SIP DESCRIPTION -CRRA -Tradine Aerccment and Order No. 8116B

I. SIP - DESCRIPTION OF DERC CREATION ANDIOR USE

SIP SUMMARY TABLE

Tradinf Aereemcot and Order No. 8116B

Connecticut Resources Recovery Authority Reserve~MaximRd Hartford cr 06103

(CRRA, Mid - Conn. I South Meadow Statio~)

Identifier IClient 5497 Town # 75 Premise # 1 Sequence #

158

Contact Mr. Scon Smith, Tel: (860) 757- 7725 Fax (860) 757-7742

Environmental Manae:er Smith(@.crra.onz

Pollutant and Regulatory Standard: NOx I Section 22a-174-22 ofthe Regulations of

Connecticut State Astencies.

Nonattainment Area Classification Serious

Annual DERCs needed Estimated < 5 tons.

Annual DERCs 2enerated Estimated aoproximately 5 tons

Comoliance Time Period Unlil Aori130, 2007.

Max. Emission Rate: CEM and fun load emission rate (FLER) for Generation

and Use. (See Table I below):

Table 1

CRRA Turbine Generators Trading Agreement and Order No. 81168

NOx Emissions Rate and AJlowable Limits in IbsIMMBtu

DEP Permits Fuel Maximum Slack Allowable FLER Date of Next Slack Test

and Re~. No. Cao3citv Test Rate Rate Stack Test Date

IIA NO.20ill 256.5 0.79 0.289 0.81 11130/04 11130/09

R160 distillate

liB NO.20ill 256.5 0.70 0.289 0.81 11130/04 11/30/09

R161 Distillate

12A No.20ill 256.5 0.76 0.289 0.81 12101104 12101109

R162 distillate

12B No.20ill 256.5 0.68 0.289 0.81 12101104 12101109

R163 Distillate

13A No.20ill 256.5 0.80 0.289 0.81 12102104 12102109

R164 Distillate

13B No. 2 Oil I 256.5 0.77 0.289 0.81 12102104 12102109

R165 Distillate

14A No.2 Oil I 256.5 0.80 0.289 0.81 12103104 12103109

R166 Distillate

14B No.20ill 256.5 0.68 0.289 0.81 12103/04 12103109

R167 Distillate

n. SPECIAL REQUIREMENTS

a CRRA operates eight (8) combustion turbines ("peaking units") in accordance with the

data shown in Table I above.

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

8116B.

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STATE OF CONNECTICUT

DEPARTMENT OF ENVIRONMENTAL PROTECTION

In the matter of )

)

The State of Connecticut )

)

and )

)

The Connecticut Resources Recovery Authority )

)

Trading Agreement

and Order No. 8116B

Whereas, the Commissioner of Environmental Protection ("Commissioner") and the Connecticut

Resources Recovery Aut}1ority ("eRRA") agree that it is in the public interest that they work

cooperatively to improve the air quality within the State of Connecticut and that the use of discrete

emission reduction credit ("DERC") trading to reduce nitrogen oxide ("NOx") emissions will

achieve this result in a timely and cost-effective manner.

A. At the request and with the agreement of CRRA. the Commissioner finds the following:

;:

, .

I. This Trading Agreement and Order supersedes Trading Agreement and Order 8116A

signed by the Commissioner on March 18,2003.

2. CRRA is a public instrumentality and political subdivision of the State of Connecticut

established to provide solid waste management services to Connecticut's municipalities

located at Reserve-Maxim Roads, Hartford, Connecticut ("facility").

3. At the facility, CRRA owns and operates fuel burning equipment which consists of eight

(8) combustion turbines ("peaking units") which are subject to section 22a-174-22 of the

Regulations of Connecticut State Agencies ("Regulations") pertaining to the control of

NOx emissions.

4. On the dates provid~d in Table I of this Trading Agreement and Order, CRRA perfonmed

NOx stack emission testing approved by the Commissioner.

5. CRRA exceeds the NOx allowable emission rate limit specified in Section 22a-174-22(e)

of the Regulations as shown in Table 1 of this Trading Agreement and Order.

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The Connecticut Resources

Recovery Authority

2 Trading Agreement and

Order No. 8116B

Table 1

NUx RAT"'" AND ABLE LL"'I1T~ (Ibs/MMBru)

Fuel Burning FUEL FLER NOx Stack Test Date of

EquipmentJ Next Stack (IbsIMMBru) Allowable Rate Stack Test

Registration.No. Rate (IbsIMMBru) Test Due

ObsIMMBru) Date

11A ! N~. Zor 0.79 11130104 11130109 other

R260 distillate oil 0.81 0.289

liB No.2 or 0.70 11130104 11130109

R261 other

distillate oil 0.81 0.289

12A No.2 or 0.76 1211104 1211/09

R262 other

distillate oil 0.81 0.289 .

