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# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

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

(Printed on Recycled Paper) 79 Elm Street • Hartford, CT 06106 5127 An Equal Opportunity Employer U.S. Environmental Protection Agency ("EPA") Method 7E emission tests performed on the dates shown in Table 1 resulted in NOx emissions rates as follows: TRADING AGREEMENT**A~** ORDER NO, 8109 MODIFICATION No,2

Table 1 IISC

- NOx EMISSION TEST RATES AND LIMITS (lbsIMMBtn) 'Boilers in Building# I Boiler Fuel Heat input Test rate Testrate Test rate FLERs NOx Dale MMBtulbr 5195 5/99 2104 Limit Rate Next Test (5/00) Due Boiler #] #6 oil 61 0,38 0,25 0.294 0,33 0.25 2126/09

(Riley) Nat. Gas 0,26 0,12 0,175 N/A 0.20 2124/09 Boiler#2 #6 oil 61 0,36 0,24 0,263 0,29 0.25 2/25/09

(Riley) Nat. Gas 0,27 0,08 0,160 N/A 0,20 2/24/09 Boiler#3 #6 oil 61 0,40 0,25 0,294 0,33 0,25 2/26/09

(Riley) Nat. Gas N/A 0.13 0,149 N/A 0,20 2/24/09 Boiler#4 #6 oil 73 0,44 (0,374) N/A N/A 0,25 Shut down

(CE) Boilers in Building # 3 Boiler Fuel Heat input Testrate Testrate Test rate FLER NOx Date MMBlulbr 5/95 1/99 12103 Limit Rate Next Test (5/00) Due Boiler #1 #4011 0.29 Ceased N/A 0,29 0.25 N/A (CB) #2 Oil 20,9 N/A 0,171 0,192 N/A 0,20 1/9109 Nat. Gas 0,08 (0,111) 0,114 N/A 0,20 12118/08 Boiler#2 #4011 0,27 Ceased N/A 0,27 0,25 N/A (CB) #2 Oil 20,9 N/A 0,189 0,174 N/A 0,20 1/9/09 Nat. Gas 

### om (0,102) 0,099 N/A 0,20 12/18/08 WHEREAS, the Commissionerand HSC, having agreed to the terms and conditions set forth in Trading Agreement and OrderNo, 8109 signed by the Commissioneron April 29, 2003, and Order 8109 Modification 1 issued March 15,2005 do now, by mutual agreement, modify saidTrading Agreement and Orderas follows: In the matterofaTrading Agreement and Orderbetween the CommissionerofEnvironmental Protection ("Commissioner") and Hamilton SundstrandCorporation ("HSC"). STATE OF CONNECTICUT ) )**A~** ) ) HAMILTON**SUNDSTRA~** CORPORATION )Hamilton Sundstrand Corporation 2 Trading Agreement and Order No. 8109 Modification No.2

2. Delete paragraph A.7. and substitute the following therefor:
a. DEP witnessed emissions testing conducted April 1999 and May 2000, as indicated in Table I of this Trading Agreement and Order, showed that the NOx emissions rates from the boilers were reduced below the allowable NOx emission limits set forth in Section 22a-174-22 (e) ofthe Regulations. b. DEP witnessed emissions testing conducted February 2004, as indicated in Table I ofthis Trading Agreement and Order, showed that the NOx emissions rates from the boilers exceeded the allowable NOx emission limits setforth in Section 22a-174-22 (e) ofthe Regulations.
c. On June 30, 2004 HSC retired 22 DERCs to offset excess emissions from the boilers during the time period ofApril 1999 through February 2004. Included in the amount retired is an additional 100% (11 DERCs). 3. Change the term boiler4 in paragraph A.8. to: the boilers. 4. Delete paragraph A.9. and substitute the following therefor: HSC proposes to use the full load emission rates ("FLERs") in Table 1, when burning No.6 fuel oil, for the purposes ofca!culatin,g DERCs required for the boilers. 5. Attachment 2 ofTrading Agreement and Order 8109 is deleted in its entirety and the appended Attachment 2 is substituted in lieu therefor. 6. Delete paragraph A.12. and substitute the following therefor: As documented in Attachment 2, incorporated herein by reference in this Trading Agreement and Order, and shown in Table 3, since the installation oflow NOx burners in the boilers, HSC has generated 16.5 tons ofNOx DERCs (7.6 ozone and 8.9 non-ozone). Twenty percent ofthese DERCs (1.5 tons ozone and 1.8 non-ozone have been permanently retired to benefit the environment. The total DERCs available for use after the environmental discount and rounding down to the nearest whole ton for annual serial number assignment is 8 tons (3 ozone and 5 non-ozone season). 7. Delete paragraph A.l3. and substitute the following therefor. Reserved

