# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

STATE OF CONNECTICUT AND 

### US Navy Submarine Base New London 

# l TRADING AGREEMENT AND ORDER NO. 8112 

# l ) ) 

### Whereas, the CommissionerofEnvironmental Protection ("Commissioner") and the United States Naval Submarine Base, Groton ("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 ofemissions reduction credit 

### ("ERes") trading ("creation" and "use") to reduce nitrogen 

### oxide ("NOx") emissions will achievethis result in atimely and cost-effectivemanner: A. 

### At the request and with the agreement ofSUBASENLON, the Commissionerfinds the fOllowing: 1. SUBASENLON is a 

### branch ofthe United States government thatowns and operates aNaval Submarine training and maintenance facility at Groton, Connecticut ("facility"). 2. At the facility, SUBASENLON operates the following fuel-burning equipment: two (2) diesel powered electric generators #29 and #519 ("generators"); six (6) steam boilers #Is, 1,2,3,4, and a#325 Kewanee ("boiler(s)"); and a heat recovery gas turbine ("turbine"). 3. Pennit#0096, for the heat recovery gas turbine is incorporated into this orderby reference and is attached hereto as Attachment A. 4. The items offuel burning equipment identified in paragraph A.2. above, are subjectto Section 22a-174-22, Regulations ofConnecticut State Agencies ("Regulations") pertaining to the control ofNOx emissions.



### Initials

..;:..**~4-'---** (Printed on**Ree:J:~d** Plpcr) /-.J 79 Elm Strecl • Harl[ord, CT 06106

- 5127 tillp:lldcp.5111C.CI.u5 A.n Equal OpporrlJ.niry £mplo)'u 

### 5.

6.

7. The heat recovery gas turbine identified in paragraph A.2. above is also subjectto Section 22a-I74-3(k)(I)(B) ofthe Regulations pertaining to requirements for NOx internal offsets. Based on manufacturer's rating data submitted by SUBASENLON, the emission rate for diesel generators #29 and #519, when firing #2 oil, is 18 and 19 grams ofNOx perbrake-horsepowerhourrespectively. When operated, these generators produce NOx emissions in excess ofthe 8 grams ofNOx per brakehorsepowerhour emission rate limit specified in Table 22-2 ofSection 22a-174- 22 ofthe Regulations. SUBASENLON proposes to compensate for the excess NOx emissions from diesel generators #29 and #519 through the use ofERCs pursuant to 

### Section 22a174-22G) ofthe Regulations. SUBASENLON proposes to obtain the required ERCs by acombination of: (a) Purchasing ERCs, and (b) using aportion ofthe em's on reductions from modification to boilers #1, 2 and 3 in accordance with


### Date

### ';'-~7-'i'i · ., 

# • , 

## i

, 

# , ; 

# f

, , 

### 1

'i 

# i 

# • 

# • ; ,NAVAL SUBMARXNE**TP~!t~** 

### AGREEMENT**&~** 

### ORDSR NO. 8112 paragr:lph A.9. to create NOx internal offsets as required pursuant to Section 22a-174-3(k)(

### J)(B) ofthe Regulations and (c) provide the remaining balance of emission reductions from boilers #1, 2 and 3 in accordance with paragraph A.9. to create ERCs. 

### 8. SUBASEm..ON proposes to create 

### ERCs and NOx internal offsets based on the following fuel burning improvements made to the operation ofBoilers #1, 2 and 3:

a. Fuel switching

- 1991 conversion from #6 oil to cleanerburning #2 fuel 

### oil and natural gas; and b. Burnermodification

- 1996 installation oflow-NOx burners

. 9. 

### SUBASENLONproposes to apponion these su:p1us emission reductions to create: (a) ERCs for diesel generators #29 and 

### #) 19, and (b) NOx internal offsets for the heat recovery gas turbine. The apportionment ofemissions reductions to ERCs and internal offsets will be based on calculations shown in this Trading Agreement and Order, the internal offset calculations 

### in Permit#0096, and the following schedule:


### a. 

## .£..B..C1- Prior to turbine start up, create ERCs durin$ operation ofboilers 

### #1,2, and 

### 3 based on the difference between the baselIne Reasonably Available Control Technology (RACT) limit 0.225 IbsiMMBtu for switching from #6 oil to #2 oil and natural gas (Section 22a-174- 22(f)(3)(B)) and the Depanment ofEnvironmental Protection (DEP) approved stack test results for the 10w-NOxburners, and; b. After turbine start up, create ERCs during operation ofboilers #1, 2, and 3 based on the difference between baseline permit #0096 limit 0.15 IbsJ1vfMBtu for #2 oil and natural 

