SIP DESCRIPTION - Norwalk Power LLC-Trading Agreement and Order

No. 8218A Modification 1

I. SIP - DESCRIPTION OF DERC CREAnON AND/OR USE

SIP SUMMARY TABLE

Tradin2 Al!reement and Order No. 8218A

Norwalk Power LLC Manresa Island Ave South Norwalk cr 06854

Identifier Clien' 7741 Town # ill Premise # 141 Sequence # 1:

Contact Ms. Cynthia Karlic Tel: (860) 343-6962 Fax (860) 343-6969

RC2ionai Mana2er

Pollutant and Regulatory Standard: NOx I Section 22a-174-22 of the Regulations of

Connecticut State Agencies.

Nonattainment Area Classification Severe

Annual DERCs needed Estimated 40 non-ozone

Annual DERCs generated Estimated 50 ozone (BDERCs)

Comnliance Time Period Un,il Anril 30 2007.

Max. Emission Rate: CEM and [ullload emission rate (FLER) for Generation and

Use. (See Table I below):

Table I

NOx Emission Rates and Allowable Limits

Unit Fuel Maximum Stack Test FLER Allowable Date of Next

PIR number Capacity (ppmvd) IbsIMMBtu Rate Stack Stack

MMBtulhr IbsIMMBtu _ Test Test Due

Boiler I #6 oil 1776 CEM CEM 0.25 NA NA

R-1l7-0028 #2 oil " " " 0.17 " " and Non-ozonec " " " 0.15 " .,

Boiler 2

R-137-0030

II. SPECIAL REQUIREMENTS

a. This Trading Agreement and Order Modification supersedes Trading Agreement and

Order No. 8218A issued on April 30, 2003.

b. Calculations ofcredits used or generated shall be as specified in Trading Agreement and

Order No. 8218A.

c. Starting on October 1,2003 and until April 30, 2007 during the non-ozone season: For

purposes of generating DERCs from the boilers at the facility, Norwalk Power LLC shall

use 0.15 IbslMMBtu of heat input when operating on No.6 fuel oil and/or No.2 fuel oil

as the non·ozone season baseline emission rate for the boiler. Ten (10) percent of all

DERCs (tons) generated by the boilers shall be retired by the facility and permanently

removed from all calculations on a non-ozone season basis to assure a benefit to the

environment.
STATE OF CONNECTICUT

DEPARTMENT OF ENVIRONMENTAL PROTECTION

TRADING AGREEMENT AND

ORDER NO. 8218A

MODlFICAT10NNO.l

AND

NORWALK POWER u..C

STATE OF CONNECTICUT

TRADING AGREEMENT AND ORDER MODlFICATION

In the matter of a Trading Agreement and Order between the Commissioner of Environmental

Protection ("Commissioner") and Norwalk Power u..c (''NP'').

WHEREAS, the Commissioner and NP, having agreed to the terms and conditions set forth in

Trading Agreement and Order No. 821BA issued on April 30, 2003, do now, by mutual

agreement, modify said Trading Agreement and Order as follows:

1. Delete the date September 3D, 2004, and substitute therefor May 1,2007, in

paragraphs A.9., c.l., C.2., C.3.a., C.3.a. footnote 3, C.3.b., C.3.c., C.3.d., C.3.e.,

C.3.f., and C.6.

2. Delete paragraph A.6. and substitute the following therefor:

Pursuant to Section 22a-174-220) of the Regulations, NP intends both to acquire

and generate approved DERCs until May 1, 2007 for boilers 1 and 2 at the

facility. Approved DERCs are defined for purposes of this Trading Agreement

and Order as those for which the Commissioner has provided written authority for

use in compliance with Section 22a-174-22 of the Regulations.

3. Delete paragraph B.I. and substitute the following therefor:

Comply with Section 22a-174-22(d)(I) of the Regulations through use. of Budget

Discrete Emission Reduction Credit ("BDERC") and DERC trading. '

4. Delete paragraph C.6.b. and substitute the following therefor:

,. ..

~j

During the non-ozone season:

During the period from October I through April 30, inclusive, each year until May

1, 2007, the boilers shall, in addition to meeting the 24-hour emission limit in

Table 22-1 of Section 22a-174-22 of the Regulations, meet a non-alone season

emission limit of 0.15 IbfM1v1Bm. Prior to October 1, 2003, October 1, 2004,

October 1, 2005, and October I, 2006, NP shall estimate and acquire the amount

of non-Olone season DERCs or allowances needed to comply with Section 22a-

(Printed on Recycled Paper)

79 Elm Street • Hartford, cr 06t06· 5127

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All Eq"a.l OpfH'rI""iry Employe'
1 orwalk Power liC 2 Trading Agreement and Order

No. 82l8A Modification No.1

C)

5.