### Hamilton SundstrandCorporation 3 

### Trading Agreement and OrderNo. 8109 Modification No.2 8. DeleteTable 3 and substitute the following therefor:

Table 3 Approved DERCs Generated from 1999 through 2003 (After rounding down to the nearest whole ton) Yearof Ozone season Tons Non-ozone season Tons Expiration**~eneration** Date 1999 CT99/8109(DC)NOxoz(1) 1 CT99/8109(DC)NOxnoz(l) 1 12/31/04 2000 CTOO/8109(DC)NOxoz(1) 1 CTOO/8109(DC)NOxnoz(I-2) 2 12/31105 2002 CT02/8109(DC)NOxoz(1) 1 CT02/8109(DC)NOxnoz(l) I 12/31/07 2003 CT03/8109(DC)NOxnoz(1) 1 12131108


### 9. Delete paragraph A.14. and substitute the following therfor: HSC shall cease operation ofBoiler4 in building 1 upon issuance ofthis Trading Agreement and OrderModification. 10. Change the amountofDERCs specified in paragraph B.1. from 17 tons ( 8 tons ozone, 9 tons nonozone) to 8 tons ( 3 tons ozone,S tons non-ozone).
11. Delete paragraph B.2. and substitute the following therefor: The Commissioner, in accordance with the provisions ofthis Trading Agreement and Order, pursuant to Section 22a-174-22G) ofthe Regulations, hereby allows HSC to comply with Section 22a-174-22(d) ofthe Regulations through use ofDERC trading to achieve the nitrogen oxide emission reduction requiredby Subdivision 22a-174-22(d)(1) ofthe Regulations. 12. Change the date specifiedin paragraphs A.8., C.l., C.2., and C.13. from April 30, 2007 to May 1, 2009. 13. Delete paragraph C.2.c. and substitutethe following therefor: HSC shall comply during the operation ofthe boilers with FLERs shown in Table 1 in accordance with this Trading Agreement and Order. 14. Delete paragraphs C.3., C.4. and C.5., and substitute the following for each therefor: Reserved. 15. Delete paragraph C.6. and substitute the following therefor.Hamilton Sundstrand Corporation 4 Trading Agreement and OrderNo. 8109 Modification No.2
DERC Use. Until May 1,2009, before the first day ofeach month HSC shall have in its possession sufficient approved DERCs for such month for the boilers in building 1 based on the following calculation:
a. Before the first day ofeach month, HSC shall estimate DERCs required for such calendarmonth for the boilers in building 1 when burning No.6 fuel oil as follows: Estimated DERCs (tons) use = {(Estimatedfuel use in MMBtu) x ((FLER)

- (0.95 x NOx allowable emission limit)) }+2000 lbs/ton. Where:

• Allowable limit= allowable limit rate in IbslMMBtu shown in Table 1 ofthis Trading Agreement and Order.

• Full load emission rate (FLER) as shown in Table 1 ofthis Trading Agreement and Order.

