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 ofConnecticut and 

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Whereas, the Commissioner ofEnvironmental 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 ofConnecticut and that the use ofemissions 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 OrderNo. 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 aplastics 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 ofthree (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 ofthe 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:

'.J**(Pri~ted** on Recycled Paper) 79 Elm StrecI • Hartford. CT 06106

- SI27 htIp:lIdep.slale.ct.us II" Equal Oppr.>rr",,,iry Ernplo,urCYTEC Industries, Inc. 2 Trading Agreement and OrderNo. 8114 A



### ...J' 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 

# I 2103/00 2/03/05 R·I08 Nat. Gas 80 0.07 0.093 0.20 Boiler 3 

# I No.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 Boiler4 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 burningNo.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) ofthe Regulations CYTEC intends to comply with Section 22a-174-22(e) ofthe Regulations, through the use ofemissions averaging and emission reduction trading ofapproved DERCs at the facility Wltil April 30, 2007 in accordance with this Trading Agreement and Order.
7. The use ofemission**ave~ging** is a form ofemission 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 ofSection 22a-174-22 ofthe 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 orthey were purchasedby CYTEC. DERC creation serial numbers assigned by the Department to these previously approved DERCs are provided in Table 2 ofthis Trading Agreement and Order. Unused DERCs are subject to the vintage restrictions ofthis Trading Agreement and Order. Dates afterwhich the unused DERCs will no longerbe eligible for use as aresult 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 ofthis 

### Trading Agreement and Order, pursuant to Section 22a-174-22(j) ofthe 

### Regulations, hereby allows CYTEC to complywith



### . Section 22a-174-22 oftlie Regulations through use ofacombination ofemissions averaging 

# , and DERC trading at thefacilityas providedherein. 

### C. With the agreement 

### ofCYTEC. the Commissioner, acting underthe Connecticut General Starutes Section 22a-6, 22a-171, 22a-174, 22a-I76, and 22a-I77, orders CYTEC as follows:
I. Upon issuance ofthis Trading Agreement and Order, at the facility, CYTEC shall 

### comply with 

### Section22a-174-22 ofthe Regulations through emission reduction trading until CYTEC achieves permanent compliance with the emissions standard 

### in Section 22a-174-22(e) ofthe Regulation orby April 30, 2007 whichever is earlier:



### a CYTEC shall useapproved DERCs as required underthis TradingAgreement and Order, b. CYTEC shall havein its possession sufficient approved DERCs to meet applicable NOx emissionlimits as allowed underthis TradingAgreement and Order; and

c. CYTEC shall comply during the operation ofthe boilers with 

### the FLERs shown in Table I ofthis Trading Agreement and Order. 2. Averaging and DERC trading: Until April 30, 2007, before the first day ofeach month 

### CYTEC shall have in its possession sufficient approved DERCs for such month for fuel-burning equipment specified in Table 1based on the following calculation: No laterthan the last day ofthe 

### following month, calculateDERCs used 

### in the preceding calendarmonth

# as follows:

I. 

### TotalMonthlvAveraeing Credits (HMA.CS") available from those units that are below the allowable emissions limits (fuels otherthan No.6 oil) in the Averaging Set (as defined in Table I). The Total MACs shall be the sum of 

### the MACs during thatmonth 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 1ofthis 

### 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 MonthlvAveralring Debits ("MADs") generated from the sludge incinerator and boilers 1 and 3 units when burningNo.6 oil with emission rates 

### in excess ofallowable 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)

- DebitFLER in Ibs/MMBru)] .;- 2000 Ibs/ton.

Ill.

IV. 

### NetMADs for each calendarmonth as follows:
Net MADs = the swn ofthe Total MADs (negative nwnber) plus the Total MACs (positive number). No approved DERCs will be required for emissions 

### in anymonth during which there are more MACs than 

### .M..:\D5. Net MACs may not be carried forward to the next month. For each month with anegative Net MADs, the amount ofDERCs required for such month shall equal the Net MADs. The total amount ofapproved 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. Forthe sludge incinerator, hot oil furnace and spray dryer heat inputs, CYTEC shall multiplythe rated capacity in :MMBtulbourby the hours ofoperation. For boilers 1,3, and 4, CYTEC shall calculate the total monthly heat inputby allocating the overall fuel use bythe individual steam production from each boiler. b. To prevent exceeding the lower ofhistorical 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 peryear, based on the 1990historic level. -.J
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 222-174-22CYTEC Industries, Inc. 5 Trading Agreement and Order No. 8114 A**~.}.** 

# '- ofthe 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. Forpurposes ofcalculating total emissions, only emissions from sources in the averaging set shall be included; emissions used shall be for a calendar year, based

.on mostrecent .official emissions testresults, 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 maybe exceeding a FLER limit shown in Table 1 above, CYTEC shall conduct NOx emissions testing 

### afme corresponding source on orbefore sixty (60) days after the potential exceedance ofthe above limits in accordance with the following;
1. CYTEC shall submit to the Commissionerfor his review and wrinen approval an Intent-To-Test ("IT!") protocol not less than thirty (30) days pnor to the emissions testino requiredpursuant to paragraph C.4 ofthis Trading Agreement and 

### OTter. The ITT protocol shall include at least: 

### ii. The Department's Bureau of

### AirManagement Test Form No.1, "Intent to Test", 

### iii. System operatingparameters indicative ofthe highest**opera~g** rate since the last previous stacktest or the most recent Department WItnessed emission test which everis more recent, including, but not limited to: steam outputrate,**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 ofthe Regulations, including operating the applicable sources at not less than ninetypercent (90%) ofIts maxunwn rated capacity limit orhighest 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 Commissionerto be present during such testing and to independently verify facility operanons, airpollution control equipmentparameters, and testing procedures. vii. Within 30 days after**cornpletin~** any emissions testing required 

### by this TradingAgreement and Order, \..YTEC shall submit to the CommIssioner a wrinen repon providing the results ofsuch testing; within 15 days ofa notice from the Commissionerindicating any defiCIencies in such report, CYTEC shall submit arevised repon. 

