# )fi( STATE OF CONNECTICUT**~~~**

# ~m::~:RTMENT OF

# ENVI~ONMENTAL PROTECTION

) Trading Agreement The State ofConnecticut and) and Order No. 8112A ) United States Naval Submarine Base )



### Whereas, the CommissionerofEnvironmental Protection ("Commissioner") and United States Naval Submarine Base, New-London ("SUBASENLON") agree that it is in the public interest that they work cooperatively to improve the air quality within the State ofConnecticut and that the use ofdiscrete emission reduction credit (UDERC") trading to reduce nitrogen oxide (''NOx'') 

### emissions will 

### achieve this result in a timely and cost-effective manner.

A. At the request and wilh the agreement ofSUBASENLON, the Commissioner finds the following;**.~** 'J 

### '-- 1. This Trading Agreement and Order supercedes Trading Agreement and Order 8112 issued on April 30, 1999, and Trading Agreement and Order 8112 Addendum 1 issued on July 30, 2001.
2. SUBASENLON 

### is abranch ofthe Up.ited States government that owns and operates a

• aval Submarine training and maintenance facility at Groton, COIUlecricut ("facility").
3. At the facility, SUBASENLON operates the following fuel-burning equipment: one (1) diesel powered electric generator ("diesel generator 519") which is used exclusively for training <;Ifpersonnel 

### in the operation and maintenance ofsuch engines on board submarines, and boilers 1,2 and 3 ("boilers 1,2 and 3") that are subject to Section 22a-174-22, Regulations ofCoIUlecticllt State Agencies ("Regulations") pertaining to the control ofNOx emissions.
4. Emissions testing resulted 

### in NOx emission rates for diesel generator 519, in grams per horsepower hour ("g:mIHP-hr'') and boilers I, 2 and 3 in pounds per million British thermal units ("lbsIMMBru")"as follows:
Table 1 SUBASENLON Emission Test Results, Allowable Emission Limits and FLERs in gm/HP-br or IbsfMMBtu

Unit Fuel Emission Test 

### FLER Allowable Emission Next Rate Emission Test Date EmissionT #2oiVNat.Gas Limits est Due Gen. #519 

### ! #2 diesel oil 19.88 24.63 8 11/19/02 

### I 11/19107 Boiler 1 #2oillN"nl.Gas 0.145/0.086 0.143/0.J26 0.20 

## I 6/20/02 

## I 6/20/07 Boiler 2 #2oillN"at.Gas 0.158/0.096 0.144 10.099 

### I 0.20**6/19~20/02** 

### I 6/19-20/07 Boiler 3 #2oiVNat.Gas 0.134/0.090 0.134/0.076 

### I 0.20 I2I11/0l I 12111106 (Prinled on Retytled Paper) 79 Elm Sneet • Hm!ord, CT 06106

_S127 htlp:J/dep.SIlLe.tl.us ,\/> Equrz/ Oppor!u'lI/y**E,"p/o.~(,**U.S. Naval Submarine Base 

### 2 Trading Agreement and Order 8112 A



# ,'"1. """p .' 5. SUBASENLON is in excess ofthe allowable limits in Section 22a-174-22(e) ofthe Regulations as shown in Table 1 ofthis Trading Agreement and Order when operating diesel generator 519.
6. Depending on the training schedule, SUBASENLON operates diesel generator 519 in "standard operation" or as a "peakerunit". Pursuant to the Department of Environmental Protection ("Department") policy on 

### "Credit Tradingfor Sources with IrregularNOxEmissions" policy, with arevised date ofFebruary 27, 2001, attached hereto and incorporated byreference into this Trading Agreement and Order as Exhibit 1, each pe-mng unit has a peak dailyNOx emissions greaterthan three times the average daily emissions during the ozone season and is therefore considered to be a source with irregular NOx emissions.
7. Pursuant to Section 22a-174-220) ofthe Regulations SUBASENLON proposes to comply with Section 22a-174-22{e) ofthe Regulations, for diesel generator 519's emissions, through the use ofapproved DERCs until April 30, 2007 at the facility in ac.cordance with this Trading Agreement and Order.
8. Emissions testing perfonned forboilers I, 2 and 3 resulted in NOx emissions rates as shown 

### in Table I.
9. SUBASENLON is 

### in excess ofthe generation FLERs, as shown 

### in Table I, when operating boiler 1,2 and 3.
10. Based on findings by the Department on June 11, 2002, Notice ofViolationNOV No. 14895 was issued on June 20, 2002 to SUBASENLON for exceeding generation FLER limits for boilers 3 specified in Trading Agreement and Order 8112. On August 9, 2002, SUBASENLON voluntary notified the Department that boilers I and 2 also exceeded generation FLER limits specified in Trading Agreement and Order 8112. The exceedance ofthe three boilers resulted in the creation of 1 tons ofozone and 3 tons ofnon-Olone invalid credits during the time period since the previous emissions test.
II. 