### gas and the DEP approved stack test results for the low-NOx burners.


### c. Internal offsets

- After turbine stnrt up, permanently=Sec aside internal offsets from the operation ofboilers #1, 

### 2, and 

### 3 on a one-to-one basis based on the difference between the historical baseline 

### RA.CT .0.25 IbslMMBtu on #6 fuel oil and the permit#0096 limit of 

### 0.15 Ibs/tylj\1Btu.



### Date -2- 10. Diesel generators #29 and #519, depending on emissions and operating schedule are subjectto either (a) ERCs required for "mass" emissions units on,a monthly basis or 

### (b) ERCs**re~uired** for "peaking" units on aozone season basiS,**!h~se** units are considered' peaking units" when their total peak daily NOx emISSions are greater than three (3) times their average daily emissions during the,ozone season. Therefore, they are sub/'eet to the Credit Trading for Sources WIth Irregular NOx Emissions guide ioes ("peaking protocol") incorporated into this ofderby reference (Attachment B). The emiSSions calculated in accordance with the appropriate emissions prococols are as follows:

a. During the period June I. 

### 1995 through M:w 24. 

### 1996. the NOx emissions from diesel generating units #29 and #519 were 

### 19.65 tons [otal(14.8 tons peak ozone and 4,85 tons non-ozone).**Initial~~~~** 

### __

### NAVAL SUBMARINE T?ADING AGREEMENT AlID ORDER NO. 8112 b. During the period Mav 25.1996 through December 31. 1996. SUBASENLON used diesel generator#29 as an emergency generator 

### only, therefore generator#29 was exempt from RAeT 

### requirements for that period. Diesel generator#S 19 had 0.26 tons (0.04 ozone and 0.22 

### non-ozone season).

c. On :lnd after Januarv 1. 1997. SUBASENLON proposes to retum diesel generator#29 from emergency generator status to an electrical 

### power producingpeaking unit. d. During the period Januarv 1. 1997 through December 31. 1997. the actual quantity ofapproved ERCs required for operation of#29 and #519 diesel generators were 6.98 tons total (5.5 total tons on a peak. basis during the ozone season and 1.48 tons total in the non-ozone season).

e. On and after March 18.1998 based on DEP approval ofofficial stack testing conducted November4, 1997, #29 diesel generator meets the emission limits 

### in Table 22-2 emission limits in Section 22a-174-22 ofthe Regulations. 

### f During the period Januarv 1. 1998 through April 30. 2003. the anticipated quantity ofapproved ERCs required annually for operation of #519 diesel generator is approximatly 5.7 tons total (4.7 total tons on a peak basis during the ozone season and 1.0 tons total in the non-ozone season). The actual excess emissions will be calculated each year. 

### 11. Pursuant to Section 22a-174-22G) ofthe Regulations, SUBASENLON has purchased or created the following ERCs:

a. On Mav 24. 1996, pursuant to Section 22a-174·22(j) ofthe Regulations, SUBASENLON purchased 26 tons ofapproved ERCs to be used to compensate for excess NOx emissions from #519 and #.29 diesel generators since May 31, 1995. b.

.On March 15. 1997. SUBASENLON purchased an additional 19 tons of 'approved ERCs to be used to balance the anticipated excess NOx emissions from #29 generator's electrical powerproducing service (see paragraph A.10.c. above) until SUBASENLON can create a sufficient quantity ofERCs to become selfsustaining (see paragraph C.6. below).

c. SUBASENLON seeks approv:l1 for: During J:lnuarv 1. 1996 through December 31. 1996. a total of 31.3 tons ofdiscrete ERCs (14.2 tons ozone season and 17.1 tons 

### non-ozone season) created using boilers 1,2, and 3 in accordance with paragraph A.9. above, and;

. During Janu:lrv 1. 1997 through December 31. 1997. a total of 12.81 tons ofdiscrete ERCs (1.7-l tons ozone season and 11.07 I.

II.

Initialsk -3- 

### Date

# ·
NAVAL SUBMARINE**T~DING** 

### AGREEMENT A}ID ORDER NO. 8112
tons non-ozone season) created using boilers 1,2, and 3 in accordance with paragraph A.9. above. 

