 

# I R42 

# I Nat gas 

# I 189 0.352-- 0.20 Boilerno. 9 f 6 oit 0.444' • 0.25 Facility 2· 

# I RIS 

# I #6 oil 

# I I" 

# I 0.326" 

# I 0.15 Boile: no. I Facility 2 . 

# I RI6 

# I #6 oil 

# I I" 0.306·· 

# I 0.25 Boile: no. 2 Facility 2· Pl' 

# I #6 oil 

# I 183 

# I 0.343" 

# I 0.25 Boilerno. 3 Facility 2- 

# I P36 #6 oil 

# " 

# I 0.378" 

# I 0.25 Boiler no. 4 Facility 2- 

# I P62 

# I Je: fuel 

# I 260 

# I 380 

# I 75ppmvd engine ppmvd" Facility 3- EI NaLgas 283 26 ppmvd 

# 551:=d engme Jet fuel 380 7 ppmvd ppmvd·· "Reasonably Available CODtrol Technology'

•• Indicates that emission rate for t.lJ.e specified piece ofequipment and fuel type is in excess of the emission rates specified in Section 22a-174-22, Table 22-2, oft.l:I.e Regulations. Note: To establish L!Je full load emission rate ("FLER'') for the facility 2 and facility 3 engines, one engine was tested at facility 2, an.d one engine was tested at facility 3. The facility 2 engine stacktesting result was also used the testresuit for a facility 3 engine onjet fuel. 4. On and afterMay 31, 1995, Section 22a-174-22(e) ofthe Regulations requires tbat tbe facility I boilers, facility 2 boilers, facility 2 engines, and tbe facllity 3 

### engines emitNOx atrates no greaterthan the R..o..CTrates she,,",1l in 

### Table 1 above. P&Wproposes to use approved ERCs for compliance purposes at facility I, facility 2 and facility 3, when and ifP&W chooses to operate tbe 

### facility 1boilers, facility 2boilers, faciliiy 2engines, and facility 3 engines on
Initials: Date;

### UNITED TECHNOLOGIES CORPORATION 

## ., 

# '" TR,WING AGREEMENT AND ORDER NO. 8134



### 5. fuels that exceed the RACT rates shov..n in Table I ahove. Pursuant to Section 22a-174-22(j) ofthe Regulations, P&W acquired the 

### follo',),oing amounts ofapproved ERCs as sho\.vn in Table 2 below:

TABLE 2

6.



### B.



## c. Date 

# , Ozone Season"Credits Non-ozone season credits 

# . 9/28/95 

### 36 tons 

### 28 tons 

### 1/29/96 

# I 29 tons 30 

### tons 4/29/96 

# I 50 tons 

### 50 tons 1/10/97 Owns 

### 50 tons
12/10/97 

# otons 30 tons Approved ERCs are defined for the pUIJlOse ofthis Trading Agreement and Order as those which the Commissionerhas provided written authorization for use in compliance with Section 22a-174-22 ofthe Regulations. The Commissioner, in accordance with thep'rovisions ofthis Trading Agreement and Order, and pursuantto Section 22a-174-22(j) ofthe Regulations, hereby allows P&W to 

### comply with Section 22a-174-22 ofthe Regulations through the use ofERC trading referenced in Section A herein, 10 achieve the NOx emission reduction required by 

### Section 22a-174-22(d)(2) ofthe Regulations. With the agreement 

### ofP&W rthe Commissioner, acting under Sections 22a·6, 22a-171, 

### 22a-174, 22a-176, and 22a-l77 ofthe Connecticut General Statutes, orders P&W as follows: 1. After May 3], 1995, and until May 1,2003 or until P&W achieves compliance with the emission standards in Section 22a-174-22(e) ofthe Regulations, whichever occu.rs earlier, P&W shall have in its possession approved ERCs and shall document and record the amounts ofall fuel and ERCs used by the facility

I boilers, facility 2 boilers and engines, and the facility 3 enginC?s each month, and provide such records in accordance with the following and Section 22a-174- 

### 22 ofthe Regulations:

a. Docwnentthat sufficient approved ERCs are available for the facility 1 boilers, the facility 2 boilers, the facility 2 engines and facility 3 enllines no later than the first ofeach calendar month to assure comDliance Ior, at a minimum, that calendarmondl;

.