### In response to NOV No. 14895, SUBASENLON agreed to retire without use, 4 tons ofvalid DERCs (I ton ofalone season and 3 tons ofnon-alone season) to replace 4 tons ofthe invalid DERCs, and retired without use another 4 tons ofvalid DERCs (I ton ofozone season and 3 tons ofnon-ozone season) for a 100% penalty premium.
12. The Commissioner, pursuant to Section 22a-174-22 ofthe Regulations, previously approved the NOx DERCs referenced 

### in Table 2 ofthis Trading Agreement and Order. DERC creation serial numbers ifassigned by the Deparonent to these previously approved DERCs are provided 

### in Table 2 ofthis Trading Agreement and Order. Unused DERCs are subject to the vintage restrictions ofthis Trading Agreement and Order. Dates after which the unused DERCs will no longer be eligible for use as a result ofthe vintage restrictions are provided in Table 2 ofthis Trading Agreement and Order in the expiration date column.

## u.s. Naval Submarine Base 3



# • TradingAgreement and Order 8112 A

Table 2 SUBASENLON
- DERCs Previously Purch.:ased .:and Gener:Hed (10 the extent nor alre.:adv used) Year Ozone Season NO:rDERC Ozone Non-ozone season NOx Non- Expir:ttion

of serial numbers Season DERC seri:tl numbers ozone Date Gen. DERCs seaSOD DERCs 1996 Generated SINNotassigned 14.2 Generated SINNot assi2Iled 17.1 12131/04 1996 Purchased SINNot**assi~ed** 26 N/A N/A 12131104 1997 Purchased SlN-Notassigned 19 N/A N/A 12131104 1997 Generated SIN Notassi2tled 1.74 Generated SIN NotassilZDed 11.07 

### I 12131/04 1998 CT2818112(DqNOxoz(l) I CT9818112(DqNoxnoz(I-4) 

## I 4 

### I 12131/04 1999 NlA N/A CT99/8112(DC Nomoz 1-4) 4 

### I 12131/04 2000 crOO/8112 DC)NOxoz(J) I crOO/8112(DC Nomoz 1·5) 5 12/31/05 2001 NIl\. N/A CTOl/8112mc Noxno 1·2) 

### I 2 12/31/06 2002 

### I cr02l8112(DC)NOxoz(l) 

### I I CT02I8112(DC)Noxnoz(I·2) 

### I 2 

### I 12131107 

### B. The Commissionerin accordance with the provisions ofthis Trading Agreement and Order, and pursuant to Sections 22a.174-22(d)(3), (e) and

## OJ ofthe Regulations hereby allows SUBASENLON to comply with Section 22a-174-22 ofthe Regulations through 

### use ofDERC trading and the emissions limitations at the facility as provided herein. 

# J .-c.

, , 

## -' With the agreement ofSUBASENLON, the Commissioner, actingunder Sections 22a-6, 22a-I71, 22a-174, 22a-I76, and 22a-177 ofthe 

### COIU1ecticut General Starutes, orders SUBASENLON as follows:
1. Upon issuance ofthis Trading Agreement and Order, SUBASENLON shall: 

### a) 0 

### longercreatenewDERCs usingboilers I, 2 and 3 at the facility; and b) Submit to the Commissioneracertification that it has retired withoutuse, 8

### tons ofDERCs to offset the FLER exceedance described in NOV No. 14895. 

### 2. Upon issuance ofthis 

### TradingAgreement and Order at the facility, SUBASENLON shall complywith Section 22a-I74-22 of

### the Regulations through emission reduction trading until the diesel generator 519 

### achieves pennanent compliance with the emission standard in Section 22a-174-22(e) ofthe Regulations orby April 30, 2007, 

### whicheveris earlier, as follows:

a. SUBASENLON·shall use approved DERCs as required under this Trading 

### Agreement and Order;
b. SUBASENLON shall have in its possession sufficient approved DERCs to meet the applicable NOx emission limits as allowed underthis Trading Agreement and Order; and

### U.S. Naval Submarine Base 4 

### Trading Agreement and Order 8112 A

c. SUBASENLON shall comply during operation ofeach peaking unil with the FLERs shown in Table I ofthis Trading Agreement and Order. 