### These ERCs are net marketable ERCs afterapplying the following discounts. The Depanment requires that ERCs created be discounted to 

### guarantee the achievrnentofenvironmental goals. The ERCs created by SUBASENLONhave been discounted as follows:
l. 

### a 10% 

### discountto benefit the environment; and

11. a 10% discount factor due to the use ofstack tests in lieu of Continuous Emission Monitoring (CEMs) to verify emissions reductions. 12. Upon review and approval ofthe emission reduction credits 

### by the Commissioner, the emission reduction credits will conform to the requirements of Section 22a-174-22G) ofthe Regulations. Specifically, the reductions are: Real because they result in areduction ofactual emissions released into the 

### air, net ofany consequential increase in actual emissions resulting from shifting demand. The emission reductions are properly measured, recorded and reported. 

### Quantifiable becausethey are based on: (a) fuel switching; and (b) approved stack tests before and after installation ofthe low-NOx burners 

### as applied in an appropriate reliable and replicable protocol, providing 

### arate and total mass amount ofreduction. Surplus because they are not required by any Connecticut statute orregulation mandated by a current State Implementation Plan (SIP), and are not currently relied upon in any applicable attainment plan, any reasonable further progress plan or milestone demonstration. Permanentbecause the low NOx burners 

### are in place and operating and 

### an appropriate tracking system is in place to monitOr use ofERCs; Enforceable because the ERCs are approved by the Commissioner retrospectively. 

### B. The Commissioner, in accordance with the provisions ofthis Trading Agreement and Order, pursuantto Section 22a-

### t74-22(d)(4) ofthe Regulations, hereby allows for the use and creation ofapproved ERCs for purposes ofcomptia.'lce under Section 22a-174- 22(j) ofthe Regulations to achieve a portion ofthe nitrogen oxide emission reductions required by this Regulation and 

### as follows: 1. Approval ofSUBASENLON ERCs created. The Commissionerhereby approves use of:
a. 31.3 tons (14.2 tons ozone season and 17.1 tons non-ozone season) ofdiscrete NOx ERCs created during the period January 1, 1996, through December 31,1996, and;

# IniLial~~~~ _ -4-

### NAVAL SUBMARINE TRADING 

### AGREEMENI A}ID 

### ORDER NO, 8112 b,

a.



### c. b, 12.81 tons (1.74 tons ozone season and 11.07 tons non-OZQne 

### season) ofdiscrete NOx ERCs created during the period January 1,1997, through December 31,1997. 

### These ERCs are shown in SUBASENLON's creation spreadsheet and incorporated 

### by reference into this Trading Agreement and Order (See Att:lchment C). Such ERCs are approved, in accordance with this Trading Agreement and Order for purposes ofcompliance with Sections 22a-174-220) 

### and 22a-\74-3(1)(5) ofthe Regulations, 2. Approval QfSUBASENLON future ERCs created. Voen sufficient documentation that SUBASENLON has met the

### requtrements QfParagr:lphs C.6. through C.9., inclusive, ofthis Trading Agreement and Order, the Commissioner may provide written approval ofERCs created by SUBASENLON retrospectively, in addition to those created by paragraph B.1. above. Requests for approval ofall subsequentERCs created shall be submined in writing to the 

### Commissioner, Approved ERC, createdby SUBASENLON may be held or transferred to other sources. Discrete ERCs shall remain valid until they are used or through April 30, 2003, whichever occurs first. C. With the agreement ofSUBASENLON, the Commissioner, acting under Connecticut General Statutes Sections 22a-6, 22a-171, 22a-174, 22a-176, and 22a-177, orders 

### SUBASENLON as follows: 1. ERCs Required ruse). SUBASENLON shall acquire and or create and use approved ERCs, as required 

### in this Trading Agreemeot and Order. Approved ERCs shall beused for the period beginning Juoe I, 1995 and continuing until SUBASENLON achieves permanent compliance with the emission standards in Section 22a-174-22(e) ofthe Regulations, through April 30, 2003, whichever is earlier, subject to the following requirements: Prior to the Commissioner's initial approval ofERCs created on site, use only '·purchased" approved ERCs to compensate for excess NOx emIssions from #29 and #519 generators; : After the Commissioner's approval ofERCs created on site, 

### SUBASENLON may use any combination ofapproved ERCs either 'created by SUBASENLON or purchased from other approved sources. Approved ERCs for use in the ozone season must be "owned" by SUBASENLON prior to the ozone season. Approved ERCs for use in the non-ozone season must be "owned" by SUBASENLON prior to their use. 2. Prior to May 1,2003, SUBASENLON, during operation ofeach generator, shaH not exceed the full load emission Rates (FLERs), as shown in Table 1 below.

