STATE OF CONNECTICUT

DEPARTMENT OF ENVIRONMENTAL PROTECTION

In the matter of

The State of Connecticut and

Sikorsky Aircraft Corporation

RECEIVED

NOV 0 2006

EH & S Department

)

Trading Agreement

and Order No. 8120A

Modification I

Whereas, the Commissioner of Environmental Protection ("Commissioner") and Sikorsky Aircraft

Corporation (Sikorsky) having agreed to the terms and conditions set forth in Trading Agreement

and Order 8120A issued on March 27, 2003, do now, by mutual agreement, modify said Trading

Agreement and Order as follows:

I. Delete the date April 30, 2007, and substitute therefor the date May I, 2009, in

paragraphs A.6., B.I., B.2., B.6., and B.13.

2. Delete paragraph A.4. and substitute the following therfor:

Official U.S. Environmental Protection Agency ("EPA") Reference Method 7E

stack testing performed on May 16, 2005 and September 2, 2005 resulted in NOx

emission rates as follows:

Table 1

NOx Stack Test Rates, FLERs and Allowable Limits (IbslMMBtu)

UNIT Fuel Heat Input Stack FLER Allowable Date of Date of Next

Reg. or (MMBtulhr) Test Limit Last Stack Test

Permit No. Rate Rate Stack Test

Boiler No. I No.6oil 48.0 0.379 0.39 0.25 5116/05 5116/10

R178-0019 Natural Gas 50.4 0.178 N/A 0.20 5116/05 5116/10

Boiler No.2 No.6oil 48.0 0.289 0.34 0.25 5116/05 5116110

RI78-0018 Natural Gas 50.4 0.175 N/A 0.20 5116/05 5/16110

Boiler No.3 No.6 oil 48.0 0.322 0.35 0.25 5/16/05 5116110

R178-0017 Natural Gas 50.4 0.196 N/A 0.20 5116/05 5116/10

Boiler No.4 No.6 oil 48.0 0.319 0.33 0.25 5116/05 5/16110

Rl78-0016 Natural Gas 50.4 0.196 N/A 0.20 5/16/05 5116110

Boiler No.5 No.6oil 49.5 0.325 0.35 0.25 912/05 9!2!IO

PI78-0039 Natural Gas 52.5 0.120 N/A 0.20 9/2/05 9/2/10

3. Delete paragraph B.2.b. and substitute the following therfor:

No later than the twentieth day of each month, calculate and permanently retire

DERCs used in the preceding calendar month for the boilers as follows:

DERCs (tons)= {actual fuel use in MMBtu x ((FLER) - (.95 x NOx allowable

limit))} -;- 2000 lbs/ton

(Printed on Recycled Paper)

79 Elm Street • Hartford. CT 06106· 5127

An Equal Opportunity Employer
Sikorsky Aircraft Corporation 2 Trading Agreement

and Order No. S120A

Modification 1

4. Delete paragraph B.7. and substitute the following therfor:

Document that sufficient approved DERCs are available for the boilers no later than

the first of each calendar month to assure compliance for, at a minimum, that

calendar month. DERCs required shall be adjusted upwards by 100% if DERCs are

not in Sikorsky's possession for use prior to the first day of each month or applicable

season. However, nothing in this Trading Agreement and Order shall affect the

Commissioner's authority to institute any proceeding or take any other action to

require additional upward adjustment, based on the gravity of any alleged

noncompliance or violation of law. Sikorsky shall permanently retire the quantity of

DERCs equivalent to the excess emissions plus a 100% premium within sixty (60)

days of Sikorsky's discovery of the DERC shortfall. Sikorsky shall certify and

report any such DERC retirement to the Commissioner in accordance with

paragraph B.lS. of this Trading Agreement and Order.

5. Delete paragraph B.9.. and substitute the following therefor:

FLER Exceedance. Noncompliance with an established FLER shall subject Sikorsky to

make restitution by matching the quantity of emissions ("true up") caused by the

exceedance plus a 100% premium. The true up in tons of DERCs shall be equal to the

FLER exceedance in Ibs/MMBtu, multiplied by the total heat input during the period of

noncompliance divided by 2000 lbs/ton. If the period of noncompliance is not known,

the time period from the completion of the last/previous Commissioner witnessed

emission test through the date the FLER compliance is achieved as approved by the

Commissioner shall be used. However, nothing in this Trading Agreement and Order

shall affect the Commissioner's authority to institute any proceeding or take any other

action to require additional upward adjustment, based on the gravity of any alleged

noncompliance or violation of law. Sikorsky shall permanently retire DERCs calculated

in accordance with the above plus a 100% premium within sixty (60) days of Sikorsky's

discovery of the FLER exceedance. Sikorsky shall report any FLER exceedance to the

Commissioner in accordance with paragraph C.12. of this Trading Agyeement and Order.

6. Delete paragraph B.12 and substitute the following therefor:

Extension. No later than May 1,2009, with respect to the boiler, Sikorsky shall comply

with the requirements of Sections 22a-174-22(d)(I) and 22a-174-22(d)(2)(A) of the

Regulations and amendments thereto. There is no assurance that after full program

review of this and other Trading Agreements and Orders that the Commissioner will

grant a written extension of this Trading Agreement and Order.
Sikorsky Aircraft Corporation 3 Trading Agreement

and Order No. 8120A

Modification I

7. Delete the date September I, 2006, and substitute therefor the date September I, 2008 in

paragraph B.13..

8. Delete the word "individual" and substitute therefore the word "section" in paragraph

B.29..

9. Delete the name "Mr. Roland L. Severance Jr., PE" in paragraph B.30..

All other terms and conditions of Trading Agreement and Order No. 8120A issued by the

Commissioner acting under Chapter 446c, Sections 22a-6, 22a-171, 22a-174, 22a-176, and 22a-l77

of the Connecticut General Statutes shall remain in effect.

Sikorsky hereby consents to the entry of this modification to the Trading Agreement and Order

without further notice.

Name: Z13€f-r:r: qJ2~3"V

Title: ,/{1/ICI1t9Bf.. Gv/.fo.upC'.u-h:A'cn>-' ~A.CJ~ Al~s

Date: 1~/!¥/(;,5

as a modification of an Order of the Commissioner of Environmental Protection

/

,

Date

CITY OF STRATFORD

MAILED CERTIFIED MAIL,

RETURN RECEIPT REQUESTED

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