SIP DESCRIPTION ConnecticutJet Power LLC Tradine A2reement and Order No. 8180A Modification 1 I. SIP

- DESCRIPTION OF DERC CREATION ANDIORUSE SIP SUMiViARY TABLE TradinoAoreement and Order No. 8180A ConnecticutJet Power Mill #30 Inland Road Versailles

### cr06383 P.O. Box 238 Identifier Client 7741 Towns # 67 Premises # 11 Sequences # § 183 24 

### ill. 43 

### 1 14 14 I Contact Ms. Cynthia Karlic Tel: (860) 343-6962 Fax (860) 343-6969 Recional Mana2er Pollutant and Regulatory Standard: NOx Section 22a-174-22 ofthe Regulations of Connecticut State A2encies. NonattainmentArea Classification 

## I Serious to Severe Annual DERCs needed Estimated 5ozone and Inon-ozone each turbine. Comoliance Time Period Until Aoril30. 2007. Max. Emission Rate: full load emission rate rFLER) for Use. (SeeTable Ibelow)



## - Table 1 NOxEmission Rates and Allowable Limits 

### Unit Fuel Maximum StackTest 

## FLER Allowable Date of 

### Next PIRNumber Capacity (ppmvd) IbslMMBtu 

### Rate Stack Stack (all PWFT4A-8 MMBtulbr IbslMMBtu 

### Test TestDue rurbines) Branford -10 #2 oil 256 184 0.80 0.29 9/6101 9/6106 R·8 Greenwich-IO #2 oil 256 193 0.80 0.29 8/22/01 8122/06 R-52 Greenwich-II #2 oil 256 144 0.80 0.29 8/23/01 8123/06 R·53 Greenwich-12 #2 oil 256 182 0.80 0.29 8123/01 8123/06 R-54 Torrington-IO #2 oil 256 194 0.80 0.29 4/20101 4120106 R-67 Torrington-I0 #2 

### oil 256 197 0.80 0.29 4119/01 4119/06 R·68SIP DESCRIPTION ConnecticutJet Power LLC Trading Agreement and Order No. 8180A Modification 1

II. SPECIAL REQUIREME TS

a. This Trading Agreement and OrderModification supersedes Trading Agreement and OrderNo. 8180A issued on April 23, 2003. b. Calculations ofcredits used shall be as specified in Trading Agreement and OrderNo. 8180A.

c. ConnecticutJet PowerLLC shall acquire and pennanently retire seven ozone season DERCs for every actual ton ofexcess NOx emitted from the peaking unit during the previous ozone season based upon the actual emissions for each day that Connecticut one hour ozone levels were forecasted to be "moderate to unhealthful", "unhealthful", or "very unhealthful".

# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

STATE OF CONNECTICUT AND CONNECTICUT JET POWER liC TRADING AGREEMENT AND ORDER NO. SISOA MODIFICATION NO. I

TRADING AGREEMENT AND ORDER MODIFICATION In the malter ofaTrading Agreement and Orderbetween the Commissioner ofEnvironmental Protection ("Commissioner") and ConnecticutJet Power

# ue ("CJP"). WHEREAS, the Commissioner and CJP, having agreed to the terms and conditions set forth in Trading Agreement and OrderNo. 8I8DA signed by the Commissioner on April 22, 2003, do now, by mutual agreement, modify said Trading Agreemem and Order as follows: 1. Delete paragraph A.6. and substitute the following therefor: Reserved. 2. Delete the date May I, 2005, and substitute thereforMay 1, 2007, in paragraphs 

### A.7. andC.L 3. Delete paragraph C.2.a. and substitute the following therefor: Until May I, 2007, before the first day ofeach month CIP shall have in its possession sufficient approved DERCs for the current day for the peaking units based on the following calculations; Before the first day ofeach month, CIP shall estimate DERCs required for such month for the peaking units as follows: (i) At all times: Estimated DERCs (in tons) use 

### = [«(FLER in IbsIMMBtu)

- (0.95 x NOx allowable tate in IbsIMMBtu)) x (estimated fuel use in MMBtu)] 2000 pounds/ton**(Prinl~d** on**R~cycl~d** Paper) 79 EIIII**Slr~~l** • HUlford, CT 06106

- 5121 bClp:lldep.sI1Ie.cl.us

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..itirv P.""ilovf!r·Connecticut let PowerLLC 2 Trading Agreement and Order No. 8180A Modification No.1 No laterthan the twentieth day ofeach month, CIP shall calculate and permanently retire DERCs used in the preceding calendar month, as follows: Actual DERCs (in tons) 

### = [«(FLER in IbsIMMBtu)

- (0.95 x NOx allowable rate in IbslMMBtu)) x (actual fuel use in MMBtu)) 2000 pounds/ton Where:

• NOx allowable rate 

### = allowable limit rate in IbsJM:MBtu shown in Table 1of this Trading Agreement and Order.

• FLER 

### = full load emission rate in IbsJM:MBtu as shown in Table 1 ofthis Trading Agreement and Order.

• Discount (0.95) 

