# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

State ofConnecticut and Cascades Boxboard Group Connecticut LLC ) ) ) ) ) Trading Agreement and Order No. 8297

WHEREAS, the Commissioner ofEnvironmental Protection ("Commissioner") and Cascades Boxboard Group ConnecticutLLC ("Respondent") agree thatthe Commissioner may issue a permit or order to allow emissions trading in accordance with Section 22a-174-22(j) ofthe Regulations ofConnecticut State Agencies ("Regulations") as a method ofcompliance with Section 22a-174-22 ofthe Regulations: A. At the request and with the agreement ofRespondent, the Commissioner finds the following: 1. This Trading Agreement and Order supersedes Trading Agreement and Order 8269 and all subsequent modifications thereto. 2. Respondent is a corporation that owns and operates a manufacturing facility at 130 Inland Road, Versailles, Connecticut ("facility"). 3. At the facility, Respondent operates the emission unit described in Table 1 below, which is subject to Section 22a-174-22 ofthe Regulations ofConnecticut State Agencies ("Regulations") pertaining to the control ofNitrogen Oxide (NOx) emissions. 4. For the purposes ofthis Trading Agreement and Order, the following definitions shall apply:

a. Allowable Emission Limit (AEL): the applicable NOx emission limit set forth in Section 22a-174-22(e) or Section 22a-174-22(f) ofthe Regulations corresponding to the emission unit described in Table 1 ofthis Trading Agreement and Order b. Allowance: CAIR NOx Ozone Season allowance originally allocated to a CAIRNOx Ozone Season unit, as defined in Section 22a-174-22c ofthe Regulations, located in the State ofConnecticut or a NOx allowance designated specifically for compliance during Ozone Season control periods and allocated to a CAIRNOx Ozone Season unit located in the State of Connecticut after the date ofissuance ofthis Trading Agreement and Order.

c. CAIR NOx Ozone Season unit: shall be as defined in Section 22a-174-22c of the Regulations d. CEMS: Continuous Emissions Monitoring System (Printed on Recycled Paper) 79 Elm Street • Hanford. CT 06106-5127 www.cI.gov/dcp An Equal Opporrtmity EmployerCascades Boxboard Group ConnecticutLLC 

### 2 Trading Agreement and Order 8297

e. Discrete Emission Reduction Credit (DERC): aunit that was generated and approved by the Commissioner in accordance with a Trading Agreement and Orderissued by the Commissioner or generated and approved by the Commissionerin accordance with aprotocol submitted and approved pursuant to Section 22a-174-38 ofthe Regulations. Such unit is equivalent to 1 ton of NOx emissions and may be used for emissions trading in accordance with Section 22a-174-22G) ofthe Regulations, subject to the provisions ofPart B of this Trading Agreement and Order. f. Non-Attainment Area: means the geographic areawhich has been designated as nonattainment pursuant to 40 CFR 81 in accordance with the provisions of 42 USC 7407 (Section 107 ofthe Act). Pursuantto 40 CFR 81.307, the designated ozone non-attainment areas in the State ofConnecticut are: the Greater Connecticut, CT area and the New York-NorthernNew Jersey-Long Island, NY-NJ-CT area. g. CAIRNATS: "CAIRNOxOzone Season Allowance Tracking System" as defined in 40 CFR 96.302. h. Ozone Season: May 1 through September 30 ofeach calendaryear or such period as defined by the U.S. Environmental ProtectionAgency, subsequentto the issuance ofthis Trading Agreement and Order.

I. Non-Ozone Season: the period ofconsecutive calendar months between two successive Ozone Seasons Table 1 CAIRNOx Ozone Season Unit UNIT- Fuel Heat Input (MMBtu) Allowable Emission Limit reg. or permit no. (AEL)-Lbs/MMBtu PH Boiler No.6 Oil 275 .25 P-170-0003 Nat. Gas 288 .20 5. The Respondent agrees that the actual NOx emissions rate from the emission unit described in Table I, at times, exceeds the corresponding AEL. 6. Pursuant to Section 22a-174-22(j) ofthe Regulations, Respondent proposes to comply with Section 22a-174-22(e) ofthe Regulations, when operating the emission unit described in Table I by means ofemissions trading in accordance with the provisions of this Trading Agreement and Order. 7. The Respondent proposes to use the actual 24-hour average emissions rate measured by CEMS for the purposes ofcalculating Actual DERCs/ Allowances Required for the emission unit described in Table I. The Commissioner, in accordance with Section 22a-174-22(j) ofthe Regulations hereby allowsCascades Boxboard Group Connecticut LLC 

