SIP DESCRIPTION

- Devon PowerLLC Trading Agreement and Order No. 8251 Modification 1 I. SIP

- DESCRIPTION OF DERC CREATION AND/OR USE SIP SUMMARY TABLE Tradin2 Ae.reement and Order No. 8251 Devon Power 700 Naugatuck Devon CT 06460 Avenue Identifier 

# I Client 7741 Town # 105 Premise # 14 1 Sequence # Contact Ms. Cynthia Karlic Tel: (860) 343·6962 Fax (860) 343-6969**Ftegional~anager** Pollutant and Regulatory Standard: NOx 

# I Section 22a-174-22 ofthe Regulations of Connecticut State Agencies. Nonattainment Area Classification Severe Annual DERCs needed Estimated 0 Annual DERCs e:enerated Estimated 0 ComplianceTime Period Until ADri130, 2007. Max. Emission Rate: CEM and full load emission rate (FLER) for Generation and Use. (See Table 1below):
Table 1 NOx Emission Rates and AllowableLimits 

### Unit Fuel Maximum Stack Test FLER Allowable Date of Next PIR number Capacity (ppmvd) IbslMMBtu Rate Stack Stack MMBtuIhr IbslMMBtu Test TestDue 40MWGE Jet Fuel 1295 CEM CEM 0.20 NA NA

Turbines Nat. gas 

### " " " 0.20 " 

### " Ilthrul4 Non-olonec 

### " " " 0.15 

### " " 105-0040 105-0041 105-0042 105-0043
II. SPECIAL REQUIREMENTS
a. This Trading Agreement and OrderModification supersedes Trading Agreement and Order No. 8251 A issued on April 30, 2003. b. Calculations ofcredits used shall be as specified in Trading Agreement and OrderNo. 8251A.
c. Starting on October 1, 2003 and until April 30, 2007 during the non-Olone season Devon PowerLLC shall meet a non-ozone season emission limit of 0.15 IbslMMBtu ofheat input when operating on Jet fuel or natural gas.

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# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

STATE OF CONNECTICUT AND DEVON POWER LLC TRADING AGREEMENT AND ORDER NO. 8251 MODlFICATION NO. !


### TRADING AGREEMENT AND ORDER MODlFICATION In the matter ofaTrading Agreement and Orderbetween (he CommissionerofEnvironmental 

### Protection ("Commissioner") and Devon PowerLLC ("DP"). WHEREAS, the Commissionerand DP. having agreed to the [enns and conditions set forth in Trading Agreement and OrderNo. 8251 signed by the Commissioneron September 15, 2003, do now, by mutual agreement, modify saidTrading Agreement and Order as follows: 

### 1. Delete the date May 1,2005, and substitute therefor May 1, 2007, in paragraphs 

### A.4. and C.1. 2. Delete paragraph C.2. and substitute the following therefor: 

### DERC 

### use. Starting on October 1, 

### 2004, and until Mny 1, 2007, before the first day ofeach non-Olone season, DP shall have in irs possession sufficient approved DERCs for'the turbines based on the following:
a. Duling the nonwozone season: DP shall meet a non-ozone seasonal average emission limit of0.15 

### Ibs1MMEtu. Prior to October 1, 2004, October I, 2005 and October 1, 2006, DP shall estimate and acquire the amount ofDERCs or aJlowances required for such non-ozone season needed to comply with Section 22a-174-22(e)(3) of the Regulations as follows: Estimated DERCs (tons) 

### = [Estimated fuel use in MMBtu from October 1 through April 30 x (estimated seasonal average NOx emission rate in Ibs/MMBtu during October 

### 1 through April 30

- (0.95 x 0.15 IbslMMBtu))] 2000 pounds/ton. No laterthan May 31, 2005, May 31, 2006, and May 31, 2007, when the turbines have anon·ozone seasonal average actual NOx emission rate exceeding 0.15 IbslMMBtu, DP shall calculate and permanenrly retire [he amount ofDERCs used in the preceding non-ozone season as follows: (Prinled on Reey<::led Paper) 79 Elm Slrtt! • Ihtltord, CT 06106

_SI27 htlp:lldCp.Slalt .CI.IIS A.1t Equal Oppon
..ttiry EmployerDevon Power LLC 

### 2 Trading Agreement and OrderNo. 8251 Modification No. I Actual D.ERCs (tons) 

### = [Actual [ueluse in Ml\1Btu .from October 1 through April 30 x (nctual season<ll <lverage NOx emission rate in IbslMMBtu during October I through April 30- (0.95 