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

• Fuel heating value = 152,000 Btu/gal for No.6 fuel oil. b. No laterthan the twentieth day ofeach month, calculate and permanently retire actual DERCs used in the preceding calendarmonth for the boilers in building 1 when burning#6 fuel oil using the FLER as follows: Actual DERCs (tons) used = {(actual fuel use in MMBtu) x ((FLER)

- (0.95 x NOx allowable emission limit)) }+2000 lbs/ton 16. Delete paragraphs C.7. and e.8. and substitute the following therefor: Reserved. 17. Delete paragraph C.9. and substitute the following therefore: Upon issuance ofthis Trading Agreement and Order, ifHSC has reason to believe it may be exceeding the FLERs for the boilers, HSC shall conduct NOx emissions testing ofthe corresponding boiler on orbefore sixty (60) days afterthe exceedance ofthe above limits in accordance with the following: i. HSC shall submit, for the Commissioner's review and written approval, an Intent-ToTest ("ITT") protocol not less than thirty (30) days priorto the emissions testing required pursuant to this paragraph and paragraph C.18 ofthis Trading Agreement and Order. The ITT protocol shall include at least: ii The Department's Bureau ofAirManagementTestForm No.1, "Intentto Test"..'

Hamilton SundstrandCorporation 

### 5 Trading Agreement and OrderNo. 8109 Modification No.2 iii. System operating parameters indicative ofthe highest operating rate since the last previous stacktest orthe mostrecentDepartment witnessed emission test which everis more recent, including, butnot limitedto: steamoutputrate, temperature and pressure, fuel firing rate, and NOx emissions rate. iv. The ITT protocol shall provide that HSC shall perform testing as specified in Sections 22a-174-5 and 22a-174-22 ofthe Regulations. v. HSC shall perform all testing required by this Trading Agreement and Orderin accordance with the approved ITT protocol.
VI. In conducting and performing the testing required by this Trading Agreement and Order, and analyzing the results ofsuch testing, HSC shall adhere to methods specified in Sections 22a-174-5 and 22a-174-22 ofthe Regulations and as approved by the EPA and the Commissioner. Vll. HSC shall schedule all emissions testing so as to allow the Commissionerto be present during such testing and to independently verify facility operations, airpollution control equipment parameters, and testing procedures. viii. Within 30 days aftercompleting any emissions testing required by this Trading Agreement and Order, HSC shall submitto the Commissionera written report providing the results ofsuch testing; within 15 days ofanotice from the Commissioner indicating any deficiencies in such report, HSC shall submit arevised report. 18. Deleteparagraph C.12. and substitute the following therefor: Annual Emission Statement. No laterthan March 1, ofevery year afterissuance ofthis Trading Agreement and Order, HSC shall include with the Annual Emission Statement provided to the Commissioner, arecord ofeach sale orothertransfer, ofDERCs forthe previous calendaryear. HSC shall also include actual NOx emissions from each boilerusing DERCs, and the amount ofall DERCs used including serial number (ifassigned), and approvedDERCs purchased from otherfacilities. These reports shall be on a form prescribed by the Commissioner and shall be in monthly increments, and by ozone and non-ozone seasons. 19. Delete paragraph C.14. and substitute the following therefor: DERC Shortfall. At a minimum, DERCs required shall be adjusted upwards by 100% ifDERCs are not in HSC'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 orviolation oflaw. HSC shall permanently retire the quantity of DERCs equivalent to the excess emissions plus a 100% premium within sixty (60) days ofHSC's discovery ofthe DERC shortfall. HSC shall certify and report any such DERC retirement to the Commissionerin accordance with paragraph C.36 ofthis Trading Agreement and Order. 20. Delete paragraph C.16. and substitute the following therefor:Hamilton Sundstrand Corporation 