# !nitia1S~ -5- 

### Dace

### NAVAL SUBMARINE TPAQING .¥JREEMENI AND ORDER NO. 611,
Table I 

### ERe USE SUBASENLON· FLERS AND NO:,: EiYDSSrON RATES UNIT FUEL FUR ••• StackTest "RACT" Rale Rate" Rate Limits (gmIIlP.h,) (gm!HP·h,) (gmIHP·hr) Unit#29 #2 oil meets Table 22-2**7.8~"** 8 Genentor limiu Sl:l.rting 3118198 Unitil519 il2 oil 24.63- 23

..46- 8 Generator

••



# ... Stacktesting conducted [1/4/97 showed emission rate e;(ceeds Table 22·2, Section**22a·17~·22** ofthe Regulations. FLER of 19.8 gm/Hp-hrused from 6/1/95 to 12131/97 forERC.i required Wltil stacktesting conducted. Fl..ERand stackemissionrates may be revisedupon successful completion of approved stacktests and the Commissioner's m-iew andwritten approval. FLERof18.9 gmIhrbased on the #29 MFG n.ting (18 grnIHP·hr) was used 6/1/95 to 3/18198 forERes required until stacktesting conducted. Stack testing conducted 11/4197showed unit #29 meets Table 22-2 limits. 3. SUBASENLON shall calculate, obtain and permanently retire a quantity of approved ERCs equal to any excess NOx emissions during

## any period(s) since June 1, 1995 when the NOx Emissions have exceeded the limItS set forth in Section 22a-I74-22 ofthe Regulations. 

### Ifit is determined in the future that diesel generators #29 andlor#519 were operated such that the FLERs shown in Table 1 were exceeded, SUBASENLON shall calculate, obt.ain and permanently retire a quantity ofapproved ERCs equal to at least double (2:x) the excess NOx emissions resulting from such exceedance ofthe FLER. In addition, except as otherwise provided in**Paragr~ph** C.S. below, ifSUBASENLON fails to have sufficient approved ERes on hand prior to use, SUBASENLON shall obtain and pennanently retire a quantity ofapproved ERCs equal to at least double (2x) the amount ofERCs calculated pursuantto Pnragraph CA. below. 4. June Ii 1995 through April 30.2003

- To comply with the NOx emission reductions required pursuantto Section 22a-174·22G) ofthe Regulations, SUBASENLON shall priorto each ozone season, anticipate ifthe maximum peak emissions will exceed three times the average daily emissions for the upcoming ozone season and select to operate #29 andlor#519 diesel generators as either a Mass emissions unit(s) or Peaking emissions unit(s) and calculate and have on· hand sufficient approved ERCs as follows: for aMass emissions unit (non peaking) priorto each month, ERCs required to offset'excess emissions for generators 

### # 29 and 

### # 5 I9 on aMass basis, or; for aPeaking unit, prior to the ozone season ERCs required to offset excess emissions from Unit #29 and #519 generators in accordance with Credit Trading for Sources with Irregular Ox 

### Ca)

r 

### .·r Cb)

# InitialS~ -6- 

### Date

# ..

NAVAL SUBMARINE TRADING AGREEMENT AND ORDER NO. 8112

Date 

### Emissions guidelines. Table 1 above, therequirements of Par:lgr.:lph C.5. below,' and the following: 

### (c) Anticipated ERCs Required Mass Basis· Priorto each month, SUBASENLON shall estimate anticipated ERCs in tons required on a mass basis for#29 and #519 generators during the entire ozone season: ERes (tons) ona mass basis = 

### [Number of 

### ozone monthsxgal/monthx 

### heatinputinMMBtuigalx (FLERFamslHP-hr

- (RACTingrams/HP-hr x 

### 0.9j·)) x 

### UF."x

### HP-hr/O. 002)44

### MMBtu r 

### Ibsl4H6grams] + 

### 2000 pounds/ton.

• 5'10 design margin

•• Manufact'.lf'er's e:l.gine efficiency'"' j4"1o forif29 and 37% for #519. Cd) Anticipated ERCs Repuired Peak-Dailv basis

- SUBASENLON shall 

### calculate and have on hand priorto the stan ofthe ozone season at least 

### the quantity ofanticipated ozone season peak-dar. ERCs in tons by dividing**one~third** 

### ofthe maximum estimated 

### daIly ERCs (tons) on amass basis converted to Rounds, adjusted for the ratio ofoperating hours e.g" maximum estimated hours/24 