### = 5% design margin applied to the allowable limitrate. ii) 

### During the ozone season only: No laterthan December 31st each year, CIP shall acquire andpermanently retire seven ozone season DERCs for every actual ton ofexcess NOx emitted from the peaking units during the previous ozone season based upon the actual emissions for each day that Connecticut one hour ozone levels were forecasted to be "moderate to unhealthful", "unhealthful", or "very unhealthful", until such time that the EPA revokes the I-hourstandard. Upon such revocation, CJP shall calculate and permanently retire seven ozone season DERCs for every actual ton ofexcess NOx emitted from the peaking units during such ozone season based upon the actual emissions for each day that Connecticuteight hourozone levels were forecasted to be "unhealthy for sensitive groups", "unhealthy", or "very unhealthy". Where: Actual ton ofexcess NOx emitted 

### = [«(FLER in IbsIMMBtu)

- (0.95 x NOx allowable rate in IbslMMBtu))x (actual fuel use in MMBtu)J .,. 2000 pounds/ton The total acrnal tons ofexcess NOx emitted from the peaking units during forecasted ozone exceedance days shall 

### be multiplied by seven and then rounded to the next greater whole ton, to determine the number ofDERCs to be pennanentlyretired. This requirement is in addition to the CJP's requirement to estimate excess emissions and subsequent pennanent retirement ofa sufficient numberofapproved DERCs in accordance with paragraph C.2.a.(i) ofthis Trading Agreement and Order. 4. Delete paragraph C.2.b. and substitute the following therefor:

### ConnecticutJet PowerLLC

Reserved. 3 

### Trading Agreement and Order No. 8180A Modification No. I

5. Delete paragraph C.2.c. and substitute the following therefor: 

### During the non-ozone season: Until May 1, 2007, from October 1through April 30, inclusive, each year, the peaking units shall, in addition to meeting the 24-houremission limit in Table 22-1 ofSection 22a-174-22 ofthe Regulations, 

### meet a**non~ozone** 

### season emission limit of0.15 IbJrvTh1Btu. Priorto October 1, 2004, October I, 2005 and October I, 2006, CJP shall estimate and acquire the 

### amountofDERCs orallowances required for such non-ozone season needed to comply with Section 22a-174-22(e)(3) ofthe Regulations as follows: 

### EstimatedDERCs (tons) use = 

### [Estimatedfuel use in NfMBtu from October 1 through April 30 , (allowable emission rate in IbslMMBtu

- (0.95, 0.151blMMBtu))J + 

### 2000 Ibslton 6. Delete paragraph C.2.d. and substitute the following therefor: No laterthan May 31 of2005,2006 and 2007, in addition to the DERCs retired pursuant to paragraph C.2.a. ofthis Trading Agreement and Order, CJP shall 

### calculate and permanentlyretire DERCs used in the precedingnon-ozone season as follows: Actual DERCs (tons) used 

### = [Actual fuel use in MMBtu from October I through 

### April 30 x (allowable emission rate in IbslM11Btu

- (0.95, 0.151blMMBtu))J + 

### 2000 lbslton 7. Delete paragraph C.6. and substitute the following therefor: 

### (a) Annual DERC Report. No later than March 1ofevery yearafterissuance of this TradingAgreement and Order, CJPshall submitin writing to the Commissioner, arecord.ofeach sale orothertransfer ofnERCs for the previous calendaryear. CJP shall also include actual NO, emissions from the peaking units and the amount ofall DERCs used (including serial numbers (if assigned) andDERCs purchasedfrom otherfacilities). These reports shall 

### be 

### on forms prescribedby the Commissionerand shall be

### in monthly increments, and by ozone and non ozone seasons. (b) Starting on October 1. 

### 2004: No later thanJuly 30 ofevery year afterissuance ofthis Trading Agreement and Order, CJP shall submit in writing to theConnecticut Jet Power

### LLC 4 Trading Agreement and Order No. SISOA Modification No. I Conunissionerthe non-Olone season fuel consumption and amount ofall DERCs used (including serial numbers (ifassigned) and approved DERCs purchased from otherfacilities) for the peaking units during the October through April time period in the previous calendaryear. These repons shall be on a form prescribed by the Conunissioner. 8. Delete paragraph e.7. and substitute the following therefor: Allowance Use. Pursuantto Section 22a-174-22(d)(3) ofthe Regulations, CIP may use NOx allowances, until May I, 2007, for the peaking units pursuant to Section 22a-174-22(j) ofthe Regulations [Q achieve all ora portion ofthe reductions required by Section 22a-174-22 ofthe Regulations. Any allowance used for compliance with Section 22a-174-22(e) ofthe Regulations shall be subject to all restrictions and/or requirements applicable to DERCs contained in this Trading Agreement and Order,

a. In orderfor CJP [Q use NOx allowances, CJP shall create a general account oruse an existingcompliance account or overdraft account in EPA's NOx Allowance Tracking System ("NATS"); and b. Each allowance used for compliance with Section 22a-174-22 ofthe Regulations shall be equivalent to one discrete emission reduction credit. Allowances shall be considered used for compliance with Section 22a174-22 ofthe Regulations when they are transferred from the facility's NOx general account in the NATS orthe facility's NOx compliance account in the NATS to the CT State NOx Retirement Account (Account ill CTOOOOOO0300 in the NATS). 9. Delete paragraph e.S. and substitute the following therefor: DERC Shortfall. At aminimum, DERCs required shall be adjusted upwards by

