Ir';,;-------------------------------------------- ------ 

# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION 

# l

In the matter of The State ofConnecticut and United Technologies Corporation ) ) ) ) ) Trading Agreement and OrderNo. 8134A Modification 1

Whereas, the Commissioner ofEnvironmental 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 saidTrading Agreement and Order as follows:
1. Delete paragraph A.l. and substitute the following therefor: P&W is a company which owns and operatesjetengine 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 ofburning 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") andjet fuel burning production GG-8 gas turbine engines ("facility 2 engines"). At facility 2 similarproduction 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 ofthe Regulations ofConnecticut State Agencies ("Regulations"), pertaining to the control ofNOx 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_verUnited 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 75ppm Engines Iblbr 

## * Rates are in LbslMMBtu unless otherwise noted 

## ** For GG8 Engine- % ofMRC 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) ofthe Regulations requires that the facility I boilers, facility 2 boilers, and the facility 2 engines emit NOx atrates no greaterthan the RACT rates shown in Table I above. P&Wproposes 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 oruntil P&W achieves compliance with the emission standards in Section 22a-174-22(e) ofthe Regulations, whicheveroccurs earlier, P&W shall acquire and retire approved DERCs and shall document and record the amounts ofall fuel and DERCs used by the facility 1 boilers, and facility 2 boilers and engines, each month, andprovide such records in accordance with the following and Section 22a-174-22 ofthe 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 priorto the first day ofeach month or applicable season. However, nothing in this Trading Agreement and Order shall affectthe Commissioner's authority to institute any proceeding ortake any other action to require additional upward adjustment, based on the gravity ofany alleged noncompliance or violation oflaw. P&W shall permanently retire the quantity of DERCs equivalentto the excess emissions plus a 100% premium within sixty (60) days ofP&W's discovery ofthe DERC shortfall. P&W shall certify and report any such DERC retirement to the Commissioner in accordance with paragraph C.24. ofthis Trading Agreement and Order.
10. Delete paragraph C.l.b. and substitute the following therefor: No laterthan the twentieth day ofeach month, P&W shall calculate and permanently retire DERCs used in the preceding calendarmonth for each boiler and engine, as follows: BoilerDERCs (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 ofOperation x (FLER in lbsihr)

- (0.95 x NOx allowable rate in IbsIMMBtu)) x (fuel use in MMBtu)] .;- 2000 pounds/ton Where:UnitedTechnologies Corporation 4 Trading Agreement and Order No. 8134A Modification 1

• NOx allowable rate

## =RACT rate shown in Tables 1 ofthis Trading Agreement and Order.
• FLER = full load emission rate as shown inTable 1 ofthis 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: Priorto 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-hourbasis.
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 afterthe consentofthe Commissionerby written modification ofthis Trading Agreement and Order.
14. Delete paragraph C.5. and substitute the following therefor: FLERExceedance. Noncompliance with an establishedFLER shall subject P&W to make restitutionby 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 Ibs/MMBtu, multipliedby the total heat inputduring the period of noncompliance divided by 2000 lbs/ton. Ifthe period ofnoncompliance is notknown, the time periodfrom the completion ofthe last/previous Commissioner witnessed emission testthrough the date the FLER compliance is achieved as approved by the Commissioner shall be used. However, nothing in this Trading Agreement and Order shall affectthe Commissioner's authority to institute any proceeding ortake any other action to require additional upward adjustment, based on the gravity ofany alleged noncompliance or violation oflaw. P&W shall permanentlyretire DERCs calculated in accordance with the above plus a 100% premium within sixty (60) days ofP&W's discovery ofthe FLER exceedance. P&W shall report any FLER exceedanceto the Commissioner in accordance with paragraph C.24. ofthis Trading Agreement and Order.,-----------------------------------------

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 Section22a-174-22(k) ofthe Regulations, P&W shall conduct NOx emission tests ofthe facility 1 boilers, facility 2 boilers, and the facility 2 engines at least once every five years. Such NOx emissiontest shall be conducted priorto five years from the date ofthe last test for each such unit. 16. Deleteparagraph C.7. and substitute the following therefor: From the date ofthe mostrecent NOx emission tests identified in paragraph A.3. and priorto May 1,2009, P&W shall comply with paragraph 6 ofthis Trading Agreement and OrderModification. P&W shall demonstrate compliance with these limitations by monitoring and documenting hourly steam production. However, ifat any time after the date ofthe mostrecent 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 maximumrated capacity as stated above, P&W shall conduct NOx emissions testing ofthe facility 1 boilerno. 6, facility 1 boiler no. 8, facility 1 boiler no. 9, facility 2 boilerno. 2, orfacility 2 boiler no. 4 on orbefore sixty (60) days afterexceedance ofthe above limits in accordance with the following:
a. P&W shall submit to the Commissionerfor his review and written approval an Intent-To-Test ("ITT") protocol not less than thirty (30) days pnorto the emissions testing required pursuantto this Trading Agreement and Order. The ITT protocol shall include at least: The Department ofEnvironmental Protection's Bureau ofAir ManagementTestForm No. I, "Intentto Test"; System operating parameters indicative ofproper operation, including, but not limited to, fuel firing rate, NOx emissions rate, temperature andpressure, and steamproduction rate. The ITT protocol shall rrovide that Respondent shall perform testing as specified in Sections 22a-174-5 and 22a-174-22 ofthe Regulations, includmg 0l?erating the facility 1 boilerno. 6, facility I boilerno. 8, facility 1 boilerno. 9, facility 2 boilerno. 2, orfacility 2 boilerno. 4 at not less than ninety percent (90%) ofits maximum capacity limit orhighest 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 ofsuch testmg, Respondent shall adhere to methods specified in Sections 22a-174-5 and 22a-174-22 ofthe Regulations and as approved by the United States EPA and the Commissioner.

