Trading Agreement

and Order No. 8114A

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STATE OF CONNECTICUT

DEPARTMENT OF ENVIRONME~PROTECTI~ft'

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CYTEC Industries, Inc.

The State of Connecticut and

In the maner of

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

Industries, Inc. C"CYTEC'l 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 emissions averaging

("averaging") and discrete emission reduction credit ("DERC") trading to reduce nitrogen oxide

C'NOx'l emissions will achieve this result in a timely and cost-effective manner:

A. At the request and with the agreement ofCYTEC, the Commissioner finds the following:

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1. This Trading Agreement and Order supercedes Trading Agreement and Order No. 8114

issued on December 20, 1996, Trading Agreement and Order No. 8114 Modification

issued on April 29, 1999, and Trading Agreement and Order No. 8114 Modification No,

2 issued on May 26,2001.

2. CYTEC is a corporation that owns and operates a plastics and resin research and

manufacturing facility at 425 South Cherry Street in Wallingford, Connecticut

("facility").

3. At the facility, CYTEC operates fue1~burning equipment that consists of three (3) boilers

1,3, and 4, one (1) hot oil furnace, one spray dryer, and one (1) multi-hearth sludge

incinerator ("units") which are subject to Section 22a-174-22 of the Regulations of

Connecticut State Agencies (''Regulations'').

4. Official U.S. Environmental Protection Agency ("EPA") Method 7 stack tests perfonned

January 31 through February 9,2000, resulted in NOx emissions rates as follows:

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CYTEC Industries, Inc. 2 Trading Agreement

and Order No. 8114 A

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Table 1

CYTEC - NOr Emissions r:l.le. FLERs and A1low:able Rates in Lbs/MlVffitu

Unil Fuel Heal Input Emission FLER NOx Stack Next

Reg. '# R- MMBruI!ll Test Credit or Allowable Test Dale Tesl Due

Pennit :; p. 212000 debit Limits

Boiler I No.6 oil 80 0.28 0.390 0.25 I2103/00 2/03/05

R·I08 Nat. Gas 80 0.07 0.093 0.20

Boiler 3 INo.6 oil 89 0.26 0.30 0.25 2104/00 2/04/05

R·IIO Nat. Gas 89 0.20 N/A 0.20

Boiler 4 No.2 oil 21 0.082 0.101 0.20 1/31/00 IIll/05

R·I09 Nat. Gas ' 21 0.102 0.11 0.20

Sludge Sludge and II 0.29 0.52 0.33 2109/00 2109/05

Incineralor No.2 oil

P·IO

Hot Oil No.2 oil II 0.12 0.155 0.20 2/09/00 2109/05

Furnace Nat. Gas II 0.10 0.11 0.20

P·9

Spray No.2 oil 10 0.14 0.173 0.254 2109/00 2109/05

Dryer I Nat. G",

(122.6 ppm) (180 ppm)

R·173 10 0.12 0.132 0.186

(128oom) (180oom)

5. When burning No.6 fuel oil in boilers I and 3, CYTEC exceeds the NOx allowable

emissions rate limits specified in Section 22a-174-22 (e) oIthe Regulations.

6. Pursuant to Section 22a·174-220) of the Regulations CYTEC intends to comply with

Section 22a-174-22(e) ofthe Regulations, through the use of emissions averaging and

emission reduction trading of approved DERCs at the facility Wltil April 30, 2007 in

accordance with this Trading Agreement and Order.

7. The use of emission ave~ging is a form of emission trading as defined in the EPA

Economic Incentive Plan rules, 40 C.F.R. Section 51.493 et seq.

8. CYTEC will comply with the requirements of Section 22a-174-22 of the Regulations by

using diSCOWltS, full load emission rates ("FLERs"), a facility emission limitation cap

"cap" and design margin specified in this Trading Agreement and Order.

