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"). OrderNo. 8029A ) ) ) ) )

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) testrigs that are locatedatthe 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 OrderNo. 8029, dated July 31, 1989, issued onNovember 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 vapordegreasers, unit nos. E45170 and E63847; two (2) solvent recovery stills, unit nos. F0651 and F0652; flush rigs; seventy-seven (77) testrigs 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 CONNECTICUTb. The Respondent shall maintain and keep records ofall solvents added to vapor 6. According to the compliance plan: h. Various hand wiping operations and associated used hand wipe storage vessels. OrderNo. 8029A 2

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," whichtermhereinaftermeans "0%" VOC, or solvents that contain only exempt VOCs when operating open top vapor degreaser unitno. E45170 and still unit no. F0652, which are both identified inparagraph 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 OrderNo. 8029 referenced in paragraph A.I ofthis Consent Order.

c. RACT for the testrigs shouldbe workpractice requirements because the rigs are closed loop systems. f. Fifty-six (56) testrigs, located throughoutthe facility, that use acalibrationfluid, presently stoddard solvent, to simulate aviation fuels.

b. The installation ofadditional control equipment for the testrigs is technically or economically infeasible. 5. On September 8, 2004, the Respondent submitted for the Commissioner's review a compliance plan dated September2,2004 forthetestand flush rigs. Thecomplianceplan 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 ofthe Regulations, the test rigs are subject to the implementation ofa Reasonably Available Control Technology ("RACT").

B. With the agreementofthe Respondent, the Commissioner, pursuantto 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 SundstrandHamilton 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 aminimumrecoveryrate ofninety-five (95) percentofthe VOC being condensed for the solvent recovery still unit no. F0651 identified in paragraph A.3 ofthis Consent Order. To ensure a 95% recovery rate, the Respondent shall operate the condenser coil coolanttemperature on still unit no. F0651 at or below 95% ofthe boiling point ofthe solvent in use. 3. The condensercoil outletcoolanttemperature 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 ofsolventrecovery 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% ofthe 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 ofaviation fuels specified in paragraph A.3.e. ofthis Consent Order, the Respondent shall use only calibration fluid as specified in paragraph A.3.f. ofthis Consent Orderoranotherphysio-chemicallyequivalentcompoundwith avaporpressure ofless than 3.1 mmHg at 70 ofwhile performing fuel simulation in any existing or new testrigs. Ifthe Respondent needs to use anotherVOC containingcompound with avapor pressure greaterthan 3.1 mmHg at 70 of, the Respondent shall submita report detailing the technical and economic issues ofusing such compound(s) to the Department and obtain the Commissioner's written approval priorto the use ofsuch compound(s).
8. The testrigs operatedpriorto the effective date ofthis Consent Orderwill be considered "existing test rigs" for the purposes ofthis Consent Order. Any test rig that is not an "existing test rig" but is laterinstalled bythe Respondent will be considered a "new test rig" for the purposes ofthis Consent Order.
The Respondent shall notifYthe Commissioner, in writing, withinthirty (30) days ofthe installation ofa new test rig or the elimination ofany existing test rig.
9. Withinthirty (30) days from issuance ofthis ConsentOrder, the Respondent shall submit to the Commissioner a report documenting, by site location, the unit identification

---------------------------------------Hamilton Sundstrand 4 Order No. 8029A number ofeach test rig and the name ofthe compound used in eachtestrig. Suchreport may include, butis not limited to atable identifying building, unit identificationnumber and compound type. 10. The following work practices shall be followed by the Respondent for existing and new test rigs:

a. Atthebeginning ofeach work shift, the Respondent shall inspectfittings andhoses 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 slippedhose fitting shall be immediatelycontained andcleaned. All wiperags used for spill cleanup shall be stored in a closed containeruntil proper disposal.

c. Aftereach run, theparts andhoses shall notberemoved from theunit's draintable until dripping has stopped.
d. TheRespondent shall maintain andkeeprecords ofall aviationfuels, orcalibration 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 orpounds. Records shall also be made in accordance with paragraph B.12 ofthis Consent Order.
II. The following workpractices 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 OrderNo. 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 ofeach compound, the vapor pressure ofeach compound, the percent VOC content by weight ofeach compound, the amount ofeach compound used in gallons and the amount ofeach compound's manifested waste.

c. The results ofany 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 ofwaste. 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. Ifthe Commissionernotifies the Respondentthatany documentorotheractionis deficient, and does not approve it with conditions ormodifications, it is deemed disapproved, and the Respondent shall correctthe deficiencies and resubmititwithinthetime specifiedbythe Commissioner or, ifno time is specified by the Commissioner, within 30 days ofthe Commissioner's notice ofdeficiencies. Inapproving any documentorotheractionunder 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 inthis ConsentOrder, "Commissioner" meansthe Commissioneror a representative ofthe Commissioner.
16. Dates. The date of"issuance" ofthis Consent Order is the date the Consent Order is deposited in the U.S. mail or personally delivered, whichever is earlier. The date of submissionto the Commissionerofany documentrequired bythis consentordershall be the date such document is received bythe Commissioner. The date ofany notice by the Commissionerunderthis consentorder, includingbutnot limitedto noticeofapproval or disapproval ofany document or otheraction, 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 orperformed by a date which falls on a Saturday, Sunday or a Connecticut or federal holiday shall be submitted orperformed by the next day which is not a Saturday, Sunday or Connecticut or federal holiday.Hamilton Sundstrand 6 OrderNo. 8029A

17. Certificationofdocuments. Any document, includingbutnot limitedto anynotice, which is required to be submittedto the Commissionerunderthis 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 bythe individual(s) responsible for actuallypreparing 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 ofmy 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 orthe 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 ofother 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 Commissionerthat the actions taken by the Respondent pursuant to this consent order will result in compliance orprevent or abate pollution.
23. Access to facility. Any representative ofthe Department ofEnvironmental Protection may enter the facility without prior notice for the purposes ofmonitoring and enforcing the actions required or allowed by this consent order.Hamilton Sundstrand 7 OrderNo. 8029A 24. No effect on rights ofother persons. This consent order neither creates nor affects any rights ofpersons or municipalities that are not parties to this consent order.
25. Notice to Commissioner ofchanges. Within 15 days ofthe date the Respondent becomes aware ofa 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 submitthe correct or omitted information to the Commissioner.
26. Notification ofnoncompliance. 

### 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 ofany document required hereunder, the Respondent shall immediately notifY by telephone the Bureau ofAir Management Unit identified in the next paragraph and shall take all reasonable steps to ensure that any noncompliance or delay is avoided or, ifunavoidable, 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 ofany compliance dates proposed shall not excuse noncompliance or delay.
27. Submission ofdocuments. 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 ofEnvironmental Protection Bureau ofAir Management Compliance and Field Operations 79 Elm Street, 5th Floor Hartford, Connecticut 06106-5127
28. Joint and several liability. Respondents shall bejointly and severally liable for compliance with this Consent Order.Hamilton Sundstrand 8 OrderNo. 8029A

Issued as a final order ofthe Commissioner ofthe Department ofEnvironmental 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 

# 9/31,109 Date: 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