### hr· and divided by 13) as follows: 

### ERCs (tons)peak-daybasis = 

### [(maximum doily

### ERCs onamass basis in poundsx maximum estimatedhours/2-1 hr· ratio a/operatinghours)-':-3) + 

### 13 pounds/dayiton.

• Adjusted for#:S 19 unitonly Ce) Actual ERCs

- SUBASENLON shall determine and retire sufficient 

### approved ERCs to 

### offsetexcess emissions during the appropriate time period by repeating the calculations in paragr:lphs C.4., (a) through (d) above, using actual fuel use. The actual approved ERCs will be the ERCs calculated on the basis of: (i) Formass emissions, at the end ofeach month, the actual "Mass" ERCs required for that month, or; '(ii) 

### FQrpeaking emissions. at the end ofthe ozone season., the greater of: Total actual "Mass" ERCs required during the entireOZQne season orthe ma:'::imum individual**"Peak.~day"** 

### ERCs required on any predicted ozone alert day. To the extent that the number ofERCs used to offsetpeak day emissions exceeds the total mass ofexcess NOx emissions for the OZQne seasQn, the remaining mass value ofsuch ERCs may be carried forward fQruse in the winter (non-ozone season). Any unused ERCs may.be carried forward through April 

### 30. 2003 eXcept as may be limitedby this Trading Agreement and Order, orby regulation. Note: Ifthe anticipated method ofoperatiQn was incorrect and/or insufficient apprQved ERCs were on-hand as required, apremium in accordance with paragraph C.3. shall be required immediately.

# InitialS~ -7-

### NAVAL SUBMARINE TRADING AGREEMENT AND ORDER NO. 8112 5. Except as described in paragraph C.S.a. and C.S.b. below, SUBASENLON 

### shall acquire sufficient approved ERCs to assure that an adequate number of approved ERCs for use during the ozone season are available prior to each month 

### (orpriorto the start afthe ozone season for peaking units) and priorto use during the non-ozone season as follows:

a. For the Period ofJune 1. 1995 through M3V 24.1996. SUBASENLON shall retire a sufficientquantity ofapproved ERCs to offset excess emissions from #29 and #519 diesel generator.5,**~an** additional ten (10) percent premium for having passed the December 31, 1995 deadline without owning ERCs priorto use. 

### The peak. emissions for#29 and #519 diesel generators during this period were 21.69 tons (16.3 tons ozone and 5.34 tons non-ozone) (includmg the 10% premium for the period from December 31, 1995 through May 24, 1996, when SUBASENLON 

### first purchased ERCs). b. From Mav 25,1996 through December 31. 1996, During the period March 1996 to October 1996, #29 was used on an emergency generator status only. Unit#519 was not operated on any ozone days predicted by the DEP to be unhealthful. The 1996 mass emissions for#29 and #519 were 0.26 tons (0.04 tons ozone and 0.22 non-ozone).

c. From Januarv 1. 1997 through December 31. 1997, During the period January 1, 1997 through December 31, 1997 mass emissions for #29 and #519 were 6.98 tons (5.5 tons ozone and 1.48 nonozone). d. From Januarv 1. 1998 through April 30. 2003, Based on 1995 fuel use data, the approved ERCs required annually for the 1998

- Apri130, 2003 operation are anticipated to be 5.7 tons total (4.7 tons total on a**~eak.** basis (based on 0.71 tons mass) during the ozone season and .:1.0 tons m the nonozone season. (See SUBASENLON spreadsheet Attachment D).
At the end ofeach calendaryear, the actual excess emissions will be calculated for such year. The calculation ofexcess emissions shall be included in the annual report required in Paragraph £.2. ofthis Trading Agreement and Order. 6. 

### ERe Creation. SUBASENLON may create ERCs resulting from the installation of10w-NOx burners, using the emission reductions generated. by low-NOx burners for boilers #1, 2, and 3 in accordance with the followmg:

a. Prior to startup ofthe**~ew** turbine on April 3, 1997, ERCs created will be based on the difference between baseline RACT (0.225 IbslMMBtu) and the approved boiler stack test emission results shown in Table 2 below;



### Initial -8- 

### DateNAVAL SUBMARINE TRJl.DING AGREEMENT NJP ORDeR NO, 8112 

### b, 

### After the startup ofthe new rurbine, ERCs created will be based on the difference bet\\leen the baseline permit limit (O.151bs/lv:l1vIBru) and the approved boiler stack test emission results shown in Table 2 below.