-----------------------UnitedTechnologies Corporation 6 Trading Agreement and Order No. 8134A Modification 1

18. Deleteparagraph C.13. and substitute the following therefor: 17. Delete paragraph C.9. and substitute the following therefor: Vintage Restriction. For the purposes ofcompliance with Section 22a-174-22 ofthe Regulations, DERCs/allowances shall only remain valid for five (5) calendar years from the year ofthe generation/allocation ofsuch DERCs/allowances. DERCs/allowances olderthan five (5) calendar years from their creation/allocation are not valid for use for compliance with Section 22a-174-22 ofthe Regulations. Respondent shall schedule all emissions testing so as to allow the Commissionerto be present during such testing and to independently verify facility operatIons, air pollution control equipment parameters, and testing procedures. Within 30 days aftercompleting 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 ofa notice from the CommIssionerindicating any deficiencies in such report, P&W shall submit arevisedreport. 

### e. d.

Certification ofdocuments. Any document, induding butnot limitedto any notice, which is required to be submittedto the Commissionerunder this Trading Agreement and Order shall be signedby 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) ofthe Regulations ofConnecticut State Agencies, and by the individual(s) responsible for actually preparing such document, and each such individual shall certify in writing as follows: "Ihave personally examined and amfamiliar with the information submitted in this document and all attachments thereto, and I certify thatbased on reasonable investigation, induding my inquiry ofthose individuals responsible for obtaining the information, the submitted information is true, accurate and complete to the best ofmy knowledge and belief. I understand that any false statementmade in the submitted information may be punishable as acriminal offense under section 22a-175 ofthe Connecticut General Statutes, under section 53a-157b ofthe Connecticut General Statutes, and in accordance with any applicable statute." 19. Delete paragraph C.24. and substitute the following therefor: Notification ofnoncompliance. In the event that P&Wbecomes aware that it did not or may not comply, or did not ormay not comply on time, with any requirement ofthis Trading Agreement and Order or ofany document required hereunder, P&W shall20. Delete the name "Ms. Wendy Jacobs" in paragraph C.25

22. Include anew paragraph C.27. as follows: 21. Include a new paragraph C.26. as follows: Trading Agreement and OrderNo. 8134A Modification 1 7

immediately notifyby telephone the section identified in the nextparagraph and shall take all reasonable steps to ensure that any noncompliance or delay is avoided or, if unavoidable, is minimizedto the greatest extentpossible. Withinten (10) days ofthe initial notice, P&W 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 written approval ofthe 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. Notificationby P&W shall notexcuse noncompliance ordelay, and the Commissioner's approval ofany compliance dates proposed shall notexcuse noncompliance ordelay unless specifically so statedby the Commissionerin writing.

Extension. No later than May 1,2009, , P&W shall complywith the requirements of Sections 22a-174-22(d)(1) and 22a-174-22(d)(2)(A) ofthe Regulations. There is no assurance that afterfull program review ofthis and otherTrading Agreements and Orders that the Commissioner will grant awritten extension ofthis Trading Agreement and Order. Future Compliance Report. On orbefore September 1,2008, P&W shall submit a report in writing to the Commissioner, as directed in paragraph C.25. ofthis Trading Agreement and Order, indicating how the P&W shall comply with Section 22a-174-22 ofthe Regulations on and after May 1, 2009. UnitedTechnologies Corporation 

## , 

# .

# , 

# .

United Technologies Corporation 8 Trading Agreement and Order No. 8134A Modification 1
All otherterms and conditions ofTrading Agreement and Order no. 8134A issued by the Commissioner acting underChapter446c, Sections 22a-6, 22a-171, 22a-174, 22a-176, and 22a177 ofthe ConnecticutGeneral Statutes shall remain in effect. P&Whereby consents to the entry ofthis modification to theTrading Agreement and Orderwithout 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 amodification ofan Orderofthe CommissionerofEnvironmental Protection numbered 8134A

on

## ----:~ 

# aa.. , 2007.

# A,~ fr:./Gina

### M~ Commissioner