12B No.2 or 0.68 1211104 1211109

R263 other

distillate oil 0.81 0.289

13A No.2 or 0.80 1212104 1212109

R264 om",

distillate oil 0.81 0.289

BB . No.2 or 0.77 1212104 1212109

R265 om",

distillate oil 0.81 0.289

14A No.2 or 0.80 1213/04 1213/09

R266 other

distillate oil 0.81 0.289

14B No.2 or 0.68 1213/04 1213/09

R267 other

distillate oil 0.81 0.289

6. Pursuant to Section 22a-174-22U) of the Regulations CRRA proposes to comply with

Section 22a-174-22(e) of the Regulations, for the peaking units' emissions, through the

use of approved DERCs until May I, 2007 at the facility in accordance with this Trading

Agreement and Order. - i

B. The Commissioner, in accordance with the provisions of this Trading Agreement and Order,

pursuant to Subdivision 22a-174-22(j) of the Regulations, hereby allows CRRA to comply

with Section 22a-174-22 of the Regulations, at the facility, through use ofDERC and Budget

emission reduction credits ("BDERC'') trading.

C. Therefore, with the agreement of CRRA, the Commissioner, acting under Connecticut

General Statutes Sections 22a-6, 22a-171, 22a-174, 22a-176 and 22a-177, hereby orders

CRRA as follows:

1. Upon issuance of this Trading Agreement and Order, at the facility, CRRA shall comply

with Section 22a-174-22 of the Regulations through emission reduction trading until the

peaking units achieve pennanent compliance with the emission scandard in Section 22a174-22(e) of the regulation or by May 1, 2007, whichever occurs earlier, as follows:
The Connecticut Resources

,-:--... Recovery Authority f· . '.: '

3 Trading Agreement and

Order No. 8116B

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a. CRRA shall use approved DERCs as required under this Trading Agreement and

Order;

b. CRRA shall have in ,its possession sufficient approved DERCs to meet applicable

NOx emission limits as allowed under this Trading Agreement and Order, and

c. CRRA shall comply during operation of each peaking unit with the FLERs shown

in Table I of this Trading Agreement and Order.

2. DERC use for the Peaking Units.

a. Until May I, 2007, before the Ii"t day of each month CRRA shall have in its

possession sufficient approved DERCs for such month for the peaking units

based on the following calculations;

Before the Ii"t day of each month, CRRA shall estimate DERCs required for such

month for the peaking units as follows;

(i) At all times:

Estimated DERCs (in tons) use; [«(FLER in IbslMMBtu) - (0.95 x NOx

allowable rate in IbsIMMBtu» x (estimated

fuel use in MMBtu)] .. 2000 pounds/ton

No later than th~ twentieth day of each month, CRRA shall calculate and permanently

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

Actual DERCs (in tons); [«(FLER in IbslMMBtu) - (0.95 x NOx allowable rate

in IbsIMMBtu» x (actual fuel use in MMBtu)] .. 2000

pounds/ton

Where:

• NOx allowable rate ; allowable limit rate in IbsIMMBtu shown in Table I of this

Trading Agreement and Order.

• FLER ; full load emission rate in IbsIMMBtu 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 onlv:

No later than December 31$1 each year, CRRA shall acquire and permanenrly retire

seven ozone season DERCs for every actual ton of excess NOx emiued 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 l·hour s~andard. Upon such revocation, CRRA shall calculate and pernlJnently

retire seven ozone season DERCs for every actual ton of excess NOx emitted from the
peaking units 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 Connecticut Resources

Recovery Authority

4 Trading Agreement and

Order No. 8116B

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Where:

Actual ton of excess NOx emitted: [((FLER in IbslMMBtu) - (0.95 x

NOx allowable rate in IbslMMBtu)) x (actual fuel

use in MMBtu)] .;. 2000 pounds/ton

The total actual tons of excess 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 of DERCs to be pennanently retired. This

requirement is in addition to the CRRA's requirement to estimate excess emissions and

subsequent pennanent retirement of a sufficient number of approved DERCs in

accordance with paragraph C.2.a.(i) of this Trading Agreement and Order.

b.

c.