### 3 Trading Agreement and Order 8297 Respondent to comply with Section 22a-174-22 ofthe Regulations at the facility through the use ofemissions trading, subjectto the provisions ofthis Trading Agreement and Order. B. Withthe agreement ofRespondent, the Commissioner, acting under Sections 22a-6, 22a-174, 22a176, and 22a-l77 ofthe Connecticut General Statutes, hereby orders Respondent as follows: 1. Expiration ofthis Trading Agreement and Order: The Respondent may only use emissions trading, subject to the provisions ofthis Trading Agreement and Order, until the date of expiration ofthis Trading Agreement and Order. The date ofexpiration ofthis Trading Agreement and Order shall be the earlier of:

a. January 1,2013; b. The date upon which the Respondent demonstrates to the Commissioner's satisfaction that actual NOx emissions from the emission unit, at all times, does not exceedthe corresponding AEL(s);

c. The date specified in any written notice from the Commissioner stating that the Respondent is no longer allowed to use emissions trading due to the Respondent's violation ofany provision ofthis Trading Agreement and Order; or d. The date specified in any written notice from the Commissioner, notifying the Respondent that the Commissioner has determined the use ofemissions trading as a compliance option has been further restricted, modified ornullified by:

(i) the promulgation ofan Act, Statute, or Regulations; or (ii) the issuance ofajudgment or court order. 2. Respondent shall obtain and use sufficient DERCs and/orAllowances in such a manner as to comply with Paragraphs B.7 and B.8 ofthis Trading Agreement and Order. All Allowances used must come from an emission unit that is within the same ozone nonattainment area as the Respondent. Any Allowances used to comply with this Trading Agreement and Ordermust be allocated for the control period that occurs during the same yearthose allowances are used for compliance with this Trading Agreement and Order. All DERCs used during the Ozone Season for the emission unit described in Table 1, shall have been generated during an Ozone Season. 3. Prior to using Allowances in accordance with Paragraphs B.7 and B.8 ofthis Trading Agreement and Orderthe Respondent shall obtain a General Account or Compliance Account in the CArRNATS. 4. Vintage Restriction. For the purposes ofcompliance with Section 22a-174-22 ofthe Regulations and the provisions ofthis Trading Agreement and Order, DERCs shall only remain valid for five (5) calendaryears from the year ofthe generation ofsuch DERCs. DERCs olderthan five (5) calendar years from their creation are not valid for use for compliance with Section 22a-174-22 ofthe Regulations and the provisions ofthis TradingCascades Boxboard Group ConnecticutLLC Agreement and Order 

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5. Ozone Season Fuel Use Restriction: Notwithstanding the provisions ofParagraph B.2 ofthis Trading Agreement and Order, when operating the emission unit described in Table I during the Ozone Season, the Respondent shall operate the unit while firing or co-firing the lowest NOx emitting fuel type or combination offuel types that the unit is authorized to burn in accordance with Departmental permit, registration, or applicable regulation. 6. Notwithstanding Paragraph B.5 ofthis Trading Agreement and Order, during the Ozone Season, the Respondent may operate the emission unit described above on fuels thatresult in higher emissions ofNOx, ifeither:

a. the availability offuel oil that complies with Paragraph B.5 is inadequate to meet the needs ofresidential, commercial and industrial users in this state and that such inadequate supply constitutes an emergency; or b. the supply ofgaseous fuels to the emissionunit is interrupted due to inadequate supply or in accordance with an interruptible supply agreement between the Respondent and the gaseous fuel supplier. 7. DERC/Allowance Use. Onthe first day ofeach calendarmonth, the Respondent shall possess a quantity ofDERCs and/or Allowances that equals or exceeds the quantity ofActual DERCs Required and/orActual Allowances Required in thatmonth. Compliance with ParagraphB.7 ofthis Trading Agreement and Order shall be determined as follows:

a. Before the first day ofeach month, Respondent shall estimate DERCs and/or Allowances required for such calendar month for the emission unit described in Table 1 as follows: Estimated DERCs/Allowances Reguired = {(Estimated fuel use in MMBtu) x ((Estimated 24-hr average emission rate lb/mmbtu)- (0.95 x AEL))}+2000 Ibs/ton Where:

