# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

STATE OF CONNECTICUT ) ) AND ) ) HAMILTON SUNDSTRAND CORPORATION ) TRADING AGREEMENT AND ORDERNO. 8109 MODIFICATION No. I

In the matter ofaTrading Agreement and Orderbetween the Commissioner ofEnvironmental Protection ("Commissioner") and Hamilton Sundstrand Corporation ("HSC"). WHEREAS, the Commissioner and HSC, having agreed to the terms and conditions set forth in Trading Agreement and OrderNo. 8109 signedby the Commissioner on April 29, 2003, do now, bymutual agreement, modify said Trading Agreement and Order as follows: 1. Delete paragraph A.3. and substitute the following therefor: U.S. Environmental Protection Agency ("EPA") Method 7E emission tests performed on the dates shown in Table 1 resulted in NOx emissions rates as follows: Table 1 HSC

- NO. EMISSION TEST RATES AND LIMITS (lbs/MMBtu) Boilers in Building # ] Boiler Fuel Heat input Test rate Test rate Test rate FLERs NO. Date MMBtu/br 5/95 5/99 2104 Limit Rate Next Test (5/00) Due Boiler#1 #6 oil 61 0.38 0.25 0.294 033 0.25 2/26/09

(Riley) Nat. Gas 0.26 0.12 0.175 N/A 0.20 2/24/09 Boiler #2 #6 oil 61 0.36 0.24 0.263 0.29 0.25 2/25/09

(Riley) Na\. Gas 0.27 0.08 0.160 N/A 020 2/24/09 Boiler #3 #6 oil 61 0.40 0.25 0.294 0.33 0.25 2/26/09

(Riley) Nat. Gas N/A 0.13 0.149 N/A 020 2/24/09 Boiler#4 #6 oil 73 0.44 (0.374) N/A NlA 0.25 Shut down

(CE) Boilers in Building # 3 Boiler Fuel Heat input Test rate Test rate Test rate FLER NO. Date MMBtu/br 5/95 1/99 12103 Limit Rate Next Test (5/00) Due Boiler#1 #4 oil 0.29 Ceased N/A 0.29 0.25 N/A (CS) #2 Oil 20.9 N/A 0.171 0.192 N/A 0.20 1/9/09 Na\. Gas 0.08 (0.111) 0.114 N/A 0.20 12118/08 Soiler#2 #4 oil 0.27 Ceased N/A 0.27 0.25 N/A (CS) #2 Oil 20.9 N/A 0.189 0.174 N/A 0.20 1/9/09 Nat. Gas 0.07 (0.102) 0.099 N/A 0.20 12/18/08

( Printed on Recycled Paper) 79 Elm Street • Hartford. CT 06106 - 5127 An Equal Opportunity Employer, ;


### Hamilton Sundstrand Corporation 2 

### Trading Agreement and OrderNo. 8109 ModificationNo. I

2. Delete paragraph A.7. and substitute the following therefor:
a. DEP witnessed emissions testing conducted April 1999 and May 2000, as indicated in Table I of this Trading Agreement and Order, showed that the NOx emissions rates from the boilers were reduced below the allowable NOx emission limits set forth in Section 22a-174-22 (e) ofthe Regulations. b. DEP witnessed emissions testing conducted February 2004, as indicated in Table I ofthis Trading Agreement and Order, showed that the NOx emissions rates from the boilers exceeded the allowable NOx emission limits set forth in Section 22a-174-22 (e) ofthe Regulations.
c. On June 30, 2004 HSC retired 22 DERCs to offset excess emissions from the boilers during the time period ofApril 1999 through February 2004. Included in the amountretired is an additional 100% (11 DERCs). 3. Change the termboiler4 in paragraph A.8. to: the boilers. 4. Delete paragraph A.9. and substitute the following therefor: HSC proposes to use the full load emission rates ("FLERs") in Table I, when burningNo.6 fuel oil, for the purposes ofcalculating DERCs required for the boilers. 5. Attachment 2 ofTrading Agreement and Order 8109 is deleted in its entirety and the appended Attachment 2 is substituted in lieu therefor. 6. Delete paragraph A.12. and substitute the following therefor: As documented in Attachment 2, incorporatedherein by reference in this Trading Agreement and Order, and shown in Table 3, since the installation oflow NOx burners in the boilers, HSC has generated 16.5 tons ofNOx DERCs (7.6 ozone and 8.9 non-ozone). Twentypercent ofthese DERCs (1.5 tons ozone and 1.8 non-ozone have beenpermanentlyretired to benefitthe environment. The total DERCs available for use afterthe environmental discount and rounding down to the nearest whole ton for annual serial number assignment is 8 tons (3 ozone and 5 non-ozone season). 7. Delete paragraph A. 13. and substitute the following therefor. ReservedHamilton Sundstrand Comoration 3 Trading Agreement and OrderNo. 8109 Modification No.1 8. Delete Table 3 and substitute the following therefor:

