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STATE OF CONNECTICUT

DEPARTMENT OF ENVIRONMENTAL PROTECTION l

In the matter of

The State of Connecticut and

United Technologies Corporation

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Trading Agreement

and Order No. 8134A

Modification 1

Whereas, the Commissioner of Environmental Protection ("Commissioner") and United

Technologies Corporation (P&W) having agreed to the terms and conditions set forth in

Trading Agreement and Order 8134A issued on April 15,2003, do now, by mutual agreement,

modify said Trading Agreement and Order as follows:

1. Delete paragraph A.l. and substitute the following therefor:

P&W is a company which owns and operates jet engine manufacturing facilities at 400

Main Street, East Hartford, Connecticut (facility 1") and Aircraft Road, Middletown,

Connecticut (facility 2").

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

At facility 1, P&W owns and operates three (3) dual-fuel burning boilers, numbered 6,

8, and 9 ("facility 1 boilers"), capable of burning natural gas or No.6 fuel oil. At

facility 2, P&W owns and operates two (2) No.6 fuel oil burning boilers, numbered 2

and 4 ("facility 2 boilers") and jet fuel burning production GG-8 gas turbine engines

("facility 2 engines"). At facility 2 similar production GG-8 gas turbine engines are

tested in test cells. The facility 1 boilers, facility 2 boilers, and facility 2 engines are

subject to Section 22a-174-22 of the Regulations of Connecticut State Agencies

("Regulations"), pertaining to the control of NOx emissions.

3. Delete paragraph A.3. and Table 1 and substitute the following therefor:

Official U.S. Environmental Protection Agency ("EPA") Reference Method 7

emission testing perrormed on December 22,2005 for the facility 2 boilers, January

25,26, and 27, 2006 for the facility 1 boilers, and April 19,2006 for the facility 2

engines resulted in NOx emission rates as shown in Table 1 below:

(Printed on Recycled Paper)

79 Elm Street • Hartford. CT 06106 - 5127

An Equal Opportunity Emplo_ver
United Technologies Corporation 2

TABLE 1

Trading Agreement

and Order No. 8134A

Modification I

Heat Steam Test

Facilityl Fuel Input Production Steam %of Test FLER* RACT*

Equipment Limitation Limitation Production MRC Rate*

MMBtulhr Lbs steamlhr Lbs

steamlhr

Facility 1 - Nat. gas 143 120,000 116,700 97 0.327 .36 0.20

Boiler no. 6 #6 oil 144 125,000 122,600 98 0.434 .48 0.25

Facility 1 - Nat. gas 171 125,000 123,500 98 0.248 .27 0.20

Boiler no. 8 #6 oil 182 130,000 123,300 95 0.320 .35 0.25

Facility 1 - Nat. gas 165 120,000 118,400 99 0.241 .27 0.20

Boiler no. 9 #6 oil 171 125,000 122,300 98 0.309 .35 0.25

Facility 2 - #6 oil 106 73,334 69,473 95 0.337 .37 0.25 Boiler no. 2

Facility 2 - #6 oil 57 36,886 35,667 97 0.398 .44 0.25 Boiler no. 4

Facility 2- Jet fuel 283 N/A N/A 93** 346ppm 230 75 ppm Engines Iblbr

* Rates are in LbslMMBtu unless otherwise noted

** For GG8 Engine- % of MRC based on engine pressure ratio.

4. Delete paragraph A4. and substitute the following therefor:

On and after May 31,1995, Section 22a-174-22(e) of the Regulations requires that the

facility I boilers, facility 2 boilers, and the facility 2 engines emit NOx at rates no

greater than the RACT rates shown in Table I above. P&W proposes to use approved

DERCs or allowances for compliance purposes at facility 1 and facility 2 when and if

P&W chooses to operate the facility 1 boilers, facility 2 boilers and facility 2 engines on

fuels that exceed the RACT rates shown in Table 1 above.

5. Delete paragraph A5. and Table 2 in their entirety.

6. Delete paragraph A8. and Table 3 and substitute the following therefor:

P&W has agreed to accept the heat input and steam output operating restrictions on the

facility I boilers and facility 2 boilers as shown in Table 1.
United Technologies Corporation 3 Trading Agreement

and Order No. 8134A

Modification 1

7. Delete paragraph c.l. and substitute the following therefor:

After May 31, 1995, and through May 1,2009 or until P&W achieves compliance with

the emission standards in Section 22a-174-22(e) of the Regulations, whichever occurs

earlier, P&W shall acquire and retire approved DERCs and shall document and record

the amounts of all fuel and DERCs used by the facility 1 boilers, and facility 2 boilers

and engines, each month, and provide such records in accordance with the following

and Section 22a-174-22 of the Regulations:

8. Delete the date April 30, 2007 and substitute therefore the date May 1, 2009 in

paragraph C.l.h..