During the non·ozone season: Until May 1, 2007, from October 1 through April

30, inclusive, each year, the peaking units shall, in addition to meeting the 24-hour

emissiQn limit in Table 22·1 of Section 22a-174-22 of the Regulations, meet a

non-ozone season emission limit of 0.15 IblM:MBtu. Prior to October 1, 2004,

October 1, 2005 and October 1, 2006, CRRA shall estimate and acquire the

amount of DERCs or allowances required for such non-ozone season to comply

with Section 22a-174-22(e)(3) of the Regulations as follows:

Estimated DERCs (tons) use: [Estimated fuel use in MMBtu from October 1

through April 30 x (allowable emission rate in

IbsIMMBtu - (0.95 x 0.15IblMMBtu))].;. 2000

lbslton

No later than May 31 of 2005,2006 and 2007, in addition to the DERCs retired pursuant

to paragraph C.2.a. of this Trading Agreement and Order. CRRA shall calculate and

permanently retire DERCs used in the preceding non-ozone season as follows:

Actual DERCs (tons) used: [Actual fuel use in MMBtu from October 1 through April

30 x (allowable emission rate in IbsIMMBtu - (0.95 x 0.15

lb/MMBtu))j .;. 2000 lbslton

[i

,

3. BDERCs shall only be used by other NOx Budget Program sources located in Connecticut.

BDERCs shall only be used to offset ozone season excess emissions, and shall not be used for

compliance during the non-ozone season. BDERCs generated during a given year shall only be

used during the following ozone season. BDERCs are subject to all DERC requirements set

forth in this Trading Agreement and Order except for those requirements penaining solely to

non-ozone season DERCs and as otherwise may be provided.

4. CRRA shall make and keep records of: daily fuel use and fuel type; excess NOx

emissions; the numbetof DERCs in its possession. purchased and used (by serial number

if assigned) each month in accordance with the appropriate emission rates and limits in
Trading Agreement and

Order No. 8116B

The Connecticut Resources 5

t~"--'. Recovery Authority

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this Trading Agreement and Order; the number of DERCs used during the ozone season

and non-ozone season (the remainder of the year); during the ozone season, the ozone

classification as forecasted by the Commissioner on the previous day; as well as

documentation attesting to the fact that approved DERCs used during the ozone season

were generated during the ozone season. Generator certification of this fact shall be

sufficient. CRRA shall maintain and submit such records to the Commissioner in

accordance with Section 22a-174-22 of the Regulations.

5. Record Keeping. CRRA shall retain records and supporting documentation as described

in this Trading Agreement and Order for a minimum of five years, commencing on the

date such records were created. CRRA shall maintain documentation to attest to the fact

that the DERCs used during the ozone season were generated during the ozone season,

generator certification of this fact shall be sufficient; and provide the records specified

above to the Commissioner within thirty (30) days of receipt of a written request from the

Commissioner.

6. (a) Annual DERC Reoort. No later than March 1 of every year after issuance of this

Trading Agreement and Order, CRRA shall submit in writing to the Commissioner,

a record of each sale or other transfer of DERCs for the previous calendar year.

CRRA shall also include actual NOx emissions from the peaking units 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 ozone and non ozone

seasons.

(b) Starting on October 1, 2004: No later than July 30 of every year after issuance of

this Trading Agreement and Order, CRRA shall submit in writing to the

Commissioner the non-ozone season fuel consumption and amount of all DERCs

used (including serial numbers (if assigned) and approved DERCs purchased from

other facilities) for the peaking units during the October through April time period

in the previous calendar year. These reports shall be on a fonn prescribed by the

Commissioner.

7. Allowance Use. Pursuant to Section 22a-174-22(d)(3) of the Regulations, CRRA may

use NOx allowances, until May I, 2007 for the peaking units pursuant to Section 22a174-22(j) of the Regulations to achieve all or a portion of the reductions required by

section 22a-174-22 of the Regulations. ·Any allowance used for compliance with

Section 22a-174-22(e) of the Regulations shall be subject to all restrictions and/or

requirements applicable to DERCs contained in this Trading Agreement and Order;

a. In order for CRRA to use NOx allowances, CRRA shall create a general

account or use an existing compliance account or overdraft account in EPA's

NOx Allowance Tracking System ("NATS"); and

b. Each allowance used for compliance with Section 22a-174-22 of the

Regula;ions shall be equivalent to one discrete emission reduction credit.

Allowances shall be considered used for compliance with Section 22a-l74-
The Connecticut Resources

Recovery Authority

6 Trading Agreement and

Order No. 8116B

22 of the Regulations when they are transferred from the facility's NOx

general account in the NATS or the facility's NOx compliance account in the

NATS to the cr State NOx Retirement Account (Account ID

crOOOOO00300 in the NATS).