Table 2 

### ERC CREAnON SUBASE.NLON TRADING SET

- RAer A.1'fD MOxEl\tIISSION RATES BASELIJ.'fES UNIT FUEL StackTut RACT Pennit R:l!e·· "Baseline" "Baseline" (lbll\ttMBru) Limits Limits· #2oiUNat.G:u (IbflvOv(Btu) (lbfl'v1J'vffiru) Boiler 1 #2oiliNat.Gas 0.143/0.126 0.225 0.\5 Boiler 2 #2oiliNat.Gas O.144fO.099 0,225 0.15 Boiler 3 #2oi1fl'.lat.Gas 0.134/0.076 0.225 0.\5



### •



# •• c, Creation "baseline" will be: (i) beforeturbine startup •RAeT (0.225 IbslM!v1Btu) (ti) afterstartUp' permit limit (0.15 IbslMIv1Btu)

. (iii) For boiler#2 we stack test results 0.162/0.095 (TOm 3/1196 to 4/1197 

### The dates for**low~NOx** 

### burners installation and startup ofthe heat recovery gas turbine are shown in Table 3 below.
Table 3 Low-NO:o.: BURNER mSTALLATION AND TURBINE STARTUP DATES UNIT Date Boiler I 8/6/96 Boiler 2 3n196 Boiler 3 1/1/96 Turbine Start up MJ/97 

### d.

e. 

### The creation discountwill be applied to the total ERCs created (10% environmental benefit and 10% for creation based on approved stack ·tests); and The request for approvals for E'RCs created shall be submitted in writing including supporting documentation to the Commissioner. After approval in writing by the Commissioner, SUBASENLON may use the approved ERCs to compensate for #519 and #29 diesel generator excess emissions ormay make the ERCs available to other sources. 7. 

### SUBASENLON shall calculate

### ERes created from using boilm 

### #1. 2 and 

### 3. in accordancewith paragraph A.9. above, as follows:

.. r 

### a. Prior to turbine start up.

Initial -9- 

### Date"

" 

### NilVIIL SQBMARINE**TRP~ING** 

### AGREEMENT 8}ID ORDER NO. &112 Monthly ERCs (tons) [(fuel use gal/month x heal inputMMBtuigal x (RACT baseline limit' in IblMMBtu

- stack test" in IblMMBtu)) -;. 

### 2000 pounds/ton] 

### x0.90 

### x0.90'"

• •• ••• RAeT baseline

## = 0.225 IbslrvUvlBru prior to turbine start up (See**Tabl~** 2) Stack test (see Table 2) Credit cre::nion distounL (Based on lO% for environment x 10% for stack test) b. After turbine st<lrt up Monthly ERCs (tons) 2 [(fuel use gaVmonth 

### xheat input MMBtuigal 

### x (Permit limit' in IblMMBtu

- stack test" in IblMMBtu)) -;. 

### 2000 pounds/ton]x 0.90 x0.90·"

• 

# .. ... Permit baseline limit

- 0.15 IbsIMMBru afterturbine start up (see Table 2) suck test (see Table 2) Creditcreation discount (Based on 10"10 for envi.

... onmentx 10-;. for stack test) 

### 8. The above calculations shall beperformedon forms prescribed by 

### the Commissionerfor each boiler and generatorusing actual fuel consumption 

### records. 9. SUBASENLON shall document, record, and maintain records offuel type, fuel consumption, heat input, and NOx emissions for boilers #1, 2, and 3, and the rurbine on a monthly basis. (Record keeping requirements for internal offsets are described in Permit#0096). Records for generators #519 and 29 shall be maintained on a daily basis (required for the peaking protocol). 10. SUBASENLON shall obtain and maintain information from the DEP's Daily Ozone Forecastreport to determine air quality days for the purposes of calculating peak-daily emissions requirements as described in Attachment B. II. SUBASENLON shall maintain documentation regarding the number ofERCs in its possession, created, purchased and used each month, as well as to attest to the fact that approved ERCs used in the ozone season were created:during the ozone season. All records shall be maintained in accordance with Section 22a-174-4 and 22a-174-22 ofthe Regulations and shall be provided to the Commissionerwithin thirty 

### 00) days ofreceipt ofa written request from the Commissioner. 12. SUBASENLON shall maintain documentation ofmaximum daily emissions, average daily emissions and maximum peak emissions during the ozone season for comparison ofmass orpeak status and calculate acrual ERCs in accordance with paragraph C.4. ofchis Trading Agreement and Order.



### Date 

### -10- D. Restrictions When ooerating on an anticipated peak basis during the QZQne season.

. S!:JBASENLON shall restrict

## the operating hours forunit#519 generatorto th.e anticipated number ofhours per day or shall be subjecttQ the 2x penalty premIum for the quantity emissions in excess ofthe anticipated hours. E. Olher Requirements.