• AEL = Allowable Emission limit, as defined in Paragraph A.4 ofthis Trading Agreement and Order

• Discount (0.95) = 5% design margin applied to the AEL. b. No later than the twentieth day ofeach month, Respondent shall calculate actual DERCs and/or Allowances used in the preceding calendar month for the emission unit described in Table 1 as follows:Cascades Boxboard Group ConnecticutLLC 

### 5 Trading Agreement and Order 8297

Actual DERCs/Allowances Required = 2:{(Daily fuel use MMBtu) x ((actual 24-hr average emission rate Ib/mmbtu)

- (0.95 x AEL»} .;- 2000 Ibs/ton For all days in the month where actual 24-hraverage emissions rate> AEL 8. Non-Ozone Season DERC/Allowance Use. In addition to the requirements ofParagraph B.7 ofthis Trading Agreement and Order, on the first day ofeachNon-Ozone Season, the Respondent shall possess a quantity ofDERCs and/orAllowances that equals or exceeds the quantity ofNon- Ozone Season Actual DERCs/ Allowances Required for thatNon-Ozone Season. Compliance with Paragraph B.8 ofthis Trading Agreement and Order shall be determined as follows:

a. Before the first day ofeachNon-Ozone Season, Respondent shall estimate DERCs and/or Allowances required for thatNon- Ozone Season for the emission unit described in Table I based on the average actual NOx emission rate from the emission unit and an emission limit of0.1 5 Ib/mmbtu as follows: EstimatedNon-Ozone Season DERCs/Allowances Required = {(Estimated Non-Ozone Season fuel use in MMBtu) x ((estimated average NOx Emission Rate Ib/mmbtu)

- (0.95 x 0.15 Ib/mmbtu»}.;- 2000 Ibs/ton b. No later than thirty (30) days afterthe end ofeachNon-Ozone Season, the Respondent shall calculate Actual Non-Ozone Season DERCs and/or Allowances used during thatNon-Ozone Season for the emission unit as follows: Actual Non-Ozone Season DERCs/Allowances Required = {(Actual Non-Ozone Season fuel use in MMBtu) x ((Non-Ozone Season Average Actual NOx Emission Rate lb/mmbtu)

- (0.95 x 0.15 Ib/mmbtu»}.;-2000 lbs/ton

- 2:( DERCS and/or Allowances Required for all months ofthe Non-Ozone Season calculated pursuantto Paragraph B.7) 9. On or before January 3I ofeach calendar year, the Respondent shall deduct a quantity of DERCS from the currentbalance ofDERCs possessed by the Respondent and/or transfer a quantity ofAllowances from the Respondent's NOx General and/or Compliance Accounts to the CT State NOx Retirement Account (Account ID CT0000000300 in the CAIRNATS) such that the total is equal to the sum ofActual DERCs/ Allowances Required pursuant to Paragraph B.7 ofthis Trading Agreement and Order for the preceding calendaryear, rounded up to the nearest whole ton. 10. Not more than thirty (30) days afterthe completion ofthe Non-Ozone Season, the Respondent shall deduct a quantity ofDERCS from the currentbalance ofDERCs possessed by theCascades Boxboard Group ConnecticutLLC 