### 3. DERCs use for Diesel Generator519

a. Until April 30, 2007 before the first day ofeach month SUBASENLON 

### shall have 

### in its possession sufficient approved DERCs for the upcoming ozone seaso.n, based on the following calculations (described also in Exhibit 

### I); 

# , Before the first day ofeach month SUBASENLON shall estimate DERCs 

### required for such month for the diesel generator 519 

### as follows: (i) At all times (mass calculation): EstimateDERCs (tons) on 

### amass basis = 

### [Number ofozonemonths x estimated gaVrnonth xheatinput in M:MBtulgal x (FLER 

### grarnsIHP-hr- (Allowable limit in grams/HP-hrx**0.95(1~)** 

### x EFF. (2) 

### x HP-hr/0.002544 MMBtu x Ibs/453.6 grams] + 

### 2000 pounds/ton. 

### Where: (l) 

### Equivalentto a5% 

### design margin (2)

### Manufacturer's engine efficiency = 37% 

### fordiesel generator 519. (il) 

### Dunne: the ozone season onlv (peak dav calculation):



# ,

.../ 

### The estimated

### maximum excess NOx emissions 

### (in Ibs) 

### on anyofthe 

### days projected by the Commissionerto be "moderateto unhealthful", "unhealthful" or "very unhealthful" dividedby 3 and then dividedby 13 (with the resull in Ions): 

### EstimateDERCs (in tons) = 

### [(Estimate excess NOx in lbs xmaximum estimated hoursi24 hrratio ofoperating hours) + 

### 3] + 

### [13Ibs/day/ton]
b. No laterthan October 30 of2003, 2004, 2005, and 2006 calculate and 

### permanentlyretire the DERCs used 

### in the precedingozone season as the greaterof: (i) the actual total excess emissions for the ozone season in 

### tons, as follows: 

### Actual DERCs (tons) on amass basis = 

### [Numberofozone months x actual gaVmonth xheat input in MMBtulgaJ x (FLER grams/HP-hr
- (Allowable limit in gramslHP-hrx 0.95» x EFF. x HP-hr/0.002544 

### MMBtu x Ibs/453.6 grams] + 

### 2000 poundsiton.

# u.s. ""aval Submarine Base 

### 5

OR Trading Agreement and Order 8112 A**.~** 

# J (ii) the actual excess NOx emissions (in Ibs) on any ofthe days projected bythe Commissioner to be "moderate to unhealthful", "unhealthful", or "very unhealthful", divided by 3 and then divided by 13 (with the result in tons):
DERCs (in tons) = [(Actual daily excess NOx in Ibs on a mass basis x actual h6un/24 

### hr ratio ofoperating hours) + 3) + 13 Ibs/day/ton] 

## , As described in Exhibit I ofthis Trading Agreement and Order, to the extentthat DERCs used to offset on peak day basis (method (ii)) exceed the total mass excess emissions (method (i», remaining DERCs may be used in the non-ozone season in the same or subsequent years L"rrough April 30, 2007.
4. SUBASENLON shall make and keep records of: daily fuel use and fuel type; excess NOx emissions; the number ofDERCs in its possession, created, purchased and used (by serial number ifassigned) each month, as 

### in accordance with the appropriate emission rates and limits in this Trading Agreement and Order; the number ofDERCs used 

### in the ozone season and non-ozone season (the remainder ofthe year), the daily ozone classification as forecasted bythe Commissioner on the previous day; well as documentation attesting to the fact that approved DERCs used 

### in the ozone season were created during the ozone season. Generator certification ofthis fact shall be sufficient.
5. Record Keeping. SUBASENLON shall retilin records and supporting documentation as described 

### in this Trading Agreement and Orderfor a 

### minimwn offive years,'commencing on the date such records were created. SUBASENLON shall provide the records specified above to the Commissioner within thirty (30) days ofreceipt ofa 'V.'litten request from the Commissioner. All records shall be maintained 