# InitialS~

# .' 

# .'

NAVAL SUBMARINE 

### TPAQING AGREEMENT**~ND** 

### ORDER NO, 6112 1. No laterthan 30 days afterthe execution ofthis Trading Agreement and Ordec 

### SUBASENLON shall develop and submitan ERC Creation Report showing actual fuel use, emissions and ERCs created by 

### boilers #1, 2and 3 for the months of: June, July, August, and September 1996, using the calculations specified in 

### this Trading Agreement and Order. In requesting approval ofcreation aruse ofERCs, SUBASENLON shall provide documentation containing monthly operating cepom ofactual fuel use for the boilers, emissions, and acalculation ofERCs created using the appropriate 

### baselines before orafterthe new turbine startup shown in Table 2and the lowNOx burnerinstallation and turbine startup date shown in Table 3. 2. No laterthan 30 days after the execution ofthis Trading Agreement and Order. 

### for the years 1995, 1996, and 1997, and no laterthan March 1, of 1999, 2000. 2001,2002,2003, and 2004, oruntil this Trading Agreement and Orderis tenninated, SUBASENLON shall submitto the Commissioneran annual report on approved NOx ERCs sold as well as thoseused by #519 and #29 generators, 

### including the quantity offuel consumed, by type, by eachboilerand generator during the previous calendaryear. This reportshall include adescription ofthe e),rtent to which compliance with the requirements ofthis Trading Agreement and Orderwas achieved for #519 and #29 generators for each month and ozone season. These reports shall be on fonns prescribed by the Commissioner. 3. SUBASENLON shall retain records and supporting documentation as described in this Trading Agreement and Orderfor aminimum offive years, commencing on the date such records were created. 4. On orbefore Seotember I. 200?, SUBASENLONshall submit a report indicating how the Naval Submarine Base facility shall comply with Section 22a-174-22 of the Regulations afterApril 30, 2003. 5. Definitions. 

### As used in this Trading Agreement and Order, "Commissioner" means the CommissionerofEnvironmental Protection or an agent ofthe

. Commissioner. Approved ERCs are defined for purposes ofthis order as those for which the Commissionerhas provided wrineo authorization for use in compliance with Section 22a-174-22 ofthe Regulations. "Ozone season" means the period from May I through September30 in any given calendaryear. 6. Notification ofnoncompliance. In the event that SUBASENLON becomes aware that itdid notor may not comply, ordid notormay not comply on time, with any requirement ofthis Trading Agreement and Orderorofany document required hereunder, SUBASENLON shall immediately notify the Commissionerand shall take all reasonable steps to ensure that any noncompliance ordelay is avoided or, ifunavoidable, is minimized to the greatestextent possible. In so notifying the Commissioner, SUBASENLON shall state in writing the reasons for the noncompliance ordelay and propose, for the review and written approval ofthe Commissioner, dates by which compliance shall 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 ordelay, an.d the Commissioner's approval ofany compliance dates proposed shall not excuse noncompliance ordelily unless specifically so**~e** 

### Commissioner inwriting,
Initials -11- Date -+-,27·,/9

### WIVAL SUBMARINE 

### TRADING AGREEMENT AND ORDER NO. 8112
7. Certification ofdocuments. Any 

### document, includingbutnot limited to any notice, which is required to be submitted to the Commissioner under this Tradino 

### Agreement and Ordershall be signed by 

### the chiefexecutiveofficerof .=> SUBASENLON

### oraduly authorized representative ofsuch officer, as those terms are defined in Section 22a-430-3(b)(2) ofthe Regulations, and by the individual or individuals responsible for acrually preparing such document, each ofwhom shall examine and be familiar with the information submitted in the document and all attachments thereto, and shall make inquiry ofthose individuals responsible for obtaining the information to determine that the information is true, accurate, and complete, and each ofwhom 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 certify that based on reasonable investigation, including my inqUiry ofthose individuals responsible for obtaining the infonnation, the submitted Information is true, accurate and complete to the best of

## my knowledge and belief. 1understand that any false statement made in the submItted information may be punishable as a criminal offense under Section 22a-l75 ofthe Connecticut General Statutes or, in accordance with Section 22a-6 ofthe Connecticut General Statutes, pursuant to Section 53a-157b ofthe Connecticut General Statutes, and in accordance with any other applicable stafilte." 8.