9. The Commissioner, in accordance with the provisions ofTrading Agreement and Order

No. 8114A, pursuant to Section 22a-174-22 ofthe Regulations, approved the NOx

DERCs referenced in Table 2 ofthis Trading Agreement and Order or they were

purchased by CYTEC. DERC creation serial numbers assigned by the Department to

these previously approved DERCs are provided in Table 2 of this Trading Agreement

and Order. Unused DERCs are subject to the vintage restrictions of this Trading

Agreement and Order. Dates after which the unused DERCs will no longer be eligible

for use as a result ofthe vintage restrictions are provided in Table 2 ofthis Trading

Agreement and Order in the expiration date column.
CYTEC lndustries, Inc. 3 Trading Agreement

and Order No. 8114 A

Table 2

CYTEC - Purchased ADoroved DERCs

Year Ozone season Tons NOD-ozone season Tons Expiration Date

Pre·1999 SIN nOI assigned 22 12/31/04

200] United Illuminatin2 '0 12131/05

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

pursuant to Section 22a-174-22(j) of the Regulations, hereby allows CYTEC to comply with

. Section 22a-174-22 oftlie Regulations through use of a combination of emissions averaging , and DERC trading at the facility as provided herein.

C. With the agreement ofCYTEC. the Commissioner, acting under the Connecticut General

Starutes Section 22a-6, 22a-171, 22a-174, 22a-I 76, and 22a-I77, orders CYTEC as follows:

I. Upon issuance of this Trading Agreement and Order, at the facility, CYTEC shall

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

until CYTEC achieves permanent compliance with the emissions standard in Section

22a-174-22(e) of the Regulation or by April 30, 2007 whichever is earlier:

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

Order,

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

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

c. CYTEC shall comply during the operation ofthe boilers with the FLERs shown in

Table I of this Trading Agreement and Order.

2. Averaging and DERC trading: Until April 30, 2007, before the first day of each month

CYTEC shall have in its possession sufficient approved DERCs for such month for

fuel-burning equipment specified in Table 1 based on the following calculation:

No later than the last day ofthe following month, calculate DERCs used in the preceding

calendar month as follows:

I. Total Monthlv Averaeing Credits (HMA.CS") available from those units that

are below the allowable emissions limits (fuels other than No.6 oil) in the

Averaging Set (as defined in Table I). The Total MACs shall be the sum of

the MACs during that month calculated for each unit in the Averaging Set as

follows:

MACs (tons) = [heat input in MMBtu x «(0.80 x Allowable limits in

IbslMMBtu) - Credit FLER in IbsIMMBru)] + 2000

Ibslton.

Where:

• Allowable limit = allowable limit rate in IbsfMJvrntu shown in

Table 1 of this Trading Agreement and Order.
CYTEC lndustries, Inc. 4 Trading Agreement

and Order No. 8114 A

• Full load emission rate credit or debit (FLER) = for the

appropriate equipment as shown in Table 1 ofthis Trading

Agreement and Order.

• Discount (0.80) = includes 20% discount on allowable limits for

averaging credits above, (and a 10% discount and a 5% design

margin on debits below).

• I Fuel heating value = as appropriate for the fuel used.

,

11. Total Monthlv Averalring Debits ("MADs") generated from the sludge

incinerator and boilers 1 and 3 units when burning No.6 oil with emission

rates in excess of allowable limits in the Averaging Set. The Total MADs

shall be the sum ofthe MADs during that month calculated for each unit in

the Averaging Set as follows:

MADs (tons) [heat input in MMBru x «0.85 x allowable limit in

Ibs/MMBru) - Debit FLER in Ibs/MMBru)] .;- 2000

Ibs/ton.

Ill.

IV.

Net MADs for each calendar month as follows:

Net MADs = the swn of the Total MADs (negative nwnber) plus the Total

MACs (positive number). No approved DERCs will be required for

emissions in any month during which there are more MACs than .M..:\D5. Net

MACs may not be carried forward to the next month.

For each month with a negative Net MADs, the amount ofDERCs required

for such month shall equal the Net MADs. The total amount of approved

DERCs used and permanently retired each month shall be equal to the sum of

the DERCs required for each month.

3. Unit Restrictions and Annual Emissions Cap.

a. For the sludge incinerator, hot oil furnace and spray dryer heat inputs, CYTEC

shall multiply the rated capacity in :MMBtulbour by the hours of operation. For

boilers 1,3, and 4, CYTEC shall calculate the total monthly heat input by

allocating the overall fuel use by the individual steam production from each boiler.

b. To prevent exceeding the lower of historical actual or allowable emission limits

("historic levels") actual emissions shall not exceed historic levels as shown below:

CYTEC's Averaging Set NOx emissions shall not exceed 54 tons per year,

based on the 1990 historic level.

