d. Flush rigs subject to Section 22a-174-20(1) ofthe Regulations.

2. The Respondent is an Aerospace Manufacturing and Rework Operation doing business at

One Hamilton Road, Windsor Locks, Connecticut ("facility").

) Order No. 8029A

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CONSENT ORDER

STATE OF CONNECTICUT

DEPARTMENT OF ENVIRONMENTAL PROTECTION

a. One open top vapor degreaser, unit no. E63847, is operated in accordance with

Section 22a-174-20(l) of the Regulations of the Connecticut State Agencies

("Regulations.")

e. Twenty-one (21) test rigs that are located at the facility's fuels research laboratory

and use "aviation fuels", which are identified hereinafter as "JP-4," "JP-8," "Jet

A" and "Iso-octane".

c. Solvent recovery still unit no. F0651 uses "VERTREL," a VOC containing

solvent and solvent recovery still unit no. F0652 uses an exempt VOC.

I. This order supersedes Consent Order No. 8029, dated July 31, 1989, issued on November

29, 1989.

(Printed on Recycled Paper)

79 Elm Street _ Hartford, CT 06106-5127

www.cI.gov/dep

An Equal Opportunity Employer

b. One open top vapor degreaser, unit no. E45170, was installed prior to calendar

year 1980 and uses an exempt VOc.

3. At the facility, the Respondent currently operates the following Volatile Organic

Compound ("VOC") emitting stationary sources: two (2) open top vapor degreasers, unit

nos. E45170 and E63847; two (2) solvent recovery stills, unit nos. F0651 and F0652;

flush rigs; seventy-seven (77) test rigs and seventeen (17) surface coating spray booths.

The Respondent also performs hand wipe activities that use VOC solvents. Additional

details ofthese VOC emitting sources are as follows:

A. With the agreement of Hamilton Sundstrand, A United Technologies Company Cthe

Respondent"), the Commissioner of the Department of Environmental Protection

("Commissioner") finds the following:

HAMILTON SUNDSTRAND ,

A UNITED TECHNOLOGIES COMPANY

VS.

STATE OF CONNECTICUT
b. The Respondent shall maintain and keep records of all solvents added to vapor

6. According to the compliance plan:

h. Various hand wiping operations and associated used hand wipe storage vessels.

2 Order No. 8029A

a. Exempt VOCs are defined as those compounds explicitly excluded from the

definition of"VOC" in 40 CFR 51.1 OO(s).

I. The Respondent shall only use "non-VOC solvents," which term hereinafter means "0%"

VOC, or solvents that contain only exempt VOCs when operating open top vapor

degreaser unit no. E45170 and still unit no. F0652, which are both identified in paragraph

A.3 ofthis Consent Order.

g. Seventeen (17) surface coating spray booths subject to Control Technique

Guidelines adopted in Section 22a-174-20(s) of the Regulations and/or New

Source Review Permits ("NSR").

a. RACT for the vapor degreasers, stills, and hand wipe activities shall be the

RACT methods established in Consent Order No. 8029 referenced in paragraph

A.I ofthis Consent Order.

c. RACT for the test rigs should be work practice requirements because the rigs are

closed loop systems.

f. Fifty-six (56) test rigs, located throughout the facility, that use a calibration fluid,

presently stoddard solvent, to simulate aviation fuels.

b. The installation of additional control equipment for the test rigs is technically or

economically infeasible.

5. On September 8, 2004, the Respondent submitted for the Commissioner's review a

compliance plan dated September 2,2004 for the test and flush rigs. The compliance plan

has been reviewed and is hereby approved by the Commissioner with the conditions

specified in paragraph B ofthis Consent Order.

4. On February 10,2004, the Department determined that the potential VOC emissions

generated from the test rigs were over 25 tons. Pursuant to Section 22a-174-32 of the

Regulations, the test rigs are subject to the implementation of a Reasonably Available

Control Technology ("RACT").