Table 3 Approved DERCs Generated from 1999 through 2003 (After roundine down to the nearest whole ton) Year of Ozone season Tons Non-ozone season Tons Expiration generation Date 1999 CT99/8109(DC)NOxoz(I) 1 CT99/81 09lDC1NOxnozlI) 1 12/31/04 2000 CTOO/81 09IDC)NOxoz(I) 1 CTOO/8109IDC)NOxnozi1-2) 2 12/31/05 2002 CT02/81 09(DC)NOxoz(l) 1 CT02/8109(DC)NOxnoz(I) 1 12/31/07 2003 CT03/8109(DC)NOxnoz(I) 1 12/31/08
9. Delete paragraph A.14. and substitute the following therfor: HSC shall cease operation ofBoiler4 in building 1 upon issuance ofthis Trading Agreement and OrderModification. 10. Change the amount ofDERCs specified in paragraph B.1. from 17 tons ( 8 tons ozone, 9 tons nonozone) to 8 tons ( 3 tons ozone,S tons non-ozone).
11. Delete paragraph B.2. and substitute the following therefor: The Commissioner, in accordance with the provisions ofthis Trading Agreement and Order, pursuantto Section 22a-174-22(j) ofthe Regulations, hereby allows HSC to complywith Section 22a-174-22(d) ofthe Regulations through use ofDERC trading to achieve the nitrogen oxide emission reduction required by Subdivision22a-174-22(d)(l) ofthe Regulations. 12. Change the date specified inparagraphs A.8., C.l., C.2., and C.13. from Apri130, 2007 to May 1, 2007. 13. Delete paragraph C.2.c. and substitute the following therefor: HSC shall comply during the operation ofthe boilers with FLERs shown in Table 1 in accordance with this Trading Agreement and Order. 14. Delete paragraphs C.3., C.4. and C.5., and substitute the following for each therefor: Reserved. 15. Delete paragraph C.6. and substitute the following therefor.Hamilton Sundstrand Corporation 4 Trading Agreement and OrderNo. 8109 Modification No. I
DERC Use. Until May I, 2007, before the first day ofeach monthHSC shall have in its possession sufficient approved DERCs for such month for the boilers in building I based on the following calculation:
a. Before the first day ofeach month, HSC shall estimate DERCs required for such calendarmonth for the boilers in building I when burning No.6 fuel oil as follows: Estimated DERCs (tons) use = {(Estimated fuel use in MMBtu) x «FLER)

- (0.95 x NOx allowable emission limit))}-i-2000 lbs/ton. Where:

• Allowable limit = allowable limitrate in Ibs/MMBtu shown in Table I ofthis Trading Agreement and Order.

• Full load emission rate (FLER) as shown in Table I ofthis Trading Agreement and Order.

• Discount (0.95) = 5% design margin applied to the allowable limitrate.