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c. Approved DERCs may be used to offset emissions above the historic level;

however, said DERCs shall be separated from DERCs and/or averaging credits

used for meeting emission rate limits specified in Table 22-1, Section 222-174-22
CYTEC Industries, Inc. 5 Trading Agreement

and Order No. 8114 A

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of the Regulations. The quantity ofDERCs required to offset excess monthly

emissions above the historic level shall equal the difference between the total

emissions (in tons) and the historic level (in tons), plus a 100% premium equal to

the difference in DERCs for exceeding the cap.

d. For purposes of calculating total emissions, only emissions from sources in the

averaging set shall be included; emissions used shall be for a calendar year, based

.on most recent .official emissions test results, beginning in calendar year 1996.

Approved DERCs shall be in CYTEC's possession before the historic level is

exceeded.

4. Upon issuance ofthis Trading Agreement and Order, ifCYTEC has reason to believe it

may be exceeding a FLER limit shown in Table 1 above, CYTEC shall conduct NOx

emissions testing afme corresponding source on or before sixty (60) days after the

potential exceedance of the above limits in accordance with the following;

1. CYTEC shall submit to the Commissioner for his review and wrinen

approval an Intent-To-Test ("IT!") protocol not less than thirty (30) days

pnor to the emissions testino required pursuant to paragraph C.4 of this

Trading Agreement and OTter. The ITT protocol shall include at least:

ii. The Department's Bureau ofAir Management Test Form No.1, "Intent to

Test",

iii. System operating parameters indicative ofthe highest opera~g rate since

the last previous stack test or the most recent Department WItnessed

emission test which ever is more recent, including, but not limited to:

steam output rate, teTI~erarure and pressure, fuel firing rate, and. Ox

emissions rate. The protocol shallITovide that CYTEe shall perform

testing as specified in Sections 22a-17 -5 and 22a-174-22 of the

Regulations, including operating the applicable sources at not less than

ninety percent (90%) ofIts maxunwn rated capacity limit or highest

operating rate smce Its last/previous emissions test, whichever IS higher.

iv. CYTEC shall perform all testing required by this Trading Agreement and

Order in accordance with the approved ITT protocol.

v. In conducting and performing the testing required by this Trading

Agreement and Order, and analyzing the results ofsuch testino , CYTEC

shall adhere to methods specified in Sections 22a-174-5 and 2~a-174-22 of

the Resulations and as ap~roved by the United States Environmental

Protectlon Agency ("EPA ') and the Commissioner.

vi. CYTEe shall schedule all emissions testing so as to allow the

Commissioner to be present during such testing and to independently

verify facility operanons, air pollution control equipment parameters, and

testing procedures.

vii. Within 30 days after cornpletin~ any emissions testing required by this

Trading Agreement and Order, \..YTEC shall submit to the CommIssioner

a wrinen repon providing the results ofsuch testing; within 15 days of a

notice from the Commissioner indicating any defiCIencies in such report,

CYTEC shall submit a revised repon.

5 CYTEC shall make and keep records of: hours of operation for the sludge

incinerator, hot oil furnace, and spray dryer; heat input for boilers 1,3, and 4; and
CYTEC lndustries, Inc. 6 Trading Agreement

and Order No. 8114 A

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NOx emissions for each unit in the averaging set on a monthly basis in

accordance with paragraph C.2., and will maintain records of the averaging

credits and debits generated for emission averaging purposes on a monthly basis

including fuel type; excess NOx emissions; the number ofDERCs in its

possession, created, purchased and used (by serial number if assigned) each

month in accordance with the appropriate emission rates and limits in this

Trading Agreement and Order; the number ofDERCs used during the ozone

season and non-ozope season (the remainder ofthe year); as well as

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

season were generated during the ozone season..Generator certification ofthis

fact shall be sufficient. CYTEe shall maintain and submit such records to the

Commissioner in accordance with Section 22a-174-22 ofthe Regulations.

6. Record Keeping. CYTEC shall retain records and supporting documentation as

described in this Trading Agreement and Order for a minimum offive (5) years,

commencing on the date such records were created. CYTEC shall provide the

records specified above to the Commissioner within thirty (30) days ofreceipt of

a written request from the Commissioner.

7. Annual Emission Statement. No later than March 1, of every year after issuance

ofthis Trading Agreement and Order, CYTEC shall include with the Annual

Emission Statement provided to the Commissioner, a record of each sale or other

transfer, and use of any and all ofthe DERCs approved within and subsequent to

issuance ofthis Trading Agreement and Order until all such DERCs have been

used. CYTEC shall also include NOx emissions from each boiler using or

generating DERCs, and the amount of all DERCs used including serial number (if

assigned) and approved DERCs generated and/or purchased from other facilities),

generated andlor approved for the previous calendar year. These reports shall be

on a form prescribed by the Commissioner and shall be in monthly increments.