Initials: U;-f_ 

### Date: 

### I

. 'I ' i

..... II
, ::s '\,. '"

!UNITED TECHNOLOGIES CORPOR<\TION 

### 4 TR<\DING AGREEMENT AND ORDER NO. 8134 b. No later than the tenth day ofeach month, calculate ERCs used in the preceding calendarmonth for each boiler and engine, as follows:


### BoilerERCs (tons) = 

### [fuel use in MMBtu x (FLER in Ib/MMBtu

- (0.95 x RACTrate in IbIMMBtu))] + 

### 2000 poundslton; Engine'ERCs (tons)

### = [(Hours ofOperation xFLERin Iblhr)

- (fuel use in MMBtu x (0.95 xRACTrate in 

### IbIMMBtu))] + 

### 2000 pounds/ton; Where:

• MeT 

### rate = RACT 

### rate shown in Tables 1 

### and 3 

### ofthis Trading Agreement a..rld Order.



### • FLER = 

### full load emission rate sho'Wll in Table 3 ofthis Trading Agreement and Order. 

### Discount = 

### 5% design margin appLied to the RACT rate.

c. d.

e. 

### Document and record monthly consumption offuel and ERCs; No later than March], ofeach year this Trading Agreement and Order is in effect, include with its annual emissions statement report to the Commissioner, the montWy rate offuel consumption for each boiler and engine and ERCs used by each boiler and engine for the previous calendar year; Retain records and supporting documentation as described in this section for a minimum offive years, commencing on the date such records were created; f.

g. Maintain documentation to attest to t.l:le fact that ERCs used during the ozone season were generated during the ozone season. The ozone season is from May I through September30 in any calendar year. Generator certification ofthis fact shall be sufficient; and Provide the records specified above to the Commissioner within thirty (30) days ofreceipt ofawrinen request from the Commissioner. 2. Prior to May 1,2003 P&W shall comply during operatIon on the fuels shown in Table 3·below with the enforceable maximum FLERs shown in Table 3 below, averaged on a 24-hour basis:



### Initials: (j:.VUNITED TECHNOLOGIES CORPOR'\.TION 

### 5

TABLE 3 TRADING AGREEMENT AND ORDER NO. 8134**F:lcility/Equipm~nt Fu~1**  FLER (IblMMBtu RACT rate OblM.l\1Btu except where otherwise except where otherwise noted) noted) Facility 1 - Boilerno. 6 I #6 oil 0.33 0.25 Facility 1 - Boilerno. 8 Nat fas 0.30 0.20 #6oi 0.45 0.25 facility 1- Boiler no. 9 Nat. Gas 0.36 0.20 #6 oil 0.45 0.25 Facility 2 - Boilerno. 1 #6 oil 0.35 0.25 Facility 2

- Boiler no. 2 #6 oil 0.35 0.25 Facility 2 - Boilerno. 3 

# I #6 oil 0.35 

# I 0.25 Facility 2 •Boilerno. 4 #6 oil 0.40 

# I 0.25 Facility 2

- engine Jet fuel 230 Ib/hr 0.292 (75 ppmvd) Facility 3 - eogine Jet fuel 2301blhr 0.292 (75 ppmvd)
Each facility 2 and facility 3 engine shall comply with the FLER set fonh 

### in Table 3 abcve. 

### 3. No later than May 1,2003, P&W shall comply with 

### the requirements ofSection 22a-174-22(d)(2) ofthe Regulations. However, after full program review ofthis and other Trading Agreements and Orders and, 

### ifdetermined to be appropriate, 

### the Commissionermay grant awrinen extension ofthis Trading Agreement and Order. 4. FLERs, stack test rates and fuels set forth 

### in Tables 1 and 3 may be modified 

### only after the consent ofthe Commissionerby 'Written modification ofthis Trading Agreement and Order. 5. As 

### used in till::i 

### Trdding Order, "Commissioner" means the Commissionerof Environmental Protection or 

### an agent ofthe Commissioner. "Ozone season" means theperiodfrom May 1 

### through September 30 in 

### any given calendaryear. 6. 

### Notification ofnoncompliance. In 

### the event that P&W

### becomes aware that it 

### dId 

### not ormay not comPlY, ordidnot ormay not comply on time, with any**req~rement** 

### oftms Trading Agreement and Orderor ofany document required hereunder, P&W shall by telephone immediately notify the Bureau ofAir 