### 6 Trading Agreement and OrderNo. 8109 Modification No.2 FLERExceedance. Noncompliance with an establishedFLER shall subject HSC to make restitution by matching the quantity ofemissions ("true up") causedby the exceedance plus a 100% premium. The true up in tons ofDERCs shall be equal to the FLERexceedance in IbslMMBtu, multiplied by the total heat inputduring the period ofnoncompliance divided by 2000 Ibs/ton. Ifthe period of noncompliance is not known, the time periodfrom the completion ofthe 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 ortake any other action to require additional upward adjustment, based on the gravity ofany alleged noncompliance orviolation oflaw. HSC shall permanently retire DERCs calculatedin accordance with the above, plus a 100% premium, within sixty (60) days ofHSC's discovery ofthe FLER exceedance. HSC shall report anyFLER exceedance to the Commissionerin accordance with paragraph C.36 ofthis Trading Agreement and Order. 21. Delete paragraph C.19. and substitute the following therefor: Extension. No laterthan May I, 2009, with respectto the boilers, HSC shall comply with the requirements ofSection 22a-174-22(d)(I) ofthe Regulations. There is no assurance that afterfull programreview ofthis and otherTrading Agreements and Orders that the Commissionerwill grant a written extension ofthis Trading Agreement and Order. 22. Delete paragraph C.20. and substitute the following therefor: Future Compliance Report. On orbefore September I, 2008, HSC shall submit areport in writing to the Commissioner, as directed in paragraph C.37. ofthis Trading Agreement and Order, indicating how the facility shall comply with Section 22a-174-22 ofthe Regulations with respect to the boilers on and afterMay I, 2009.
23. Delete paragraph C.23. and substitute the following therefor: Definitions. As used in this Trading Agreement and Order,"the boilers" means boilers 1,2, and 3 in building I; "ApprovedDERCs" are those for which the Commissionerhas provided written authorization for use in compliance with Section 22a-174-22 ofthe Regulations; "Commissioner" means the Commissioneror a representative ofthe Commissioner; "Non-Ozone season" means the periodfrom October 1 through April 30 in any given calendaryear. "Ozone season" means the period from May 1 through September30 in any given calendaryear. 24. Delete paragraph C.24. and substitute the following therefor: Dates. The date of"issuance" ofthis consentorderis the date the consent orderis deposited in the U.S. mail orpersonally delivered, whicheveris earlier. The date ofsubmission to the Commissioner ofany document required by this consent order shall be the date such document is receivedby the Commissioner. The date ofanynotice by the Commissionerunderthis consent order, including but

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Hamilton Sundstrand Corporation 7 Trading Agreement and OrderNo. 8109 Modification No.2 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 personally delivered, whicheveris earlier. Except as otherwise specifiedin this consent order, the word "day" as used in this consent ordermeans calendar day. Any document or action which is required by this consent orderto be submitted orperformedby adate which falls on a Saturday, Sunday or a Connecticut orfederal holiday shall be submitted or performed by the next day which is not a Saturday, Sunday or Connecticut orfederal holiday. 25. Delete the word "individual" and substitute therefore the word "section" in paragraph C.36. 26. Delete the name "Mr. Roland L. Severance Jr., PE" in paragraph C.37.
All otherterms and conditions ofTrading Agreement and OrderNo. 8109 issued by the Commissioner acting under Chapter446c, Sections 22a-6, 22a-17I, 22a-174, 22a-176, 22a-177 and 22a-178 ofthe Connecticut General Statutes shall remain in effect.
The Hamilton Sundstrand Corporation hereby consents to the entry ofthis modification to the Trading Agreement and Order wphoutfurther notice. HAMll..TON SlmoSTRA
. PORATION I ' I

Title: Date: modification ofah Order ofthe CommissionerofEnvironmental Protection 

# /o/u/f,6, Date
TOWN OFWINDSOR LOCKS LAND RECORDS MAILED CERTIFIED MAlL, RETURN RECEIPT REQUESTED CertifiedDocumentNo.7005 3110 0001 2315 1130