### 9.

10. Final Agreement and Order. This Trading Agreement and Order is the final agreement and order by and between the Commissioner and SUBASENLON with respect to the matters addressed herein, and shall not be modified without the written agreement ofboth parties. False statements. Any false statement in any information submitted pursuant to this Trading Agreement and Order may be punishable as a criminal offense under Section 22a-175 ofthe Connecticut General Statutes or, in accordance with Section 22a-6, under Section 53a-157b ofthe Connecticut General Statutes. 

### Notice oftransfer: liabili'v ofSUBASENLON and otbers Until SUBASENLON has fully complied with this Trading Agreement and Order, SUBASENLON sball notify the Commissioner in writing no later than fifteen (15) days after transferring all or any portion ofthe facility, the operations, the site or the busines's which are the subject ofthis Trading Agreement and Order, or obtaining a new mailing or location address. My license transfer shall be conducted in accordance with Section 22a-60 ofthe Connecticut General Statutes. SUBASENLON's obligations under this Trading Agreement and Order shall not be affected by the passage oftitle to any property to any other person or municipality. Any future owner ofthe site may be subject to the issuance ofan order from the Commissioner.



# '/n-99 Date 

### -12- Commissioner's powers. Nothing in this Trading Agreement and Order shall affect the Commissioner's authonty to institute any proceeding ortake any other action to prevent or abate violations oflaw, prevent or**ab~te poll~tion,.**  recover costs and natural resource damages, and to impose penalties .forViolations oflaw which are willful or criminally negligent or for which penalties have not been specifically provided in this Trading Agreement and Order, including but not limite to violations ofany permit issued by the Commissioner. 

### Ifat any time the 

### II.

Initials

# -sj~~t~·' "



### NAVAL 

### SUBMARINE TRADING AGREEMENT AND ORDER NO. 811< Commissionerdetermines that the actions taken by SUBASENLON pursuant to this Trading Agreement and Order have not 

### fully achieved compliance with Section 22a-174-22 ofthe Regulations, the Commissionermay institute any 

### independent proceeding against SUBASENLON and/orrequire SUBASENLON to undertake further investigation or further action. 

### 12. SUBASENLON's obligations under law. Nothing in this Trading Agreementand Ordershall relieve SUBASENLON ofotherobligations underapplicablefederal, state and local law. 13. Access tQ records and facilitv. Any representative ofthe Depanment of 

### Environmental Protection may enterthe facility and inspect and copy records within 

### normal business hours without priornotice for the purposes ofmonitoring

. and enforcing the actions required or allowed 

### by this Trading Agreement and

Order. 14. No effect on 

### rights ofotherpersons. This Trading Agreement and Order shall neither create nor affect any rights ofpersons who or municipalities which are not parties to this Trading Agreement and Order. 15. No creation ofpropertv rights. This Trading Agreement and Order does not create any property rights with respect to these ERCs. 16. Notice to Commissionerofchanges. Within fifteen (15) days ofthe date SUBASENLON becomes aware ofa change 

### in any information submined to the Commissionerunder this Trading Agreement and Order, orthat any such information was inaccurate or misleading orthat any relevant infonnation was omined, SUBASENLON shall submitthe correct oromined infonnation to the Commissioner. 17. Submission ofdocuments. Any document required to be submined to the

. Commissionerunder this Trading Agreement and Ordershall, unless otherwIse specified in writing by the Commissioner, be directed to: 

### Mr. Roland L. 

### Severance, Jr., P.E. DepanmemofEnvironmental Protection .Bureau ofAir Management Compliance and Field Operations Division Emissions Trading Unit 79 

### Elm Street Hartford, Connecticut 06106

# InitialS~

-13- 

### Date 

## 10·990' ,-



### NAVAL SUBMARINE TRADING AGREEMENT**~~** 

### ORDER NO, 6112 SUBASENLON consents to the issuance ofthis Trading Agreementand Order withoutfurther notice. The undersigned certifies that he/she is fully authorized to enterinto this Trading Agreement and Orderand to legally bind SUBASENLON to the tenns and conditions ofthe 

### Trading Agreement and Order, 

### By the United States Naval Submarine Base New London ("SUBASENLOW)



### Signarure:

# :::;il~~~~~~~t+--- TypeName:**~alJl"UJ.J"""tLbd!J=lUL...."",,-N!,,-·** 

### Type Title: Commanding Officer 

### Date: 

## J/.,27,

## qq

Issulas..

# .aPJk~l consent

### orderofthe 

### Commissionerof

### Environmental Protection

### on~D,1999,

TOWN OF GROTON LAND RECORDS MAlLED CERTIFIED ivlAJI., 

### RETURN RECEIPT REQUESTED Certified Document

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