### in accordance with Sections 22a-174-4 and 22a174-22 ofthe Regulations.
6. Allowance Use. Pursuant to Section 22a-174-22(d)(3) ofthe Regulations, SUBASENLON may use NOx allowances, through April 30, 2007, pursuant to Section 22a-174-22(j) ofthe Regulations to achieve all or aportion ofthe reductions required by Section 22a-174-22 ofthe Regulations. Any allowance used for compliance with Section 22a-174-22(e) ofthe Regulations shall be subject to all resnictions and/orrequirements applicable to DERCs contained 

### in this Trading Agreement and Order;

. ./ 

### a. In nrder for SUBASENLON to use NOx allowances, SUBASENLON shall create a general account in EPA's NOx Allowance Tracking System (''NATS''); andU.S. Naval Submanne Base 

### 6 Trading Agreement and Order 8112 A
b. Each allowance used for compliance with Section 22a-174-22 ofthe Regulations shall be equivalent to one discrete emission reduction credit. Allowances shall be considered used for compliance with Section 22a174-22 ofthe Regulations when they are tr2nSferred from the facility's

Ox general account in the NATS to the CT State NOx Retirement Account (Account 

### ill CTOOO0000300 in the NATS).
6. DERC Doubling. At a minimum, DERCs required shall be adjusted upwards by 100% ifDERCs aI!e not 

### in SUBASENLON's possession prior to the first day ofeach month ofuse. However, based on the gravity ofnoncompliance, the Commissioner mayrequire additional upward adjustment.
7. Vinta2e Restriction. Forthe purposes ofcompliance with Section 22a-174-22 ofthe Regulations, DERCs/allowances shall only remain valid for five (5) caleodar years from the year ofthe generation/allocation ofsuch DERCs/allowances. DERCs/allowances older than five (5) calendar years from their creation/allocation are not valid for use for compliance with Section 22a-174-22 ofthe Regulations. Notwithstanding the above, DERCs/allowances generated/allocated prior to calendar year 2000 are valid for use for compliance with Section 22a-174-22 ofthe Regulations up to and including December 31,2004.
8. FLER Exceedance. Noncompliance with an established FLER shall subject SUBASENLON 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 IbsJM:MBtu, multiplied bythe total heat input during the period ofnoncompliance divided by 2000 lbs/ton. Ifthe period of noncompliance is not lmown, the time period from the completion ofthe last/previous Department witnessed emission test through the date the FLER compliance is achieved as approved bythe Commissioner shall be used. However, nothing 

### in this TradingAgreement and Order shall affect the Commissioner's authority to institute anyproceeding or take any other action to require additional upward adjustment, based on the gravity ofany alleged noncompliance or violation oflaw.
9. FLER Modification. FLERs set forth in Table I ofthis Trading Agreement and Order may be modified only after the consent ofthe Commissionerby wrinen modification oftrus Trading Agreement and Order.
10. Emissions Testing. Pursuant to Section 22a-174-22(k) ofthe Regulations, SUBASENLON shall conduct NOx emission tests ofthe units at least once every five years conunencing from the dates ofthe NOx emission tests for the diesel generator 519 and boiler.; 1,2 and 3 as provided in Table I ofthis Trading Agreement and Order.
II. Annual Emission Statement. No later than March I, ofevery year after issuance of this Trading Agreement and Order, SUBASENLON shaH include with the Annual Emission Statementprovided to the Commissioner, arecord ofeach sale or other transfer, and use ofany and all ofthe DERCs approved within and subsequent to issuance ofthis Trading Agreement and Orderuntil all such DERCs have been used. SUBASENLON shaH also include the amounts ofall DERCs used including serial

## u.s. Naval Submarine Base 7 

### Trading Agreement and Order 8112 A



# 3

· '



### ..

# . number (ifassigned) and/orpurchased from other facilities, and/or approved for the previous calendar year. These repoits shall be on a fonn prescribed by the Commissioner.
12. Program Review. After April 30, 2007 for the diesel generator 519, SUBASEI\'LON shall complywith the requirements ofSection 22a-174-22 ofthe Regulations. However, afterfull program review ofthis and otherTrading Agreements and Orders and ifdetermined to be appropriate, the Commissionermay grant written extension of this Trading Agreement and Order. Afterfull programreview, and ifthe Commissioner deems it appropriate, the Commissionermay allow the survival and use ofthese DERCs, subjectto the vintage restriction, beyond April 30, 2007.
13. Future Compliance Report. On 