9. Delete paragraph c.I.a. and substitute the following therefor:

DERC Shortfall. At a minimum, DERCs required shall be adjusted upwards by 100% if

DERCs or allowances are not in P&W'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. P&W shall permanently retire the quantity of

DERCs equivalent to the excess emissions plus a 100% premium within sixty (60) days

ofP&W's discovery of the DERC shortfall. P&W shall certify and report any such

DERC retirement to the Commissioner in accordance with paragraph C.24. of this

Trading Agreement and Order.

10. Delete paragraph C.l.b. and substitute the following therefor:

No later than the twentieth day of each month, P&W shall calculate and permanently

retire DERCs used in the preceding calendar month for each boiler and engine, as

follows:

Boiler DERCs (in tons) = [((FLER in IbslMMBtu) - (0.95 x NOx allowable rate

in IbsIMMBtu)) x (fuel use in MMBtu)] .;- 2000 pounds/ton

Engine DERCs (in tons) = [Hours of Operation x (FLER in lbsihr) - (0.95 x

NOx allowable rate in IbsIMMBtu)) x (fuel use in MMBtu)] .;- 2000 pounds/ton

Where:
United Technologies Corporation 4 Trading Agreement

and Order No. 8134A

Modification 1

• NOx allowable rate =RACT rate shown in Tables 1 of this Trading

Agreement and Order.

• FLER = full load emission rate as shown in Table 1 of this Trading

Agreement and Order.

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

11. Delete paragraph C.2 and Table 4 and substitute the following therefor:

Prior to May 1,2009 P&W shall comply during operation on the fuels shown in Table 1

with the FLERs shown in Table 1, averaged on a 24-hour basis.

12. Delete the date May 1,2007 and substitute therefore the date May 1, 2009 in paragraphs

C.3., and C.7..

13. Delete paragraph CA. and substitute the following therefor:

FLERs, emission test rates and fuels set forth in Table 1 may be modified only after the

consent ofthe Commissioner by written modification of this Trading Agreement and

Order.

14. Delete paragraph C.5. and substitute the following therefor:

FLER Exceedance. Noncompliance with an established FLER shall subject P&W to

make restitution by matching the quantity of emissions ("true up") caused by the

exceedance plus a 100% premium. The true up in tons of DERCs shall be equal to the

FLER exceedance in Ibs/MMBtu, multiplied by the total heat input during the period of

noncompliance divided by 2000 lbs/ton. If the period of noncompliance is not known,

the time period from the completion of the last/previous Commissioner witnessed

emission test through the date the FLER compliance is achieved as approved by the

Commissioner shall be used. 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. P&W shall permanently retire DERCs calculated in

accordance with the above plus a 100% premium within sixty (60) days of P&W's

discovery of the FLER exceedance. P&W shall report any FLER exceedance to the

Commissioner in accordance with paragraph C.24. of this Trading Agreement and

Order.
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United Technologies Corporation 5 Trading Agreement

and Order No. 8134A

Modification 1

I.

2.

15. Delete paragraph C.6. and substitute the following therefor:

In accordance with Section 22a-174-22(k) of the Regulations, P&W shall conduct NOx

emission tests of the facility 1 boilers, facility 2 boilers, and the facility 2 engines at

least once every five years. Such NOx emission test shall be conducted prior to five

years from the date of the last test for each such unit.

16. Delete paragraph C.7. and substitute the following therefor:

From the date of the most recent NOx emission tests identified in paragraph A.3.

and prior to May 1,2009, P&W shall comply with paragraph 6 of this Trading

Agreement and Order Modification. P&W shall demonstrate compliance with

these limitations by monitoring and documenting hourly steam production.

However, if at any time after the date of the most recent emission tests specified

in paragraph A.3. during the period that this Trading Agreement and Order

remains in effect, P&W is unable to limit maximum rated capacity as stated

above, P&W shall conduct NOx emissions testing of the facility 1 boiler no. 6,

facility 1 boiler no. 8, facility 1 boiler no. 9, facility 2 boiler no. 2, or facility 2

boiler no. 4 on or before sixty (60) days after exceedance of the above limits in

accordance with the following:

a. P&W shall submit to the Commissioner for his review and written

approval an Intent-To-Test ("ITT") protocol not less than thirty (30) days

pnor to the emissions testing required pursuant to this Trading

Agreement and Order. The ITT protocol shall include at least:

The Department of Environmental Protection's Bureau of Air

Management Test Form No. I, "Intent to Test";

System operating parameters indicative of proper operation,

including, but not limited to, fuel firing rate, NOx emissions rate,

temperature and pressure, and steam production rate.