Should CYTEC choose to discontinue the generation ofDERCs, CYTEC will

notify the Commissioner upon discontinuance.

8. Allowance Use. Pursuant to Section 22a·174-22(d)(3) ofthe Regulations,

CYTEC may use NOx allowances, througb April 30, 2007, pursuant to Section

22a-174-22 (j) of the Regulations to achieve all or a portion ofthe reductions

required by Section 22a-174-22 of the Regulations. Any allowance used for

compliance with Section 22a-174-22(e) ofthe Regulations shall be subject to all

resnictions and/or requirements applicable to DERCs contained in this Trading

Agreement and Order;

a. In order for C¥TEC to use NOx allowances, CYTEC shall create a general

account in EPA's NOx Allowance Tracking System (''NATS''); and

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

Regulations shall be equivalent to one discrete emission reduction credit.

Allowances shall be considered used for compliance with Section 22a-174-22

of the Regulations when they are transferred from the facility's NOx general
CYTEC Industries, Inc. 7 Trading Agreement

and Order No. 8114 A

account in the NAIS to the CT State NOx Retirement Account (Account ill

CT0000000300 in the NATS).

9. DERC Doubling. At a minimum, DERCs required shall be adjusted upwards by 100%

ifDERCs are not in CYTEC's possession prior to the first day of each month for use.

However, based on the gravity of noncompliance, the Conunissioner may require

additional upward adjustment.

-10. Vintage Restriction.' For the pwposes of compliance with Section 22a~ 174-22 ofthe

Regulations, DER'Cs/allowances shall only remain valid for five (5) calendar years from

the year ofthe generation/allocation ofsuch DERCs/allowances. DERCs/allowances

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. Not'N'ithstanding the above,

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

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

31,2004.

11. FLER Exceedance. Noncompliance with an established FLER shall subject CYTEC to

make restitution by matching the quantity of emissions ("true up'') caused by the

exceedance plus a 100% premiwn. The true up in tons of DERCs shall be equal to the

FLER exceedance in IbsIMMBtu, multiplied by the total heat input during the period of

noncompliance divided by 2000 lbs/ton. Ifthe period of noncompliance is not known,

the time period from the completion of the last/previous Department witnessed emission

test through the date the FLER compliance is achieved as approved by the

Conurussioner shall be used. However, nothing in this Trading Agreement and Order

shall affect the Conunissioner's authority to institute any proceeding or take any other

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

noncompliance or violation ofIaw.

12. FLER Modification. FLERs set forth in Tables 1 of this Trading Agreement and Order

may be modified only aft"er the consent ofthe Commissioner by written modification of

this Trading Agreement and Order.

13. Emissions Testing. Pursuant to Section 22a-174-22(k) ofthe Regulations, CYTEC

shall conduct NOx emission tests ofthe units at least once every five years commencing

from the dates ofthe NOx emission tests for the boilers as provided in Table 1 afthis

Trading Agreement and Order.

14. Extension. No later than April 30, 2007 for the boilers, CYTEC shall comply with the

requirements in Section 22a-174-22 (d) (1) of the Regulations. However, after full

program review of this and other Trading Agreements and Orders and if detemrined to

be appropriate, the Commissioner may grant written extension of this Trading

Agreement and Order.

15. Future Compliance Report. On or before September I, 2006, CYTEC shall submit a

report indicating how the facility will comply with Section 22a-174-22 of the

Regulations after April 30, 2007.

16. Full compliance. CYIEC 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.
CYTEC Industries, Inc. 8 Trading Agreement

and Order No. 8114 A

17. Approvals. CYTEC shall use best efforts to submit to the Commissioner all documents

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

the Commissioner notifies CYTEC that any document or other action is deficient, and

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

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

Commissioner or, ifoo time is specified by the Commissioner, within 30 days ofIhe

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 sqbmined or performed or with such conditions or modifications as

the CommissioneI: deems necessary to carry out the purposes ofthis Trading Agreement

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

18. Definitions. As used in this Trading Agreement and Order, "Commissioner" means the

Commissioner or a representative ofthe Commissioner. "Ozone season" means the

period from May 1 through September 30 in any given calendar year. The date of

"issuance" ofthis 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.