8. DERC Shomall. At a minimum, DERCs required shall be adjusled upwards by 100% if DERCs

are not in CRRA's possession for use prior to the first day of each month or applicable season.

However, nothing in this Trading Agree~ent 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. CRRA

shall permanently retire the quantity ofDERCs equivalent to the excess emissions plus a 100%

premium within sixty (60) days of CRRA's discovery of the DERC shomal!. CRRA shall

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

paragraph C.30. of this Trading Agreement and Order.

9. Vintage Restriction. For the purposes of compliance with Section 22a-174-22 of the

Regulations, DERCsiallowances shall only remain valid for five (5) calendar years from

the year of the generation/allocation of such DERCsiallowances. DERCsiallowances

older than five (5) calendar years from their creation/allocation are not valid for use for

.compliance with Section 22a-174-22 of the .Regulations. Notwithstanding the above,

DERCsiallowances generated/allocated prior to calendar year 2000 are valid for use for

compliance with Section 22a-174-22 of the Regulations up to and including December

31,2004.

10. R..ER Exceedance. Noncompliance with an established FLER shall subject CRRA 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 lbsJM:11Btu, multiplied by the total heat input during the period of

noncompliance divided by 2000 lbslton. If the period of noncompliance is not known,

the time period from the completion of the 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 or take any other

action to require additional upward adjustment, based on the gravity of any alleged

noncompliance or violation of law. CRRA shall permanently retire DERCs calculated in

accordance with the above plus a 100% premium within sixty (60) days of CRRA's

discovery of the FLER exccedancc. CRRA shall report any FI.ER exceedance to the

Commissioner in accordance with paragraph C.30. of this Trading Agreement and Order.

o

11. FLER Modification. FLERs set forth in Table 1 of this Trading Agreement and Order

may be modified only after the consent of the Commissioner by written modification of

this Trading Agreement and Order.

12. Emissions Testing. Pursuant to Section 22a-174-22(k) of the Regulations CRRA shall

conduct NOx emission tests of the peaking units at least once every five years

commencing from the dates of the emission tests for the peaking units as provided in

Table 1 of this Trading Agreement and Order.

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The Connecticut Resources

<''-..1 Recovery Authority

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7 Trading Agreement and

Order No. 8116B

13. Extension. No later than May 1, 2007, with respect to the peaking units, CRRA shall

comply with the requirements of Sections 22a-174-22(d)(I) and 22a-174-22(d)(2)(A) 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.

14. Future Compliance RepoIt. On or before September I, 2006, CRRA shall submit a repoIt

indicating how the facility shall comply with Section 22a-174-22 of the Regulations with

respect to the peaking units on and after May 1,2007.

15. Full compliance. CRRA shall not be considered in full compliance with this Trading

Agreement and Order until all actions required by this Trading Agreement and Order

have been completed as approved and to the Commissioner's satisfaction.

16. Approvals. CRRA shall use best efforts to submit to the Commissioner all documents

required by this Trading Agreement and Order in a complete and approvable form. If the

Commissioner notifies CRRA that any document or other action is deficient, and does

not approve it with conditions or modifications, it is deemed disapproved, and CRRA

shall correct the deficiencies and resubmit it within the time specified by the

Commissioner or, if no time is specified by the Commissioner, within 30 days of the

Commissioner's notice of deficiencies. In approving any document or other action under

this Trading Agreement and Order, the Commissioner may approve the document or

other action as submitted or performed or with such conditions or modifications as the

Commissioner deems necessary to carry out the purposes of this Trading Agreement and

Order. Nothing in this paragraph shall excuse noncompliance or delay,

17. 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.

,

,

18. 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

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 perfonned

by the next day whi:h is not a Saturday, Sunday or Connecticut or federal holiday.
19. Certification of documents. Any document, including but not limited [0 any notice, which

is required to be submitted to the Commissioner under this Trading Agreement and Order

shall be signed by CRRA or, if CRRA is not an individual, by Respondent's chief

executive officer or a duly authorized representative of such officer, as those terms are

defined in §22a-430-3(b)(2) of the Regulations of Connecticut State Agencies, and by the

individual(s) responsible for actually preparing such document, and CRRA or CRRA

chief executive officer and each such individual shall certify in writing as follows:

The Connecticut Resources

Recovery Authority

8 Trading Agreement and

Order No. 8116B o

"1 have personally examined and am familiar with the information submitted in this

document and all attachments thereto, and 1certify, based on reasonable

investigation, including my inquiry of those individuals responsible for obtaining the

information, that the submitted information is true, accurate and complete to the best

of my knowledge and belief. 1understand that any false statement made in the

submitted information is punishable as a criminal offense under §53a-157b of the

Connecticut General Statutes and any other applicable law."