### 6 Trading Agreement arid Order 8297 Respondent and/ortransfer aquantity ofAllowances from the Respondent's NOx General Accountto the CT StateNOx RetirementAccount (Account ID CT0000000300 inthe CAIR NATS) such that the total is equal to Actual Non-Ozone Season DERCs/ Allowances Required for the most recently completed Non-Ozone Season. Notwithstanding the control period limitations ofParagraph B.2 ofthis Trading Agreement and Order, Allowances used to comply with this Paragraph for aNon-Ozone Season must have been originally allocated for the control periods that correspond to the same calendaryears withinthatNon-Ozone Season. II. Doubling: Ifthe Actual DERCs/Allowances Required for any month, determined in accordance with Paragraph B.7, exceeds the quantity ofDERCs and/or Allowances inthe Respondent's possession onthe first day ofthat month, then in addition to the deduction or transfer specified in Paragraphs B.9, the Respondent shall deduct a quantity ofDERCs from the currentbalance ofDERCs possessed by the Respondent and/or transfer a quantity of Allowances from the Respondent's NOx General and/or Compliance Accounts to the CT StateNOx Retirement Account (Account ID CT0000000300 in the CAIRNATS) such that the total is equal to Actual DERCs/Allowances Required for thatmonth. Such additional DERC deduction or Allowance transfer shall be performed atthe same time as the DERC deduction or Allowance transfer specified in Paragraph B.9 ofthis Trading Agreement and Order. Ifthe Actual DERCs/Allowances Required for any Non-Ozone Season, determined in accordance with Paragraph B.8, exceeds the quantity ofDERCs and/or Allowances in the Respondent's possession on the first day ofthatNon-Ozone Season, then in additionto the deduction ortransfer specified in Paragraphs B.l0, the Respondent shall also deduct a quantity ofDERCs from the currentbalance ofDERCs possessed by the Respondent and/or transfer a quantity ofAllowances from the Respondent's NOx General Account or Compliance Account to the CT State NOx Retirement Account (Account ID CT0000000300 in the CAIRNATS) such thatthe total is equal to Actual Non-Ozone Season DERCs/Allowances Required for the most recently completedNon-Ozone Season. Such additional DERC deduction orAllowance transfer shall be performed at the same time as any DERC deduction orAllowance transfer specified in Paragraph B.l0 ofthis Trading Agreement and Order. Notwithstanding the provisions ofParagraph B.ll ofthis Trading Agreement and Order, any violation ofParagraphs B.7 and B.8 ofthis Trading Agreement and Order may be subjectto additional enforcement action as may be deemed appropriate by the Commissionerin accordance with the Department's enforcementresponse policy. 12. At the end ofeach calendaryear, the Respondent shall demonstrate that any Allowances used for compliance withthis Trading Agreement and Order during the year are surplus, quantifiable, enforceable and permanent. This shall be determined by demonstrating thatthe actual NOx emissions during the ozone season, as reported to the United States Enviromnental Protection Agency, from the emission unitto whichthe Allowances were originally allocated were equal to or less than the amount ofAllowances allocated to such unitby the State of Connecticut minus the Allowances used for compliance with this Trading Agreement and Order.Cascades Boxboard Group Connecticut LLC 7 Trading Agreement and Order 8297 13. Maintenance and Tune-up. Not more than 1 year from the date ofissuance ofthis Trading Agreement and Order, the Respondent shall perform maintenance and inspection ofthe emissionunit listed in Table 1. Such maintenance and inspection shall include, but not be limited to, the following:

a. Inspect the combustion system, and clean or replace any components ofthe combustion system as necessary, in accordance with manufacturer's specification or current good engineering practice; b. Inspect the system controlling the air-to-fuel ratio, and ensure that it is calibrated and functioning in accordance with the manufacturer's specifications orcurrent good engineering practice;

c. Measure the operating parameters ofthe eJTlission unit used to determine thatthe emission unit is operating in accordance with manufacturer's specification or current good engineering practice prior to and after any adjustments are made during maintenance, tune-up, or inspection activity; d. Make and keep records including, but not limited to, the following:

I. Demonstration that any maintenance, tune-up, and/or inspection activity performed on the emission unit described in Table 1 in accordance with Paragraph B.13 ofthis Trading Agreement and Order has beenperformed in accordance with the manufacturer's specifications or current good engineering practice,

11. The date and a description ofany maintenance, tune-up, and/or inspection activity performed on the emission unit described in Table I in accordance with Paragraph B.13 ofthis Trading Agreement and Order, iii. The name, title and affiliation ofthe person conducting any maintenance, tune-up, and/or inspection activity performed on the emission unit described in Table I in accordance with Paragraph B.13 ofthis Trading Agreement and Order,

IV. The operating parameters ofthe emission unit used to determine that the emission unit is operating in accordance with manufacturer's specification or current good engineering practice prior to and after any adjustments are made during maintenance, tune-up, or inspection activity performed in accordance with Paragraph B.13 ofthis Trading Agreement and Order. 14. Record Keeping;

a. By the close ofeach calendar day, the Respondent shall record the actual 24-hour average NOx emission rate for any emission unit equipped with an approved CEMS and the actual fuel type and the actual quantity ofeachCascades Boxboard Group ConnecticutLLC 