### x O.l5IbslMMBtu))] + 2000 poundslton. b. When the non·ozone season CEM·recorded NOx emission rate is used to calculate DERCs used by the turbines, DP shall include missing data c<llculatedin accordance with missing data substitution procedures under 40 

### CFR Part75.
c. DP shall not exceed any NOx permit limitations for the turbines. 3. Delete pamgraph C.7. and substitute the following therefor: DERC Shortfall. At a minimum, DERCs required shall be adjusted upwards by 100% ifDERCs are not in DP's possession for use prior to the first dayofeach non·ozone season. However, nothing in this Trading Agreement and Order shall affect the Conuriissioner's authority to institute any proceeding ortake any other action to require additional upward adjustment, based on the gravityofany alleged noncompliance or violation oflaw. DP shall pennanently retire the quantity ofDERCs equivalent to the excess emissions plus a 100% premium within sixty (60) days ofDP's discovery (Ifthe: HERr. s.hortfall. DP Sohall certify and report any such DERC retirement to the Commissionerin <!cconhlm.:e with paragraph C.26 ofthis Trading Agreement and Order. 4. Delete paragraph C.9. and substitute the following therefor: Extension. No later than May 1, 2007, with respect to the turbines, DP shall comply with the requirements ofSection 22a-174-22(d)(2)(A) ofthe Regulations. There is no assurance that afterfull program review ofthis and otherTrading Agreements and Orders thaUhe Commissionerwill grant a written extension of this Trading Agreement and Order. 5. Delete paragraph 

### C.IO. and substitute the following therefor: Future Compliance Report. On orbefore September 1,2006, UP shall submit a report in writing to the Corn.missoner, as directed in paragraph C.27. ofthis Trading Agreement and Order, indicating how the facility shall comply with Section 22a-174-22 ofthe Regulations with respect to the turbines on and after May I, 2007. 6. Delete p.:lragraph C.13. and substitute the following therefor:

### Devon Power LLC 

### 3 Trading Agreement and Order No. 8251 Modification No.1 Definitions. As llsed in this Trading Agreement and Order, "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 Commissioneror a representative ofthe Commissioner; "Non-olone sellson" means the period from October 1 through April 30 in any given calendar year. 7. Delele paragraph C.14. 

### and substitute the following therefor: Dates. The date of"issuance" ofthis Trading Agreement and Order is the date the Trading Agreement and Orderis deposited in the U.S. mail orpersonally delivered, whicheveris earlier. The date ofsubmission to the Commissionerof any documentrequired by this Trading Agreement and Order shall be 

### the date such document is receivedby the Commissioner. The date ofany notice by the Commissionerunderthis Trading Agreement and Order, including but not limited to notice ofapproval ordisapproval ofany document orotheraction, shall be 

### the date such notice is deposited in the U.S. mail oris personally delivered, whichever is earlier. Except as otherwise specified in this Trading Agreement and Order, the word "day" as used in this Trading Agreement and Ordermeans calendarday. Any document oraction which is required by this Tradi"ng Agreement and Order to be submiued orperfonned by adate which falls on aSaturday, Sunday or a Connecticutorfederal holiday shall be 

### submitted orperformed by the next day which is not aSalurday, Sunday orConnecticut orfederal huliJay. 8. Delete the word "individual" and substitute therefor the word "Section" in paragraph C.26. 9. Delete the name "Ms. Wendy Jacobs" from paragraph C.2? All other terms and conditions ofTrading Agreement and Orderno. 8251 issued by the Commissioner acting underChapter446c, Sections 22a-6, 22a-171, 22a-174, 22a-176, and 22a177 ofthe Connecticut General Statutes shall remain in effect.Devon Power

### LLC 4 Trading Agreement and Order No. 8251 Modification No. I
DP herebyconsents to the entry ofthis modification 10 the Trading Agreement and Order without funher notice. Devon Power

### LLC Signature: Type Name: Type Title: Date: 

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# Rf!J()fiu/ t.OUI({)f)lI7ed'J

# flla.rtfjer3-;(j-"QjIssued 

### as amodification ofan Order ofthe CommissionerofEnvironmental Protection.

Date



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