B. With the agreement ofthe Respondent, the Commissioner, pursuant to Sections 22a-6, 22a171, 22a-174, 22a-I77, and 22a-178 of the Connecticut General Statutes, orders the

Respondent to take the following actions:

Hamilton Sundstrand
Hamilton Sundstrand 3 Order No. 8029A

degreaser unit no. E45170 and still unit no. F0652. This record shall include the

name of solvent added, date of when solvent was added and amount of the

solvent added.

2. The Respondent shall achieve a minimum recovery rate ofninety-five (95) percent ofthe

VOC being condensed for the solvent recovery still unit no. F0651 identified in

paragraph A.3 of this Consent Order. To ensure a 95% recovery rate, the Respondent

shall operate the condenser coil coolant temperature on still unit no. F0651 at or below

95% ofthe boiling point ofthe solvent in use.

3. The condenser coil outlet coolant temperature on still unit no. F0651 shall be monitored

by a trip alarm set to 95% ofthe boiling point temperature ofthe solvent in use.

4. The Respondent shall cease operation ofsolvent recovery still unit no. F0651 identified

in paragraph A.3 of this Consent Order, whenever the solvent recovery still coolant

temperature, circulating through the condenser coil exceeds 95% of the boiling point

temperature ofthe solvent in use.

5. All waste solvent (before being recovered in the solvent recovery still) and all waste

sludge residues (before being sent out as a waste product) must be stored in closed

containers.

6. All malfunctions ofthe solvent recovery still unit no. F0651 shall be documented and

such records shall be kept at the premises for at least five years after the date that the

record is made.

7. Except for the use of aviation fuels specified in paragraph A.3.e. ofthis Consent Order,

the Respondent shall use only calibration fluid as specified in paragraph A.3.f. of this

Consent Order or another physio-chemically equivalent compound with a vapor pressure

ofless than 3.1 mmHg at 70 of while performing fuel simulation in any existing or new

test rigs. Ifthe Respondent needs to use another VOC containing compound with a vapor

pressure greater than 3.1 mmHg at 70 of, the Respondent shall submit a report detailing

the technical and economic issues of using such compound(s) to the Department and

obtain the Commissioner's written approval prior to the use ofsuch compound(s).

8. The test rigs operated prior to the effective date ofthis Consent Order will be considered

"existing test rigs" for the purposes of this Consent Order. Any test rig that is not an

"existing test rig" but is later installed by the Respondent will be considered a "new test

rig" for the purposes ofthis Consent Order.

The Respondent shall notifY the Commissioner, in writing, within thirty (30) days ofthe

installation of a new test rig or the elimination of any existing test rig.

9. Within thirty (30) days from issuance ofthis Consent Order, the Respondent shall submit

to the Commissioner a report documenting, by site location, the unit identification

---------------------------------------
Hamilton Sundstrand 4 Order No. 8029A

number of each test rig and the name ofthe compound used in each test rig. Such report

may include, but is not limited to a table identifying building, unit identification number

and compound type.

10. The following work practices shall be followed by the Respondent for existing and new

test rigs:

a. At the beginning ofeach work shift, the Respondent shall inspectfittings and hoses

for leaks prior to operation of the rigs, and a log verifying these leak check

inspections shall be maintained at the rig, and initialed and dated by the person

performing the inspection. Leaks shall be fixed, whenever they are detected, and

recorded as such in the log. No rig is to be run until the leak is repaired.

b. Any spills during transfer to and from the supply reservoir or released from a

slipped hose fitting shall be immediately contained and cleaned. All wipe rags used

for spill cleanup shall be stored in a closed container until proper disposal.

c. After each run, the parts and hoses shall not be removed from the unit's drain table

until dripping has stopped.

d. The Respondent shall maintain and keep records ofall aviation fuels, or calibration

fluids, or other fluids dispensed to the test rigs and for spent fuels and fluids

removed from the test rigs as waste. These records should at a minimum include

the date, the fluid name and the amount in gallons or pounds. Records shall also be

made in accordance with paragraph B.12 ofthis Consent Order.