### 8 Trading Agreement and Order 8297 type offuel 

### in units ofvolumeper day or MMbtuper day for each fuel used on the preceding day 

### in any ofthe emission units described 

### in this Trading Agreement and Order; b. On ofbefore the first day ofeach calendarmonth, the Respondent shall record the number ofDERCs and corresponding serial numbers and vintages for all DERCs 

### in its possession on the first calendar day ofthat calendar month;

c. On orbefore the first day ofeach calendarmonth, the Respondent shall record the number ofAllowances and corresponding identification numbers and allocation control periods for all Allowances 

### in its possession onthe first calendar day ofthat calendar month; d. On orbefore the first day ofeach calendarmonth, the Respondent shall record the number ofDERCs and corresponding serial numbers, vintages, purchase/sales dates, and sellerlbuyerfor all DERCs purchased or sold during the preceding calendar month;

e. On orbefore the first day ofeach calendar month, the Respondent shall record the number ofAllowances and corresponding identification numbers, purchase/sales dates, allocationyears, and sellerlbuyerfor all Allowances purchased or sold during the preceding calendarmonth; f. On orbefore the first day ofeach calendar month, the Respondent shall recordthe Estimated DERCs/Allowances Required for that calendar month determined 

### in accordance with Paragraph B.7 ofthis Trading Agreement and Order; g. On orbefore the twentieth calendar day ofeach calendarmonth, the Respondent shall recordthe Actual DERCs/ Allowances Required for the preceding calendarmonth determined 

### in accordance with Paragraph B.7 of this Trading Agreement and Order;

h. On orbefore the twentieth calendar day ofeach calendarmonth, the Respondent shall record the quantity ofDERCs deducted 

### in accordance with Paragraphs B.9 and B.Il ofthis Trading Agreement and Orderfor the preceding month. Suchrecords shall include the serial number and vintage ofeach DERC deducted from the Respondents currentbalance pursuantto Paragraphs B.9 and B.Il ofthis Trading Agreement and Order;

I. On orbefore January 31 ofeach calendar year, the Respondent shall record the quantity ofDERCs deducted 

### in accordance with Paragraphs B.9 and B.ll ofthis Trading Agreement and Orderfor the preceding month. Such records shall include the serial number and vintage ofeach DERC deducted from the Respondents currentbalance pursuant to Paragraphs B.9 and B.ll ofthis Trading Agreement and Order; j. On orbefore January 31 ofeach calendaryear, the Respondent shall record the quantity ofAllowances transferred 

### in accordance with Paragraphs B.9Cascades Boxboard Group Connecticut LLC 9 Trading Agreement and Order 8297 and B.ll ofthis Trading Agreement and Order. Such records shall include the identification number and allocation control period ofeach Allowance transferred pursuantto Paragraphs B.9 and B.ll ofthis Trading Agreement and Order; k. Not more than thirty (30) days afterthe completion ofeachNon-Ozone Season, the Respondent shall record the Non-Ozone Season average NOx emission rate for the emissions unit described in Table 1, the quantity DERCs and/or allowances possessed on the first day ofthe Non-Ozone Season, the quantity ofDERCs deducted and/or Allowances transferred in accordance with Paragraphs B.l0 and B.ll ofthis Trading Agreement and Order; 

### 1. For each month ofthe Ozone season, the Respondent shall maintainrecords attesting to the fact that any DERCs deducted from its balance in accordance with Paragraphs B.9 and B.ll ofthis Trading Agreement and Order satisfYthe requirements ofParagraph B.2. Generator certification of this fact shall be sufficient; and

m. On each day during the ozone season that the Respondent operates in accordance with Paragraph B.6 ofthis Trading Agreement and Order, the Respondent shall make and keep Records ofall emission unit operation in accordance with Paragraph B.6 ofthis Trading Agreement and Order, including copies ofany written correspondence from the Respondent's fuel supplier detailing the duration and circumstances ofthe inadequate fuel oil supply or interruption ofgaseous fuel supply to the emission unit. 15. Respondent shall retain records and supporting documentation required by this Trading Agreement and Order for a minimum offive years, commencing on the date such records were created. Respondent shall provide the records specified above to the Commissioner within thirty (30) days ofreceipt ofa writtenrequest from the Commissioner. All records shall be maintained in accordance with Sections 22a-174-4 and 22a-174-22 ofthe Regulations. 16. Reporting: No laterthan March 1 ofevery year after issuance ofthis Trading Agreement and Order, the Respondent shall submitto the Commissioner a writtenreport containing copies of all ofthe records requiredpursuant to Paragraphs B.l4.a