20. Noncompliance. This Trading Agreement and Order is a final order of the Commissioner

with respect to the matters addressed herein, and is nonappealable and immediately

enforceable. Failure to comply with this Trading Agreement and Order may subject

.CRRA to an injunction and penalties.

21.

22.

23.

24.

False statements. Any false statement in any information submitted pursuant to this

Trading Agreement and Order is punishable as a criminal offense under §53a-157b of the

Connecticut General Statutes and any other applicable law.

Notice of transfer; liability of CRRA. Until CRRA has fully complied with this Trading

Agreement and Order, CRRA shall notify the Commissioner in wtiting no later than 15

days after transferring all or any portion of the facility, the operations, the site or the

business which is the subject of this Trading Agreement and Order or after obtaining a

new mailing or location address. CRRA's obligations under this Trading Agreement and

Order shall not be affected by the passage of title to any propeny to any other person or

municipality.

Commissioner's powers. Nothing in this Trading Agreement and Order shall affect the

Commissioner's authority to institute any proceeding or take any other action to prevent

or abate violations of law, prevent or abate pollution, recover costs and natural resource

damages, and to impose penalties for past. present, or future violations of law. If at any

time the Commissioner determines that the actions taken by CRRA pursuant to this

Trading Agreement and Order have not successfully corrected all violations, fully

characterized the extent or degree of any pollution, or successfully abated or prevented

pollution, the Commissioner may institute any proceeding to require CRRA to undertake

further investigation or further action to prevent or abate violations or pollution.

CRRA's obligations under law. Nothing in this Trading Agreement and Order shall

relieve CRRA of other obligations under applicable federal, state and local law.

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25. No assurance bv Commissioner. No provision of this Trading Agreemen( and Order and

no action or inaction by the Commissioner shall be construed [0 constitute an assurance
The Connecticut Resources

/':'"":,. Recovery Authority r':

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9 Trading Agreement and

Order No. 8116B

by the Commissioner that the actions taken by CRRA pursuant (0 this Trading

Agreement and Order will result in compliance or prevent or abate pollution.

26. Access to facility. Any representative of the Department of Environmental Protection

may enter the facility without prior notice for the purposes of monitoring and enforcing

the actions required or allowed by this Trading Agreement and Order.

27. No effect on rights of other persons. This Trading Agreement and Order neither creates

nor affects any rights of persons or municipalities that are not parties to this Trading

Agreement and Order.

28. No Creation of Property Rights. This Trading Agreement and Order does not create any

property rights with respect to those DERCs.

29. Notice to Commissioner of changes. Within 15 days of the date CRRA becomes aware

of a change in any information submitted to the Commissioner under this Trading

Agreement and Order, or that any such information was inaccurate or misleading or that

any relevant information was omitted, CRRA shall submit the correct or omitted

information to the Commissioner.

(' 30. Notification of noncompliance. In the event that CRRA becomes aware that it did not or

may not comply, or did not or may not comply on time, with any requirement of this

Trading Agreement and Order or of any document required hereunder, CRRA shall

immediately notify by telephone the Unit identified in the next paragraph and shall take

all reasonable steps to ensure that any noncompliance or delay is avoided or, if

unavoidable, is minimized to the greatest extent possible. Within five (5) days of the

initial notice, CRRA shall submit in writing the date, time, and duration of the

noncompliance and the reasons for the noncompliance or delay and propose, for the

review and written approval of the Commissioner, dates by which compliance will be

achieved, and CRRA shall comply with any dates which may be approved in writing by

the Commissioner. Notification by CRRA 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 Commissioner in writing.

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31. Submission of documents. Any docwnent 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 by the Commissioner, be directed to:

Emissions Trading Unit

Compliance and Field Operations Division

5th Floor

Bureau of Air Management

Department of Environmental Protection

79 Elm Street

Hartford, Connecticut

06106
CRRA consents to the issuance of this Trading Agreement and Order without further notice. The

undersigned certifies that he/she is fully authorized to enter into this Trading Agreement and Order

and to legally bind CRRA to the tenns and conditions of the Trading Agreement and Order.

The Connecticut Resources

Recovery Authority

Signature: .

Type Name:

10

Floyd M Gent

Trading Agreement and

Order No. 8116B A

V

Type Title:

Date:

Director of Operations

Issued as a final Order of the Commissioner of Environmental Protection.

Date

MAll.ED CERIIFIED MAIL,

RETURN RECEIPT REQUES1ED

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