II. The following work practices shall be followed by the Respondent for the recycling and

disposal ofrags used for hand wipe activities:

a. All dirty cloth and paper rags, which are to be disposed of shall be stored in

covered containers until final disposal.

b. All dirty rags, which are to be cleaned and recycled, shall be stored in covered

containers until they are ready to be cleaned.

c. Rags being used for hand wiping shall not be visibly dripping VOC during use.

d. The dispensing containers for the solvents used in the hand wipe activities shall

be equipped with a lid or similar device that is closed when not in use.

12. Record Keeping. In accordance with Section 22a-174-32(g) of the Regulations, the

Respondent shall maintain for at least five years at such premises, and make available at

such premises for the Commissioner's inspection upon demand, the following:
Hamilton Sundstrand 5 Order No. 8029A

a. Purchase records for all materials which are used or stored at such premises

which contain VOCs.

b. For VOC emissions resulting from operating the test rigs, records ofthe name

of each compound, the vapor pressure of each compound, the percent VOC

content by weight of each compound, the amount of each compound used in

gallons and the amount of each compound's manifested waste.

c. The results of any VOC emissions testing performed pursuant to Section 22a174-32 (f) ofthe Regulations.

d. Documentation on the methodology used to calculate the facility's VOC

emissions including the calculation of waste.

13. Full compliance. The Respondent shall not be considered in full compliance with this

consent order until all actions required by this consent order have been completed as

approved and to the Commissioner's satisfaction.

14. Approvals. The Respondent shall use best efforts to submit to the Commissioner all

documents required by this consent order in a complete and approvable form. If the

Commissioner notifies the Respondent that any document or other action is deficient, and

does not approve it with conditions or modifications, it is deemed disapproved, and the

Respondent shall correct the deficiencies and resubmit it within the time specified by the

Commissioner or, if no time is specified by the Commissioner, within 30 days of the

Commissioner's notice ofdeficiencies. In approving any document or other action under

this consent order, the Commissioner may approve the document or other action as

submitted or performed or with such conditions or modifications as the Commissioner

deems necessary to carry out the purposes of this consent order. Nothing in this

paragraph shall excuse noncompliance or delay.

IS. Definitions. As used in this Consent Order, "Commissioner" meansthe Commissioner or

a representative ofthe Commissioner.

16. Dates. The date of "issuance" of this Consent Order is the date the Consent Order is

deposited in the U.S. mail or personally delivered, whichever is earlier. The date of

submission to the Commissioner ofany document required by this consent ordershall be

the date such document is received by the Commissioner. The date of any notice by the

Commissioner under this consent order, including but not limited to notice ofapproval or

disapproval ofany document or other action, shall be the date such notice is deposited in

the U.S. mail or is personally delivered, whichever is earlier. Except as otherwise

specified in this consent order, the word "day" as used in this consent order means

calendar day. Any document or action which is required by this consent order to be

submitted or performed by a date which falls on a Saturday, Sunday or a Connecticut or

federal holiday shall be submitted or performed by the next day which is not a Saturday,

Sunday or Connecticut or federal holiday.
Hamilton Sundstrand 6 Order No. 8029A

17. Certification ofdocuments. Any document, including but not limited to any notice, which

is required to be submitted to the Commissioner under this consent order shall be signed

by the Respondent or, ifthe Respondent is not an individual, by an individual who is an

authorized representative ofthe Respondent, in accordance with §22a-174-2a(a) ofthe

Regulations, and by the individual(s) responsible for actually preparing such document,

and each such individual shall certifY in writing as follows:

"I have personally examined and am familiar with the information submitted in

this document and all attachments thereto, and I certifY, based on reasonable

investigation, including my inquiry ofthose individuals responsible for obtaining

the information, that the submitted information is true, accurate and complete to

the best of my knowledge and belief. I understand that any false statement made

in the submitted information may be punishable as a criminal offense under §53a157b ofthe Connecticut General Statutes and any other applicable law."