• Fuel heating value = 152,000 Btu/gal for No.6 fuel oil. b. No laterthan the twentieth day ofeach month, calculate and permanentlyretire actual DERCs used in the preceding calendarmonth for the boilers in building I when burning #6 fuel oil using the FLER as follows: Actual DERCs (tons) used = {(actual fuel use in MMBtu) x «FLER)

- (0.95 x NOx allowable emission limit))}-i-2000 lbs/ton 16. Delete paragraphs C.7. and C.8. and substitute the following therefor: Reserved. 17. Delete paragraph C.9. and substitute the following therefore: Upon issuance ofthis Trading Agreement and Order, ifHSC has reason to believe it maybe exceeding the FLERs for the boilers, HSC shall conductNOx emissions testing ofthe corresponding boiler on orbefore sixty (60) days after the exceedance ofthe above limits in accordance with the following:
I. HSC shall submit, for the Commissioner's review and written approval, an Intent-ToTest ("ITT") protocol not less than thirty (30) days priorto the emissions testing required pursuantto this paragraph and paragraph C.18 ofthis TradingAgreement and Order. The ITT protocol shall include at least: 11 The Department's Bureau ofAirManagementTestForm No. I, "Intentto Test".Hamilton Sundstrand Corporation 5 Trading Agreement and OrderNo. 8109 Modification No.1
111. System operating parameters indicative ofthe highest operating rate since the lastprevious stack test orthe mostrecentDepartment witnessed emission test which everis more recent, including, but not limited to: steam outputrate, temperature and pressure, fuel firing rate, and NOx emissions rate. IV. The ITT protocol shall provide that HSC shall perform testing as specified in Sections 22a-174-5 and 22a-174-22 ofthe Regulations. v. HSC shall perform all testing required by this Trading Agreement and Orderin accordance with the approved ITT protocol. VI. 

### In conducting and performing the testing required bythis Trading Agreement and Order, and analyzing the results ofsuch testmg, HSC shall adhere to methods specified in Sections 22a-174-5 and 22a-174-22 ofthe Regulations and as approved bythe EPA and the Commissioner. V11. HSC shall schedule all emissions testing so as to allow the Commissionerto be present during such testing and to independentlyverify facility operations, airpollution control equipmentparameters, and testing procedures. viii. Within 30 days after completing any emissions testing required bythis Trading Agreement and Order, HSC shall submit to the Commissioner a writtenreport providing the results ofsuch testing; within 15 days ofanotice from the Commissioner mdicating any deficiencies in such report, HSC shall submit a revised report. 18. Delete paragraph C.12. and substitute the following therefor: Annual Emission Statement. No laterthan March I, ofevery year after issuance ofthis Trading Agreement and Order, HSC shall include with the Annual Emission Statementprovided to the Commissioner, arecord ofeach sale or othertransfer, ofDERCs for the previous calendaryear. HSC shall also include actual NOx emissions from each boilerusing DERCs, and the amount ofall DERCs used including serial number (ifassigned), and approved DERCs purchased from other facilities. These reports shall be on a form prescribedbythe Commissioner and shall be in monthly increments, and by ozone and non-ozone seasons. 19. Delete paragraph C.14. and substitute the following therefor: DERC Shortfall. At aminimum, DERCs required shall be adjusted upwards by 100% ifDERCs are not in HSC's possession for use priorto the first day ofeach month or applicable season. However, nothing in this Tradinl;l Agreement and Order shall affect the Commissioner's authorityto institute anyproceeding ortake any other action to require additional upward adjustment, based on the gravity ofany alleged noncompliance or violation oflaw. HSC shall permanentlyretire the quantity of DERCs equivalentto the excess emissions plus a 100% premium within sixty (60) days ofHSC's discovery ofthe DERC shortfall. HSC shall certify andreport any such DERC retirement to the Commissioner in accordance with paragraph C.36 ofthis Trading Agreement and Order. 20. Deleteparagraph C.16. and substitute the following therefor:, 

