SIP DESCRIPTION - Navv Submarine Base - Tradine Agreement and Order No. 81 12A

Modification J

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

SIP SUMMARY TABLE

Trading Agreement and Order No. 8112A

United States Naval Submarine Base Route 12, and Crystal Groton, cr 06349

Lake Road

Identifier IClient 800 Town#70 Premise # 28 ISequence # 1

Contact Mr. Michael Brown, Tel: (860) 694-5159 Fax (860) 694-4899

Environmental Mana2er

PoDutant and Regulatory Standard: NOx Section 22a·174-22 of the Regulations of

Connecticut State A2encies.

Nonattainment Area Classification Serious

Annual DERCs needed Estimated 1 ozone and I non-ozone.

Comoliance Time Period Until Aori130, 2007.

Max. Emission Rate: Full load emission rate (FLER) for Use. (See Table 1

below):

Table 1

SUBASENLON

Emission Test Results Allowable Emission Limits and FLERs

Unit; DE? Fuel Emission Test FLER Allowable Emission Next

Permit # Rate Emission Test Date Emission

Reo. # #20iIlNat.Gas Limits Test Due

Gen. #519 NO.2 diesel 19.88 24.63 8 11/19/02 11119/07

N/A oil l(m!HP-hr .mlHP-hr

Boiler 1 No.2 Oil 0.145/0.086 N/A 0.20 6/20102 6/20/07

R070-0196 Nat.Gas LbsIMMBru

Boiler 2 No.2 Oil 0.158/0.096 N/A 0.20 6119-20/02 6/19-

R070-0197 Nat.Gas LbsIMMBru 20/07

Boiler 3 No.2 Oil 0.134/0.090 N/A 0.20 12/11101 12/11/06

R070-0198 Nat.Gas LbsIMMBru

II. SPECIAL REOUIREMENTS

a. This Trading Agreement and Order supercedes Trading Agreement and Order 8112 issued on

April 30, 1999, and Trading Agreement and Order 8112, Addendum I issued on July 30,2001.

b. Calculations of credits used shall be as specified in Trading Agreement and Order No. 8112A.

c. Depending on the training schedule, SUBASENLON operates diesel generator 519 in

"standard operation" or as a "peaker unit". Pursuant to the Department ofEnvironmental

Protection (<<Department") policy on "Credit Tradingfor Sources with Irregular NOx

Emissions" policy, with a revised date ofFebruary 27, 2001.

d. The Tavy no longer creates new DERCs using boilers I, 2 and 3 at the facility.

• STATE OF CONNECTICUT

. DEPARTMENT OF ENVIRONMENTAL PROTECTION

,.~. '.....,,,

STATE OF CONNECTICUT

AND

UNITED STATES NAVAL SUBMARINE BASE

TRADING AGREEMENT AND

ORDER NO. 8112A

MODIFICATION NO. 1

1./

TRADING AGREEMENT AND ORDER MODIFICATION

In the maner of aTrading Agreement and Order between the Commissioner of Environmental

Protection ("Commissioner") and United States Naval Submarine Base, New London

("SUBASENLON").

WHEREAS, the Commissioner and SUBASENLON, having agreed to the terms and

conditions set forth in Trading Agreement and Order No. 8I12A signed by the Commissioner on

May 7, 2003, do now, by mutual agreement, modify said Trading Agreement and Order as

follows:

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o

1.

2.

3.

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

Depending on the training schedule, SUBASENLON operates diesel generator

519 in "standard operation" or as a "peaking unit",

Delete the date April 30, 2007, and substitute therefor May I, 2007, in paragraphs

A.7. and C.z.

Delete paragraph C.3 ... and substitute the following therefor:

Until May I, 2007, before the first day of each month SUBASENLON shall have

in its possession sufficient approved DERCs for the current day for the peaking

unit based on the following calculations;

Before the first day of each month, SUBASENLON shall estimate DERCs

required for such month for the peaking unit as follows:

(i) At all times:

Estimated DERCs (in tons) use = [estimated gal/month x heat input in MMBtu/gal

x (FLER grarnsIHP-hr - (Allowable limit in

gramsIHP-hr x 0.95(1»)) x EFF.(2) x HPhr/0.oo2544 MMBtu x Ibs/453.6 grams) 2000

pounds/ton.

( I'finley un I{o:cyded P;/PCf I

7Y Elm SIU"",l • ll:mr""uJ. CT 1161116 - 5127

An £'1",,/ O"I"'<'/u",'r Em,,,,,)",,r
United States Naval Submarine Base 2 Trading Agreement and Order No.

8112A Modification No. I

Where:

(1) Equivalent to a 5% design margin

(2) Manufacturer's engine efficiency;:;; 37% for diesel generator 519.

No later than the twentieth day of each month, SUBASENLON shall calculate and

permanently retire DERCs used in the preceding calendar month, as follows:

Actual DERCs (in tons) = [actual gal/month x heat input in MMBtuigal x (FLER

gramsIHP-hr - (Allowable limit in gramsIHP-hr x

0.95)) x EFF. x HP- hr/0.OO2544 MMBtu x Ibs/453.6

grams1.;. 2000 pounds/ton.

Where:

• NOx allowable rate = allowable limit rate in IbslMMBtu shown in Table I of

this Trading Agreement and Order.