### orbefore September 1, 2006, SUBASENLON shall submit a report indicating how the facility will comply with Section 22a-174-22 of the Regulations after April 30, 2007.
14. Full compliance. SUBASENLON shall notbe considered in full compliance with this Trading Agreement and Orderuntil all actions required by this Trading Agreement and Orderhave been completed as approved and to the Commissioner's satisfaction.
15. Approvals. SUBASEN"LON shall use best efforts to submit to the Commissioner all docwnents required by this Trading Agreement and Order in 

### a complete and approvable form. Ifthe Commissionernotifies SUBASENLON that any document or other action is deficient, and does not approve it with conditions ormodifications, it is deemed disapproved, and SUBASENLON shall correct the deficiencies and resubmit it within the time specified bythe Commissioneror, ifno time is specifiedby the Commissioner, within 30 days 

### ofthe Commissioner's notice ofdeficiencies. In 

### approving any document or other action under this Trading Agreement and Order, the Commissionermay approve the docwnent or other action as submined orperformed or with such conditions ormodifications as the Commissionerdeems necessary to carry out the pwposes ofthis Trading Agreement and Order. Nothing in this paragraph shall excuse noncompliance ordelay.
16. Definitions. As 

### used in this Trading Agreement and Order, "Approved DERCs" are those for which the Commissionerhas provided written authorization foruse in compliance with Section**22a~174-22** 

### ofthe Regulations; "Commissioner" means the Commissioner or arepresentative ofthe Commissioner; "Ozone season" means the period from May 1 through September 30 in any given calendar year. The date of "issuance" ofthis Trading Agreement and Orderis the date the Trading Agreement and Orderis deposited in the U.S. mail orpersonally delivered, whicheveris earlier.
17. Dates. The date ofsubmission to the Commissionerofany document required by this Trading Agreement and Order shall be the date such document is received by the Commissioner. The date ofany notice by the Commissioner under Trading Agreement and Order, including but not limited to notice ofapproval or disapproval

## u.s. Naval Submarine Base 8 Trading Agreement and Order 81!2 A



## ,

.. 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 Trading**Agreeme~t** and Order, the word "day" as used in this Trading Agreement and Order means calendar day. Any document or action which is required by this Trading Agreement and Orderto be submined orperformed by a date which falls on a Saturday, Sunday or a Cormecticut or federal holiday shall be submitted or perfonned by the next day which is not a Saturday, Sunday or Connecticut or federal holiday.



## , 18. Certification ofdocuments. Any document, including but not limited to any notice, which is required to be submitted to the Commissionerunder this TradingAgreement and Order shall be signed by SUBASENLON or, ifSUBASENLON is not an individual, by an individual who is an authorized representative ofSUBASENLON , 

### in accordance with Section 22a-174-2a(a) ofthe Regulations ofCormecticut State Agencies, and by the individual(s) responsible for actuallypreparing such document, and each such individual shall certify 

### in writing as follows: 

## "rhave personally examined and am familiar with the information submined in this docwnent 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 ofmyknowledge and belief. I understand that any false statement made 

### in the submined information is punishable as acriminal offense under §53a-157b ofthe Connecticut General Statutes and any other applicable law."
19. Noncompliance. This Trading Agreement and 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 Trading Agreement and Order may subject SUBASEN+.-ON to an injunction and penalties.
20. False statements. Any false statement in any infonnation submitted pursuantto this Trading Agreement and Orderis punishable as a criminal offense under Section 53a157b ofthe Connecticut General Statutes and any other applicable law.
21. Notice oftransfer, liability ofSUBASENLON. Unti! SUBASE ;LON has fully complied with this Trading Agreement and Order, SUBASENLO. shall notify the Commissioner 

### in writing no later than 15 days after transferring all or anyponion of the facility, the operations, the site or the business which is the subject ofthis Trading Agreement and Orderor after obtaining a new mailing or location address. SUBASENLON's obligations under this Trading Agreement and Order shall not be affected by the passage oftide to any property to any otherperson or municipality.
22. Commissioner's powers. Nothing in this Trading Agreement and Order shall affect the Commissioner's authority to institute anyproceeding or take any other action to prevent or abate violations oflaw, prevent or abate pollution, recover costs and natural resource damages, and to impose penalties forpast, present, or future violations oflaw. Ifat any time me Commissioner detennines that the actions taken

### U.S. Naval Submarine Base 

### 9 Trading Agreement and Order 8112 A



### 23.

24.