- B.14.i, B.l4j., B.l7.l and B.l7.m ofthis Trading Agreement and Order. Not later than July 30 ofeach calendar year, the Respondent shall submit a written report containing copies ofall records requiredpursuant to Paragraph B.14.k ofthis Trading Agreement and Order. The Commissionermay prescribe the forms to be used for the submission ofthese reports. The Respondent shall submitthese reports on such forms, ifprescribed by the Commissioner.

17. Full compliance. Respondent shall not be considered in full compliance withthis Trading Agreement and Order until all actions required by this Trading Agreement and Order have been completed as approved andto the Commissioner's satisfaction. 18. Approvals. Respondent shall use best efforts to submitto the Commissioner all documents required by this Trading Agreement and Order in a complete and approvable form. Ifthe Commissioner notifies Respondent that any document or other action is deficient, and doesCascades Boxboard Group ConnecticutLLC 10 Trading Agreement and Order 8297
not approve it with conditions or modifications, it is deemed disapproved, and Respondent shall correctthe deficiencies and resubmit it withinthe time specified bythe Commissioner or, ifno time is specified by the Commissioner, within 30 days ofthe Commissioner's notice ofdeficiencies. In approving any document or other action underthis Trading Agreement and Order, the Commissionermay approve the document or other action as submitted or performed or with such conditions ormodifications as the Commissioner deems necessary to carry out the purposes ofthis Trading Agreement and Order. Nothing inthis paragraph shall excuse noncompliance ordelay. 19. Definitions. As used inthis Trading Agreement and Order "Commissioner" means the Commissioner or a representative ofthe Commissioner; The date of"issuance" ofthis Trading Agreement and Order is the date the Trading Agreement and Orderis deposited in the U.S. mail orpersonally delivered, whichever is earlier. 20. Dates. The date ofsubmissionto the Commissioner ofany document required by this Trading Agreement and Order shall be the date such document is received by the Commissioner. The date ofany notice bythe CommissionerunderTrading 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 or is personally delivered, whichever is earlier. Except as otherwise specified inthis Trading Agreement and Order, the word "day" as used inthis Trading Agreement and Order means calendar day. Any document or action which is required by this Trading Agreement and Orderto be submitted orperformed by a date which falls on a Saturday, Sunday or a Connecticut or federal holiday shall be submitted orperformed bythe next day which is not a Saturday, Sunday or Connecticut or federal holiday. 21. Certification ofdocuments. Any document, including but not limited to any notice, which is required to be submitted to the Commissionerunderthis Trading Agreement and Order shall be signed by the Respondent or, ifRespondent is not an individual, by an individual, employed by the Respondent, who satisfies the criteria set forth in Section 22a-174-2a(a)(l) ofthe Regulations ofConnecticut State Agencies and bythe individual(s) responsible for actually preparing such document. Each individual who signs documents in accordance with this Paragraph shall certif'y in writing as follows: "I have personally examined and am familiar with the information submitted in this document and all attachments thereto, and Icertif'y, based on reasonable investigation, including my inquiry ofthose individuals responsible for obtaining the information, that the submitted information is true, accurate and complete to the best ofmy knowledge and belief. I understand that any false statement made inthe submitted informationmay be punishable as a criminal offense under Section 53a-157b ofthe Connecticut General Statutes and any other applicable law."
22. Noncompliance. This Trading Agreement and Orderis a final order ofthe Commissioner withrespect to the matters addressed herein, and is nonappealable and immediately enforceable. Failure to comply with this Trading Agreement and Ordermay subject Respondent to an injunction and penalties.Cascades Boxboard Group ConnecticutLLC II Trading Agreement and Order 8297 23. False statements. Any false statementin any information submitted pursuant to this Trading Agreement and Order maybe punishable as a criminal offense under Section 53a-157b ofthe Connecticut General Statutes and any other applicable law. 24. Notice oftransfer; liability ofRespondent. Until Respondent has fully complied withthis Trading Agreement and Order, Respondent shall notify the Commissionerin writing no later than 15 days aftertransferring all or any portion ofthe facility, the operations, the site orthe business which is the subject ofthis Trading Agreement and Order or after obtaining a new mailing or location address. Respondent's obligations underthis Trading Agreement and Order shall notbe affected by the passage oftitle to any propertyto any otherperson or municipality. 