### Management and shall take all reasonable steps to ensure that any noncompliance ordelay is avoided or, ifunavoidable. is minimized to the greatest extentpossible. P&W 

### shall also notify the Commissioner in 

### writing \

....

ithin ten days ofbecoming aware ofthe noncompliance orpotential noncompliance stating the date, time, 

### and duration of

### the noncompliance, the Initials: Cjf.J

....... 

### Date: 

## :/J..I( <:. I IUNITED TECHNOLOGIES CORPORATION 

### 6 TRillING AGREEMENT A.>m ORDER NO. 8134


### reasons for the noncompliance ordelay and all activities "".-hieh P&W a.r:ld its 

### agents, employees and representatives took to avoid orrepair the results ofthe noncompliance and prevent the noncompliance, and propose, for the review and wrinen approval ofthe Com:missioner, dates by which compliance will be 

### achieved. Notification by 

### P&W shall not excuse noncompliance or delay, and the Commissioner's approval ofany compliance dates proposed shall not excuse noncompliance or delay unless specifically so stated by 

### the Commissioner in writing. Nothing herein shall negateP&W's obligation to comply with Section**22a-174~** 

### 7 ofthe Regulations. To the extent thatthe provisions ofSection 22a· 174-7 

### are inconsistent with 

### theprovisions oftrus Trading Agreement and Order. 

### the more stringent ofthe provisIOns in 

### the Trading Agreement and Order or Section 22a-174-7 shall control. 7. Certification ofdocuments. Any document, including but not limited to any nonce, which IS 

### reqUlied to be submitted to the Commissioner under

### Uris Trading Agreement and 

### Order shall be signed by the responsible corporate officer ofP&W or aduly authorized representative ofsuch officer, as 

### mose terms are defmed in 

### Section 22a-430-3(b)(2) ofthe Regulations. and by the 

### individual or individuals responsible for actually preparing such docll."nent, each ofwhom shall. examine andbe familiar with 

### the information submitted in tl)e document and 

### all attacp.ments thereto, and 

### shall make inquiry ofthose individuals responsible for obtaining the infonnation to determine that 

### the information is true. accurate. and complete, a.TJ.d each ofwhom shall cerJ.fy in writing 

### as follows: "I 

### havepersonally examined and am familiar 

### with the inforro.ation 

### submined in 

### this document and all attachments thereto. and I 

### certify that based on reasonable investigation, including m"y inquiry ofthose individuals responsible for obtaining the information, the submitted information is true, accurate and complete to the best ofmy knowledge and belief. Iunderstand that any false 

### statement made in the 

### submitted informationmay be

### punishable as 

### a criminal offense under Section 22a-175 ofthe 

### Connecticut General Statutes or, in 

### accordance with Secclon 22a-6 ofthe Connecticut General Statutes, under Section 53a-157b oftbe Connecticut General Statutes. and in 

### accordance with a.1JY

### other applicable statute." 

### 8. Final**A~eement** 

### and Order. This Trading Agreement and Orderis the final agreement ana oraer by 

### ano betweenthe Commissioner and 

### P&

### Wwith respect to the matters addressed herein, and 

### shall not bemodified without the 

### written agreementofbothparties. 

### 9. False statements
..

### t:uJ.y false statement in 

### any information submined pursuant to 

### t..hJ.s liadmg Agreement 

### and Ordermay be

### punishable 

### as acriminal offense under Section 22a-175 ofthe Connecticut General Statutes or, in accordance with Section 22a-6. under Section 53a-157b ofthe Connecticut General Statutes. 10. Notice oftransfer; liability ofP&W and others. Until P&W has fully complied 

### WIth tJus 1

### radmg Agreement 

### and Order, ?&

### Wshall notify the Commissioner

### in \-vriling no later than fifteen (15) days aftertransferring all or 

### any portion ofthe facilities. the operations, the sites or the businesses which are the subject of

### this Initials: 

# &--' Date:

### UNITED TECHNOLOGIES CORPORUION 

### 7 TRADING AGREEMENT A.l'/D 

### ORDER NO. 8134

11.