100% ifDERCs are not in CJP's possession for use priorto the first day ofeach 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 otheraction to require additional upward adjustment, based on the gravity ofany alleged noncompliance or violation oflaw. CIP shall permanently retire the quantity ofDERCs equivalentto the excess emissions plus a 100% premium within sixty (60) days ofCIP's discovery ofthe DERC shortfall. CIP shall certify and report any such DERC retirement to the Commissionerin accordance with paragraph C.30. ofthis Trading Agreement and Order. 10. Delete paragraph e.1O. and substitute the following therefor:Connecticut let Power liC 

### 5 Trading Agreement and Order No. 8180A Modification No.1 Fl.ER Exceedance. Noncompliance with an established HER shall subject 

### ClP to make restitution by matching the quantity ofemissions ("true up") caused by the exceedance plus a 100% premium. The true up in tons ofDERCs shall be equal to the HER exceedance in lbs!M:MBtu, multiplied by the total heat input during the period ofnoncompliance divided by 2000 Ibslton. 

### Ifthe period of noncompliance is not known, the time period from the completion ofthe last/previous Commissioner witnessed emission test through the date the HER 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 ortake any other action to require additional upward adjustment, based on the gravity ofany alleged noncompliance or violation oflaw. CJP shall pennanently retire DERCs calculated in accordance with the above plus a 100% premium within sixty (60) days ofCJP's discovery ofthe FLER exceedance. CJP shall report anyFLER exceedance to the Commissionerin accordance with paragraph C.30. ofthis Trading Agreement and Order. 11. Delete paragraph C.13. and substitute the following therefor: Extension. No laterthan May 1, 2007, with respect to the peaking units, CJP shalf comply with the requirements ofSections 22a-174-22(d)(I) and 22a-174- 22(d)(2)(A) ofthe Regulations. There is no assurance that after full program review ofthis and otherTrading Agreements and Orders that the Commissioner will grant awritten extension ofthis Trading Agreement and Order. 12. Delete paragraph C.14. and substitute the following therefor: Future Compliance Report. On orbefore September I, 2006, CJP shall submit a report in writing to the Commissioner, as directed in paragraph C.3l. ofthis Trading Agreement and Order, indicating how the facility shall comply with Section 22a-174-22 ofthe Regulations with respect to the peaking units on and afterMay I, 2007. 13. Delete paragraph C.17. and substitute the following therefor: Definitions. As used

## in this Trading Agreement and Order, "ApprovedDERCs" are those for which the Commissionerhas provided written authorization for use in compliance with Section 22a-174-22 ofthe Regulations; "Commissioner" means the Commissioner or arepresentative ofthe Commissioner; "Non-ozone season" means the period from Ocrober 1 through April 30 in any given calendar year; "Ozone season" means the period M':lY.l through September 30 in any given calendaryear.ConnecticutJet PowerLLC 

### 6 Trading Agreement and Order No. SISDA Modification No. I 14. Delete paragraph C.IS. and substitute the following therefor: Dates. The date of"issuance" ofthis Trading Agreement and Orderis the date the Trading Agreement and Orderis deposited in the U.S. mail orpersonally delivered, whichever is earlier. The date ofsubmission to the Commissionerofany document required by this Trading Agreement and Order shall be the date such document is received by the Commissioner. The date ofany notice by the Commissionerunder this Trading Agreement and Order, including but not limited to notice ofapproval or disapproval ofany document or other action, shall be the date such notice is deposited in the U.S. mail oris personallydelivered, 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 or action which is required by this Trading Agreement and Orderto be submittedorperformed by adate which falls on a Saturday, Sunday or a Connecticut orfederal holiday shall be submitted orperformed by the next day which is not a Sarurday, Sunday or Connecticut orfederal holiday. 15. Delete the word "individual" and substitute therefor the word "Section" in paragraph C.3D. 16. Delete the narne "Mr. Michael LaFleur" in paragraph C.31. All otherterms and conditions ofTrading Agreement and Order no. 8180A 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.

### Connecticut Jet PowerLLC 7 

### Trading Agreement and Order No. 8180A Modification No.1



### CJP hereby consents to the entry ofthis modification to the Trading Agreement and Order without further notice. ConnecticutJetPower

## u..c Signature: Type Name: Type Title: Date:



### Issued as amodification ofan Orderofthe CommissionerofEnvironmental Protection.

# ---li~#@!UD tI Gina McCarthy 

### Commissioner

MAILED CERTIFlED MAll.,

RETURN RECEIPT REQUESTED CertifiedDocument No. 7002 2030 0006 5643 0055 Date