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Hamilton Sundstrand Corporation 6 Trading Agreement and OrderNo. 8109 Modification No.1 FLERExceedance. Noncompliance with an established FLER shall subjectHSC to make restitution by matching the quantity ofemissions ("true up") caused bythe exceedance plus a 100% premium. The true up in tons ofDERCs shall be equal to the FLER exceedance in Ibs/MMBtu, multiplied by the total heat input during the period ofnoncompliance divided by 2000 Ibs/ton. Ifthe period of noncompliance is not known, the time period from the completion ofthe last/previous Commissioner witnessed emission test through the date the FLER compliance is achieved as approved bythe Commissioner shall be used. However, nothing in this Trading Agreement and Order shall affect the Commissioner's authority to institute anyproceeding ortake any other action to require additional upward adjustment, based on the gravity ofany alleged noncompliance orviolation oflaw. HSC shall permanentlyretire DERCs calculated in accordance with the above, plus a 100% premium, within sixty (60) days ofHSC's discovery ofthe FLER exceedance. HSC shall report any FLER exceedance to the Commissionerin accordance with paragraph C.36 ofthis Trading Agreement and Order. 21. Delete paragraph C.19. and substitute the following therefor: Extension. No laterthan May 1, 2007, with respect to theboilers, HSC shall complywith the requirements ofSection 22a-174-22(d)(l) ofthe Regulations. There is no assurance that after full programreview ofthis and otherTrading Agreements and Orders that the Commissionerwill grant a written extension ofthis Trading Agreement and Order. 22. Delete paragraph C.20. and substitute the following therefor: Future Compliance Report. On orbefore September I, 2006, HSC shall submit a report in writing to the Commissioner, as directed inparagraph C.37. ofthis Trading Agreement and Order, indicating how the facility shall comply with Section 22a-174-22 ofthe Regulations with respect to the boilers on and after May 1, 2007.
23. Deleteparagraph C.23. and substitute the following therefor: Definitions. As used in this Trading Agreement and Order,"the boilers" means boilers 1,2, and 3 in building 1; "Approved DERCs" are those for which the Commissionerhas provided written authorization for use in compliance with Section 22a-174-22 ofthe Regulations; "Commissioner" means the Commissioner or arepresentative ofthe Commissioner; "Non-Ozone season" means the period from October 1 through April 30 in any given calendar year. "Ozone season" means the period from May 1 through September 30 in any given calendaryear. 24. Delete paragraph C.24. and substitute the following therefor: Dates. The date of"issuance" ofthis consent orderis the date the consent order is deposited in the U.S. mail orpersonallydelivered, whichever is earlier. The date ofsubmission to the Commissioner ofany document required bythis consent order shall be the date such document is receivedbythe Commissioner. The date ofanynotice bythe Commissionerunderthis consent order, includingbut.'

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### • Hamilton Sundstrand Corporation 7 Trading Agreement and OrderNo. 8109 Modification No.1 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 oris personallydelivered, 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 orderto be submitted orperformed by a date which falls on a Saturday, Sunday or aConnecticut or federal holiday shall be submitted or performed bythe next day which is not a Saturday, Sundayor Connecticut orfederal holiday.
All otherterms and conditions ofTrading Agreement and OrderNo. 8109 issued bythe Commissioner acting under Chapter446c, Sections 22a-6, 22a-171, 22a-174, 22a-176, 22a-177 and 22a-178 ofthe Connecticut General Statutes shall remain in effect.

The Hamilton Sundstrand Corporation hereby consents to the entry ofthis modification to the Trading Agreement and Orderwithout further notice. Hamilton Sundstrand Corporation // 

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- 2-Qo( Issued as amodification ofan Order ofthe Commissioner ofEnvironrnental Protection.

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MAILED CERTIFIED MAIL, RETURN RECEIPT REQUESTED Certified DocumentNo.**~002** 2030 0006 5643 0017 v



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