• FLER = full load emission rate in gm/ Hp-hr as shown in Table I of this

Trading Agreement and Order.

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

ii) During the ozone season onlY:

No later than December 31" each year, SUBASENLON shall acquire and

pennanently retire seven ozone season DERCs for every actual ton of excess 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",

until such time that the EPA revokes the 1-hour standard. Upon such revocation,

SUBASENLON shall calculate and pennanently retire seven ozone season

DERCs for every actual ton of excess NOx emitted from the peaking unit during

such ozone season based upon the actual emissions for each day that Connecticut

eight hour ozone levels were forecasted to be "unhealthy for sensitive groups",

"unhealthy", or "very unhealthy". The total actual tons of excess NOx emitted

from the peaking unit during forecasted ozone exceedance days shall be

multiplied by seven and then rounded to the next greater whole ton, to detennine

the number of DERCs to be pennanently retired. This requirement is in addition

to the SUBASENLON's requirement to estimate excess emissions and subsequent

pennanent retirement of a sufficienl number of approved DERCs in accordance

with paragraph C.3.a.(i) of this Trading Agreement and Order.

4. Delete paragraph C.3.b. and substitute the following therefore:

Reserved.

. . !

~.
United States Naval Submarine Base 3 Trading Agreement and Order No.

8112A Modification No. I

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

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

100% if DERCs are not in SUBASENLON'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.

SUBASENLON shall permanently retire the quantity ofDERCs equivalent to the

excess emissions plus a 100% premium within sixty (60) days of

SUBASENLON's discovery of the DERC shortfall. SUBASENLON shall certify

and report any such DERC retirement to the Commissioner in accordance with

paragraph C.29. of this Trading Agreement and Order.

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6.

7.

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

FLER Exceedance. Noncompliance with an established FLER shall subject

SUBASENLON 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 IbslMMBtu, multiplied by the

total heat input during the period of noncompliance divided by 2000 Ibslton. If

the period of noncompliance is not known, the time period from the completion of

the last/previous Commissioner wi01essed emission test through the date the

Fl.ER 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. SUBASENLON shall permanently retire

DERCs calculated in accordance with the above plus a 100% premium within

sixty (60) days of SUBASENLON's discovery of the FLER exceedance.

SUBASENLON shall report any FLER exceedance to the Commissioner in

accordance with paragraph C.29. of this Trading Agreement and Order.

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

Annual DERC Report. No later than March 1 of every year after issuance of this

Trading Agreement and Order, SUBASENLON shall submit in writing to the

Commissioner, a record of each sale or other transfer of DERCs for the previous

calendar year. SUBASENLON shall also include actual NOx emissions from the

peaking unit and the amount of all DERCs used (including serial numbers (if

assigned) and DERCs purchased from other facilities). These reports shall be on

forms prescribed by the Commissioner and shall be in monthly increments, and by
United States Naval Submarine Base 4 Trading Agreement and Order No.

8112A Modification No. I

ozone and non ozone seasons.

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

Extension. No later than May I, 2007 with respect to diesel generator 519,

SUBASENLON shall comply with the requirements of Section 22a-174-22(d)(I)

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.

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

Definitions. As used in this Trading Agreement and Order, "Approved DERCs"

are those for which the Commissioner has provided written authorization for use

in compliance with Section 22a-174-22 of the Regulations; "Commissioner"

means the Commissioner or a representative of the Commissioner; "Non-ozone

season" means the period from October 1 through April 30 in any given calendar

year, "Ozone season" means the period from May 1 through September 30 in any

given calendar year.

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

Dates. The date of «issuance" of this Trading Agreement and Order is the date

the Trading Agreement and Order is deposited in the U.S. mail or personally

delivered, whichever is earlier. The date of submission to the Commissioner of

any document required by this Trading Agreement and Order shall be the date

such document is received by the Commissioner. The date of any notice by the

Commissioner under this Trading Agreement and Order, including but not

limited to notice of approval or disapproval of any document or other action, shall

be the date such notice is deposited in the U.S. mail or is personally delivered,

whichever is earlier. Except as otherwise specified in this Trading Agreement

and Order, the word "day" as used in this Trading Agreement and Order means

calendar day. Any document or action which is required by this Trading

Agreement and Order to be submitted or performed by a date which falls on a

Saturday, Sunday or a Connecticut or federal holiday shall be submitted or

performed by the next day which is not a Saturday, Sunday or Connecticut or

federal holiday.

11. Delete the word "individual" and substitute therefore the word "Unit" in

paragraph C.29.

12. Delete the name "Mr. Roland L. Severance Jr., P.E." in paragraph C.30.
( United States Naval Submarine Base 5 Trading Agreement and Order No.

8112A Modification No.1

All other terms and conditions of Trading Agreement and Order no. 8112A 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.

SUBASENLON hereby consents to the entry of this modification to the Trading Agreement and

Order without further notice.

Signature:

Type Name:

Type Title:

Date:

Naka! Submarine Base

S. P. SULLIV~N

COMM~NDING OFFICER

Issued as a modification of an Order of the Commissioner of Environmental Protection.

Q;t:&L

// Gina McCarthy

/' Commissioner

/ /

,I / / .

// MAILED CERTIFIED MAIL,

RETURN RECEIPT REQUESTED

Certified Document No. 7002 2030 0007 9636 0984

Date