12.



### 13.

14.



### 15.
16. 

### Trading Agreement and Order, or obtaining anew mailing orlocation address. Any license transfer shall be conducted in accordance with Section 22a-60 ofthe 

### Connecticut General Statutes. P&W's obligations underthis Trading Asrreement and Order shall nor be affecred by the passage oftitle to any property to-any otherperson ormunicipality. Commissioner's powers. Nothing in this Trading Agreement and Order shall atteet the COmmISSIoner's authority to institute any proceeding or take any other 

### action to**pre~eht** 

### or abate violations oflaw, prevent or abate pollution, recover' costs and natUral resource damages, and to impose penalties for violations oflaw which are willful or criminally negligent orfor which penalties have not been specifically provided in this Trading Agreement and Order, including but not llInited to violations ofany permit issued by the Commissioner. Ifat any time the Commissionerdetermines that 

### the actions taken by P&W pursuantto this Trading Agreement and Orderhave notfully achieved compliance with 

### Section 222·174-22 ofthe Regulations, the Corrmlissionermay institute any 

### proceeding against P&W and/orrequire P&W to undenake further investigation orfunher action. P&W's obligations under law. Nothing in 

### this Tradino Agreement and Order shan relIeve

### pezWot other obligations underapplicabie federal, state and local law. Access to records and facility. Any repre.sentative**oftb~ pepartm~nt**  

### of EnvlTonmentaI Protecuon may enter and 

### mspect the faclhues and lnspect and copy records within Donnal business hours withoutprior notice for the purposes ofmonitoring and enforcing the actions required or allowed by this Trading Agreement and Order. No effect on ri hts 

### ofother ersons. This Trading Agreement and 

### Order shall nel er create nor ect any n 15 

### ofpersons who ormunicipalities which are not parties to this Trading Agreement and 

### Order. No Creation ofPro Ri 15. 

### This 

### Trading Agreement and Order does not create any 

### propeny n 15 W1 

### respect to these ERCs. Notice to Commissioner ofchanges. Within 

### fifteen (15) 

### days oftbe date P&W 

### becomes aware ofa 

### cnange 1D 

### any liifonnation submitted to the Commissioner underthis Trading Agreement and 

### Order, orthat any 

### such infonnation was 

### inaccurate or misleading orthat any relevant information was 

### omitted, P&W shall submitthe correct or omitted information to the Commissioner.

### iJ**·~"** 

## ' Initials: Date: .....:.'

# (L3C!-).:c~'_0

### UNITED TECHNOLOGIES CORPORf;nON 

### 8 TRWING AGREEMENT AND ORDER NO. 8134 17. Submission ofdocuments. A..'1y 

### document required to be 

### submitted to the COn:unlsslonerunderthIs Trading Agreement and Order shall, unless otherwise specified in writing by the Commissioner, be directed to: . 

### Ms. Wendy Jacobs Department 

### ofEnvironmental Protection Bureau ofAir 

### Management Compliance and Field Operations Division Emissions and Credit Trading Section 

### 79 Elm Street Hartford, Connecticut 06106-5127

Initials: r.lJ.1I../ Date: 

### II"::/cr:.. 

# ,

### UNITED TECHNOLOGIES CORPORATION 

### 9 TR,WING AGREEME "T AND ORDER NO. 8134


### P&W consents to the issuance ofthis 

### Trading Agreement and Order v.rithoUl funher notice. The undersigned certifies that he/she is fully authorized to enter ioto this Trading Agreement and Order and to legally bind P&W to the terms and conditions ofthe Trading Agreement and Order.
United Technologies COrpQration Sig;ature: 

# (J**b.w.~/!lft'..L-** TypeName: Claudia R. Coplein Type Title: VP, Environme Health 

### & Safety Date: January , 2000

# J~a final cunt

# ord~hCo , ssioner

# of~ro ental Protection on

# ~/w ., ; 

# /iL2**~e:!Y-** CITY OF EASTHARTFORD, TOWN OF MIDDLETOWN LAND RECORDS

. MAILED CERTIFIED MAIL, RETURN RECEIPTREQUESTED 

### Certified DocumentNo.