Approved DERCs are defined for pUlposes of this Trading Agreement and Order as

those for which the Commissioner has provided wrinen authorization for use in

compliance with Section 22a-174-22 ofthe Regulations.

19. Dates. The date ofsubmission to the Commissioner of any document required by this

Trading Agreement and Order shall be the date such docwnent 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 other~rise 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 Sarurday,

Sunday or a Connecticut· or federal holiday shall be submined or performed by the next

day which is not a Sarurday, Sunday or Connecticut or federal holiday.

20. Certification of documents. Any document, including but not limited to any notice,

which is required to be submitted to the Commissioner under this Trading Agreement

and Order shall be signed by CYTEC or, ifCYTEC is not an individual, by CYTEC's

chief executive officer or a duly authorized representative ofsuch 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 CYTEC or

CYTEC's chief executive officer and each such individual shall cenify in writing as

follows:

"I have personally examined and am familiar with the infonnation submitted in this

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

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

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

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

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

Connecticut General Statutes and any other applicable law."

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

Commissioner with respect to the matters addressed herein, and is nonappealable and
CYTEC Industries, Inc. 9 Trading Agreement

and Order 0.8114 A

immediately enforceable. Failure to comply with this Trading Agreement and Order

may subject CYTEC to an injunction and penalties.

22. False statements. Any false statement in any infonnation 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.

23. Notice oftransfer; liability ofCYTEe. Until C¥TEC has fully complied with this

Trading Agreement ~d Order, CYTEC shall notify the Conunissioner in writing 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 ofthis Trading Agreement and Order or after

obtaining a new mailing or location address. CYTEe's obligations under this Trading

Agreement and Order shall not be affected by the passage of tide to any propeny to any

other person or municipality.

24. 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 oflaw, prevent or abate pollution, recover costs and natural resource

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

time the Commissioner determines that the actions taken by CYTEC 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 CYTEC to

undertake further investigation or further action to prevent or abate violations or

pollution.

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

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

26. No assurance bv 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 Commissioner that the actions taken by CYTEC pursuant to this

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

27. Access to facility. Any representative ofthe Department ofEnvironmental Protection

may enter the facility without prior notice for the purposes ofmonitoring and enforcing

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

28. 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 panies to this Trading

Agreement and Order.

29. No Creation ofPropertv Ri2hts. This Trading Agreement and Order does not create any·

property rights with respect to these DERCs.

30. Notice to Commissioner of changes. Within fifteen (15) days of the date CYTEC

becomes aware of a change in any information submined to the Commissioner under

this Trading Agreement and Order, or that any such infonnation was inaccurate or

misleading or that any relevant information was omitted, CYTEC shall submit the

correct or omitted information to the Commissioner.
CYTEC Industries, Inc. 10 Trading Agreement

and Order No. 8114 A

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31. Notification of noncomoliance. In the event that CYTEe 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, CYTEe shall

immediately notify by telephone the individual 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 ofthe

initial notice, CYTEC shall submit in writing the date, time, and duration afthe

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

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

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

by the Commissioner. Notification by CYTEC 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.

32. Submission of documents. 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 by the Commissioner, be

directed to:

Mr. Roland L. Severance, Jr., P.E.

Department of Environmental Protection

Bureau ofAir Management

Compliance and Field Operations Division

Emissions and Credit Trading Section

79 Elm Street

Hartford, Connecticut 06106
'. CYTEC Industries, Inc. II Trading Agreement

and Order No. 8114 A

CYTEC consents to the issuance of this Trading Agreement and Order without funher notice. The

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

and to legally bind CYTEC to the terms and conditions ofthe Trading Agreement and Order.

CYTEC ~tries, Inc.

Signature: _--,/r.J,=t",6.",M="I.",v"-..£.M=",{fu=-,~,,- _

Type Name: -'W"i"l"l"'i=am"""S"h"a"n"'n"o"n _

Type Title: Operation Technology Manager C&?C

Date: ---:/~/_4e'.L...:.:.,=,-_.2_0_0-,3:...:.. _

JS5ued as a final order of the Commissioner ofEnvironmental Protectio

on __-,tf,..;/ 24 ,2003. /

Arthur J. Rocq e Jr.

Commissioner

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CITY OF WALLlNGFORD LAND RECORDS

MAILED CERTIFIED M.tUL,

RETUR."1 RECEIPT REQUESTED

'...,) Certified Document No.

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