25. Commissioner's powers. Nothing in this Trading Agreement and Order shall affectthe Commissioner's authority to institute anyproceeding ortake any other action to prevent or abate violations oflaw, prevent or abate pollution, recovercosts and natural resource damages, and to impose penalties for past, present, or future violations oflaw. Ifat any time the Commissioner determines that the actions taken by Respondentpursuant to this Trading Agreement and Orderhave not successfully corrected all violations, fully characterized the extent or degree ofany pollution, or successfully abated orprevented pollution, the Commissioner may institute any proceeding to require Respondent to undertake further investigation or further action to prevent or abate violations orpollution. 26. Respondent's obligations under law. Nothing in this Trading Agreement and Order shall relieve Respondent ofother obligations under applicable federal, state and local law. 27. No assurance by Commissioner. No provision ofthis Trading Agreement and Order and no action or inaction by the Commissioner shall be construed to constitute an assurance by the Commissionerthatthe actions taken by Respondent pursuantto this Trading Agreement and Orderwill result in compliance orprevent or abate pollution. 28. Access to premises. Any representative ofthe Department ofEnvironmental Protection may enterthe without prior notice for the purposes ofmonitoring and enforcing the actions required or allowed by this Trading Agreement and Order. 29. No effect onrights ofotherpersons. This Trading Agreement and Order neither creates nor affects any rights ofpersons ormunicipalities that are notparties to this Trading Agreement and Order. 30. No Creation ofProoertv Rights. This Consent Order does not create any propertyrights with respect to these DERCs or Allowances. 31. Notice to Commissioner ofchanges. Within IS days ofthe date Respondent becomes aware ofa change in any information submitted to the Commissionerunderthis Trading Agreement and Order, orthat any such information was inaccurate ormisleading orthat any relevant information was omitted, Respondent shall submitthe correct or omitted informationto the Commissioner.Cascades Boxboard Group ConnecticutLLC 12 Trading Agreement and Order 8297 32. Notification ofnoncompliance. In the eventthat Respondent becomes aware that it did not or may not comply, or did not or may not comply on time, with any requirement ofthis Trading Agreement and Order or ofany document required hereunder, Respondent shall immediately notifY by telephone the individual identified inthe next paragraph and shall take all reasonable steps to ensure that any noncompliance or delay is avoided or, ifunavoidable, is minimized to the greatest extentpossible. Within five (5) days ofthe initial notice, Respondent shall submit in writing the date, time, and duration ofthe noncompliance and the reasons for the noncompliance ordelay and propose, for the review and written approval of the Commissioner, dates by which compliance will be achieved, and Respondent shall comply with any dates which maybe approved in writing by the Commissioner. Notification by Respondent 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 Commissionerin writing. 33. Submission ofdocuments. Any document required to be submitted to the Commissioner under this Trading Agreement and Order shall, unless otherwise specified in this Trading Agreement and Order or in writing bythe Commissioner, be directed to:
Supervisor AdministrativeEnforcement Group Engineering and Enforcement Division Bureau ofAir Management Department ofEnvironmental Protection 79 Elm Street, 5th Floor Hartford, Connecticut 06106 (860) 424-3702Cascades Boxboard Group ConnecticutLLC 13 Trading Agreement and Order 8297
Respondent consents to the issuance ofthis Trading Agreement and Order without further notice. The undersigned certifies thathe/she is fully authorized to enterinto this Trading Agreement and Order and to legally bind Respondent to the terms and conditions ofthe Trading Agreement and Order. 

# /V/!!_ Signature:

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# --'~'-""'---'=----=--~----

Type Title: 

### GGclE7?4-L..--- A14Mf-66!.- Date: 

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Issued as a final consent order ofthe Commissioner ofthe Department ofEnvironmental Protection.

G e, Director Eng· eering & Enforcement Division Bureau ofAir Management

TOWN OF SPRAGUE MAILED CERTIFIED MAIL, RETURN RECEIPT REQUESTED Certified Document 

# os - 05 - ..:u:, '0 Date