The ITT protocol shall rrovide that Respondent shall

perform testing as specified in Sections 22a-174-5 and 22a-174-22 of the

Regulations, includmg 0l?erating the facility 1 boiler no. 6, facility I

boiler no. 8, facility 1 boiler no. 9, facility 2 boiler no. 2, or facility 2

boiler no. 4 at not less than ninety percent (90%) of its maximum

capacity limit or highest operating rate since its previous emission test,

whichever is higher.

b. Respondent shall perform all testing in accordance with the approved

ITT protocol.

c. In conducting and performing the required testing, and in analyzing the

results of such testmg, Respondent shall adhere to methods specified in

Sections 22a-174-5 and 22a-174-22 of the Regulations and as approved

by the United States EPA and the Commissioner.

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United Technologies Corporation 6 Trading Agreement

and Order No. 8134A

Modification 1

18. Delete paragraph C.13. and substitute the following therefor:

17. Delete paragraph C.9. and substitute the following therefor:

Vintage Restriction. For the purposes of compliance with Section 22a-174-22 of the

Regulations, DERCs/allowances shall only remain valid for five (5) calendar years from

the year of the generation/allocation of such 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 of the Regulations.

Respondent shall schedule all emissions testing so as to allow the

Commissioner to be present during such testing and to independently

verify facility operatIons, air pollution control equipment parameters, and

testing procedures.

Within 30 days after completing any emissions testing required by this

Trading Agreement and Order, P&W shall submit to the Commissioner a

written report providing the results ofsuch testing; within 15 days of a

notice from the CommIssioner indicating any deficiencies in such report,

P&W shall submit a revised report.

e.

d.

Certification of documents. Any document, induding but not limited to any notice,

which is required to be submitted to the Commissioner under this Trading Agreement

and Order shall be signed by P&W or, ifP&W is not an individual, by an individual

who is an authorized representative ofP&W, in accordance with Section 22a-174-2a(a)

of the Regulations of Connecticut State Agencies, and by the individual(s) responsible

for actually preparing such document, and each such individual 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 I certify that based on reasonable

investigation, induding my inquiry of those individuals responsible for obtaining the

information, the submitted information is true, accurate and complete to the best of my

knowledge and belief. I understand that any false statement made in the submitted

information may be punishable as a criminal offense under section 22a-175 of the

Connecticut General Statutes, under section 53a-157b of the Connecticut General

Statutes, and in accordance with any applicable statute."

19. Delete paragraph C.24. and substitute the following therefor:

Notification of noncompliance. In the event that P&W becomes aware that it did not or

may not comply, or did not or may not comply on time, with any requirement of this

Trading Agreement and Order or of any document required hereunder, P&W shall
20. Delete the name "Ms. Wendy Jacobs" in paragraph C.25

22. Include a new paragraph C.27. as follows:

21. Include a new paragraph C.26. as follows:

Trading Agreement

and Order No. 8134A

Modification 1

7

immediately notify by telephone the section identified in the next paragraph and shall

take all reasonable steps to ensure that any noncompliance or delay is avoided or, if

unavoidable, is minimized to the greatest extent possible. Within ten (10) days ofthe

initial notice, P&W shall submit in writing the date, time, and duration of the

noncompliance and the reasons for the noncompliance or delay and propose, for the

review and written approval of the Commissioner, dates by which compliance will be

achieved, and P&W shall comply with any dates which may be approved in writing by

the Commissioner. Notification by P&W shall not excuse noncompliance or delay, and

the Commissioner's approval of any compliance dates proposed shall not excuse

noncompliance or delay unless specifically so stated by the Commissioner in writing.

Extension. No later than May 1,2009, , P&W shall comply with the requirements of

Sections 22a-174-22(d)(1) 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 written extension of this Trading Agreement

and Order.

Future Compliance Report. On or before September 1,2008, P&W shall submit a

report in writing to the Commissioner, as directed in paragraph C.25. of this Trading

Agreement and Order, indicating how the P&W shall comply with Section 22a-174-22

of the Regulations on and after May 1, 2009.

United Technologies Corporation

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United Technologies Corporation 8 Trading Agreement

and Order No. 8134A

Modification 1

All other terms and conditions of Trading Agreement and Order no. 8134A 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.

P&W hereby consents to the entry of this modification to the Trading Agreement and

Order without further notice.

United Technologies Corporation

Signatur~n\~

Name: CU.PtJd~ (Vt J<uS.e\\

Title: \) a.e.c-~g, \ -\-)c: S

Date: r- &J-cJl

Entered as a modification of an Order ofthe Commissioner of Environmental

Protection numbered 8134A

on ----:~ a a.. , 2007.

fr:./ Gina

A,~ M~ Commissioner