# ,- -). 

### by SUBASENLON pursuant to this Trading Agreement and Orderhave not successfully corrected all violations, fully characterized the extent or degree ofany pollution, or successfully abated orpreventedpollution, the Commissionermay institute any proceeding to require SUBASENLO to undertake further investigation or further action to prevent or abate violations orpollution.
SUBASENLON's obligations under law. Nothing in this Trading Agreement and Order shall relieve SUBASENLON ofother obligations under applicable federal, state and local law.' 

## , No assurance bv Commissioner. No provision ofthis Trading Agreement and Order and no action orinaction bythe Commissioner shall be construed to 

### constitute an assurance by the Commissionerthat the actions taken by SUBASENLON pursuant to this Trading Agreement and Orderwill result in compliance orprevent or abate pollution.
Access to premises. Anyrepresentative ofthe Department ofEnvironmental Protection may enterthe facility withoutpriornotice for the purposes ofmonitoring and enforcing the actions required or allowed by this Trading Agreement and Order.

.<':':10

- ... "

# . ..v 26. No effect on rights ofotherpersons. TIlls TradingAgreement and Orderneither creates nor affects anyrights ofpersons ormunicipalities that are not parties to this Trading Agreement and Order.
27. No CreatIon ofProoertvRights. 

### This Consent Order does not create anyproperty rights with 

### respect to these DERCs.
28.

. otice to Commissionerofchanees. Within 15 days ofthe date SUBASENLON becomes aware ofa change 

### in anyinformation submined to the Commissionerunder this Trading Agreement and Order, orthat any such information was inaccurate or misleading orthat any relevant information was omined, SUBASENLON shall submitthe correct or omined information to the Commissioner.
29. Notification ofnoncompliance. 

### In the eveDt that SUBASENLONbecomes aware that it did not ormaynot comply, ordidnot ormaynot comply on time, with any requirement ofthis Trading Agreement and Order or ofany document required hereunder, SUBASENLON shall immediately notifyby telephone the individual 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, SUBASENLON 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 wrinen approval of the Commissioner, dates by which compliance will be achieved, and SUBASENLON shall comply with any dates which may be approved in writing by the Commissioner. Notification by SUBASENLON shall not excuse noncompliance or delay, and the

## u.s. Naval Subrnanne Base 10 Trading Agreement and Order 8112 A



### .. Commissioner's approval ofany compliance dates proposed shall not excuse noncompliance or delay unless specifically so stated by the Commissioner in writing.
30. Submission ofdocuments. Any

### document required to be submitted to the Commissioner underthis Trading Agreement and Order shall, unless otherwise specified in 

### this Trading Agreement and Orderor in writing by the Corrunissioner, be directed to: 

### Mr. Roland L. Severance, 

### Jr., P.E.

" Emissions Trading Unit Compliance and Field Operations Division, 5th

### Floor Bureau ofAir

### Management Department ofEnvironmental Protection 79 Elm Street Hartford, Connecticut 06106

### U,S. Naval Submarin'e Base 11 Trading Agreement and Order 8112 A
SUBASENLON consents to the issuance ofthis Trading Agreement and Order without funher notice. The undersigned cenifies that he/she is fully authorized to 

### enter into this Trading Agreement and Order and to 

### legally bind SUBASENLON to the terms and conditions ofthe Trading Agreement and Order.

United States Naval Submarine Base



### Signature:

# -'7""'F£~.:>..!!""=;;'I'::---------- Name:**+="T=--,=;='7'-=.JJ."~~'** 

# _ Title:

# --''='''''"'===='''''---><==='---

_ Date: 30 ApfC 03



# .-

...

# "/- -.

,'. 

# -

,



### . Roc'lJ'e, 

### Jf 

# C7 on

# "':~---'4-_ .

## ...:1 ,2003. Issued as afinal Order oftbe Commissioner ofEnvironmental Protection

# /~ / //.f //' 

### /// 

# " 

# \**':~** 

## J

TOWN OF GROTON LAND RECORDS
MAILED CERTIFIED MAlL, RETURN RECEIPT REQUESTED Cenified Document No.



## , , G:1.TR.A.OING-RLSI.TRAD1NGORDERSINAVY·SUBBASE.R.LS\81 12ANavyPeakerFin31(J-29.()3**),d~**