18. Noncompliance. This consent order is a final order ofthe Commissioner with respect

to the matters addressed herein, and is nonappealable and immediately enforceable.

Failure to comply with this consent order may subject the Respondent to an injunction

and penalties.

19. False statements. Any false statement in any information submitted pursuant to this

consent order may be punishable as a criminal offense under §53a-157b ofthe

Connecticut General Statutes and any other applicable law.

20. Notice oftransfer; liability ofRespondent. Until the Respondent has fully complied

with this consent order, the Respondent shall notifY the Commissioner in writing no

later than 15 days after transferring all or any portion ofthe facility, the operations,

the site or the business which is the subject ofthis consent order or after obtaining a

new mailing or location address. The Respondent's obligations under this consent

order shall not be affected by the passage oftitle to any property to any other person

or municipality.

21. Respondent's obligations under law. Nothing in this consent qrder shall relieve the

Respondent of other obligations under applicable federal, state and local law.

22. No assurance by Commissioner. No provision ofthis consent order and no action or

inaction by the Commissioner shall be construed to constitute an assurance by the

Commissioner that the actions taken by the Respondent pursuant to this consent order

will result in compliance or prevent or abate pollution.

23. Access to facility. Any representative ofthe Department of Environmental Protection

may enter the facility without prior notice for the purposes of monitoring and

enforcing the actions required or allowed by this consent order.
Hamilton Sundstrand 7 Order No. 8029A

24. No effect on rights of other persons. This consent order neither creates nor affects

any rights of persons or municipalities that are not parties to this consent order.

25. Notice to Commissioner of changes. Within 15 days ofthe date the Respondent

becomes aware of a change in any information submitted to the Commissioner under

this consent order, or that any such information was inaccurate or misleading or that

any relevant information was omitted, the Respondent shall submit the correct or

omitted information to the Commissioner.

26. Notification of noncompliance. In the event that the Respondent becomes aware that

it did not or may not comply, or did not or may not comply on time, with any

requirement ofthis consent order or of any document required hereunder, the

Respondent shall immediately notifY by telephone the Bureau of Air Management

Unit identified in the next paragraph and shall take all reasonable steps to ensure that

any noncompliance or delay is avoided or, if unavoidable, is minimized to the greatest

extent possible. Within five (5) days ofthe initial notice, the Respondent shall submit

in writing the date, time, and duration ofthe noncompliance and the reasons for the

noncompliance or delay, and propose for the review and written approval ofthe

Commissioner, dates by which compliance will be achieved, and the Respondent shall

comply with any dates which may be approved in writing by the Commissioner.

Notification by the Respondent shall not excuse noncompliance or delay, and the

Commissioner's approval of any compliance dates proposed shall not excuse

noncompliance or delay.

27. Submission of documents. Any document required to be submitted to the

Commissioner under this consent order shall, unless otherwise specified in this

consent order or in writing by the Commissioner, be directed to:

Compliance Analysis and Coordination Unit

Department of Environmental Protection

Bureau ofAir Management

Compliance and Field Operations

79 Elm Street, 5th Floor

Hartford, Connecticut 06106-5127

28. Joint and several liability. Respondents shall be jointly and severally liable for

compliance with this Consent Order.
Hamilton Sundstrand

8 Order No. 8029A

Issued as a final order ofthe Commissioner ofthe Department of Environmental Protection.

Respondent consents to the issuance ofthis consent order without further notice. The

undersigned certifies that he/she is fully authorized to enter into this consent order and to legally

bind the Respondent to the terms and conditions ofthe consent order.

:3 "2001

I

Date: 9/31,109

Type Title:

7008 0150 0003 2915 9392

Type Name:

Signature:

TOWN OF WINDSOR LOCKS

LAND RECORDS

MAILED CERTIFIED MAIL,

RETURN RECEIPT REQUESTED

Certified Document No. _

~Q'~ Amearreua

Acting Commissioner