6.

l74-22(e)(3) of the Regulations as follows:

Estimated DERCs (tons);;; [Estimated fuel use in :MMBtu from October 1 through

April 30 x (lower of the estimated seasonal average NOx emission rate or the

proportioned 24-hour allowable emission limit in IblMJv1Btu during October 1

through April 30 - (0.95 x 0.15IblMMBtu))J + 2000 pounds/ton.

No later than May 31 of 2004, 2005, 2006, and 2007, in addition to the DERCs

retired pursuant to paragraph C.6.a. of this Trading Agreement and Order, NP

shall calculate and permanently retire DERCs used in the preceding non-ozone

season as follows:

Actual DERCs (tons) = [Actual fuel use in MMBtu from October 1 through April

30 x (lower of the actual seasonal average NOx emission rate or the proportioned

24-hour allowable emission limit in lblMMBtu during October 1 through April 30

- (0.95 x 0.15lblMMBtu»J + 2000 pounds/ton.

Delete paragraph C.lO. and substitute the following therefor:

Annual Emission Statement and Non-Ozone Season Emission Statement. No later

than March 1 for the previous calendar year and July 30 (for the October through

April time period only starting in 2(03) of every year after issuance of this

Trading Agreement and Order, NP shall provide to the Commissioner, a record of

each sale or other transfer, and use of any and all of the DERCs approved within

and subsequent (Q issuance of this Trading Agreement and Order until all such

DERCs have been used or are no longer in NP's possession. NP shall also

include actual NOx emissions from the boilers and the amount of all DERCs used

(including serial numbers (if assigned) and approved DERCs generated and/or

purchased from other facilities), generated and/or approved for the previous

calendar year and October through April time period. These reports shall be on a

fonn prescribed by the Commissioner and shall be in monthly increments, and by

ozone and non-ozone seasons. '

Delete paragraph C.12. and substitute the following therefor:

DERC Shortfall. At a minimum, DERCs required shall be adjusted upwards by

100% if DERCs are not in NP's possession for use prior to the first day of each

month or applicable season. However, nothing in this Trading Agreement and

Order shall affect the Commissioner's authority to institute any proceeding or take

any other action to require additional upward adjustment, based on the gravity of

any alleged noncompliance or violation of law. NP shall permanently retire the

quantity of emissions caused by the exceedance plus a 100% premium within
Norwalk Power LLC 3 Trading Agreement and Order

No. 8218A Modification No.1

sixty (60) days of NP's discovery of the DERC shortfalL NP shall certify and

repon any such DERC retirement to the Commissioner in accordance with

paragraph C.31 of this Trading Agreement and Order.

7. Delete paragraph C14. and substitute the following therefor:

Extension. No later than May I, 2007, with respect to the boilers, NP shall comply

with the requirements of Sections 22a-174-22(d)(l) and 22a-174-22(d)(2)(A) of

the Regulations. There is no assurance that after full program review of this and

other Trading Agreements and Orders that the Commissioner will grant a wrinen

extension of this Trading Agreement and Order.

8. Delete paragraph C.IS. and substitute the following therefor:

Future Compliance Report. On or before September 1, 2006, NP shaIl submit a

report in writing to the Commissioner, as directed in paragraph C.32. of this

Trading Agreement and Order, indicating how the facility shall comply with

section 22a-174-22 of the Regulations with respect to the boilers on and after May

1,2007.

:0 All other terms and conditions of Trading Agreement and Order no. 8218A issued by the

Commissioner acting under Chapter 446c, Sections 22a-6, 22a-171, 22a-174, 22a-176, and 22a177 of the Connecticut General Statutes shall remain in effect.
Norwalk Power LLC 4 Trading Agreement and Order

No. 8218A Modification No. I

NP hereby consents to the entry of this modification to the Trading Agreement and Order without

fUllher notice.

Norwalk Power LLC

Signature;

Type Name:

Type Title ~/OnO-l EnVl(Dfl~1 rYl1lnllJe.r

Date 2~J,c;-atj

Entered as a modification of an Order of the Commissioner of Environmental Protection

numbered 8218A this _!.:/t.:::e-li.. __day of ....~~/~.~.

/( ,/

J~ Ld

MAILED CERTIFIED MAIL,

RETURN RECEIPT REQUESTED

Certified Document No.