### 5 CYTEC shall make and keep records of: hours ofoperation for the sludge incinerator, hot oil furnace, and spray dryer; heat input for boilers 1,3, and 4; andCYTEC lndustries, Inc. 6 

### Trading Agreement and Order No. 8114 A

'. NOx emissions for each unit in the averaging set on a monthly basis in accordance with paragraph C.2., and will maintain records ofthe 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 

### ifassigned) 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 awritten request from the Commissioner. 7. Annual Emission Statement. No laterthanMarch 1, ofevery year afterissuance ofthis Trading Agreement and Order, CYTEC shall include with the Annual Emission Statement provided to the Commissioner, a record ofeach sale orother transfer, and use ofany and all ofthe DERCs approved within and subsequent to issuance ofthis Trading Agreement and Orderuntil all such DERCs have been used. CYTEC shall also include NOx emissions from each boilerusing or generating DERCs, and the amount ofall DERCs used including serial number 

### (if assigned) and approved DERCs generated and/orpurchased from other facilities), generated andlor approved for the previous calendaryear. These reports shall be on a form prescribedby the Commissioner and shall be in monthly increments. Should CYTEC choose to discontinue the generation ofDERCs, CYTEC will notify the Commissionerupon discontinuance. 8. Allowance Use. Pursuant to Section 22a·174-22(d)(3) ofthe Regulations, CYTEC mayuse NOx allowances, througb April 30, 2007, pursuant to Section 22a-174-22 

### (j) ofthe Regulations to achieve all or aportion ofthe reductions required by Section 22a-174-22 ofthe Regulations. Any allowance used for compliance with Section 22a-174-22(e) ofthe Regulations shall be subject to all resnictions and/orrequirements applicable to DERCs contained in this Trading Agreement and Order;

a. 

### In order for 

### C¥TECto use NOx allowances, CYTEC shall create ageneral 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 ofthe Regulations shall be equivalent to one discrete emission reduction credit. Allowances shall be considered used for compliance with Section 22a-174-22 ofthe 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 ofeach month for use. 

### However, based on the gravity ofnoncompliance, the Conunissionermay require additional upward adjustment. -10. Vintage Restriction.' Forthe pwposes ofcompliance with Section**22a~** 174-22 ofthe Regulations, DER'Cs/allowances shall 

### only remain valid for five (5) calendaryears from 

### the yearofthe 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 ofthe Regulations. Not'N'ithstanding the above, DERCslallowances generated/allocatedprior to calendaryear 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 ofemissions ("true up'') caused by the exceedance plus a 100% premiwn. The true up in tons ofDERCs shall be equal to the FLER exceedance in IbsIMMBtu, multiplied bythe total heat input during the period of noncompliance divided by 2000 lbs/ton. Ifthe period ofnoncompliance is not known, the time period from the completion ofthe 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 ofany alleged noncompliance or violation ofIaw. 12. FLER Modification. FLERs set forth 

### in Tables 1 ofthis Trading Agreement and Order may be modified only aft"er the consent ofthe Commissionerbywritten 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 TradingAgreement 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) ofthe Regulations. However, after full program review ofthis and otherTrading Agreements and Orders and ifdetemrined to be appropriate, the Commissionermay grant written extension ofthis Trading Agreement and Order. 15. Future Compliance Report. On orbefore September I, 2006, CYTEC shall submit a report indicating how the facility will comply with Section 22a-174-22 ofthe Regulations after April 30, 2007. 16. Full compliance. CYIEC shall not be considered in full compliance with this Trading Agreement and Orderuntil 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 Commissionernotifies CYTEC that any document orother action is deficient, and does not approve 

### it with conditions ormodifications, 

### it is deemed disapproved, and 

### CYTEC shall correct the deficiencies and resubmit 

### it within the time specified by 

### the Commissioneror, ifoo time is specified by 

### the Commissioner, within 30 days ofIhe Commissioner's notice ofdeficiencies. 

### In approving any document or other action under this Trading Agreement and Order, the Commissionermay approve the document or other action as sqbmined orperformed or

### with such conditions ormodifications as the CommissioneI: deems necessaryto carryoutthe 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 Commissioneror arepresentative 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 Orderis the date the Trading Agreement and Order is deposited in the U.S. mail orpersonally delivered, whicheveris earlier. 

### Approved DERCs are defined forpUlposes ofthis Trading Agreement and Order as those for which the Commissionerhas provided wrinen authorization for use in compliance with Section 22a-174-22 ofthe Regulations. 19. Dates. The date ofsubmission to the Commissioner ofanydocument required by this Trading Agreement and Order shall be the date such docwnent is received by the Commissioner. The date ofany notice by the Commissionerunder this Trading Agreement and Order, including butnot limited to notice ofapproval or disapproval of any document or other action, shall be the date such notice is deposited 

### in the U.S. mail oris personally delivered, whicheveris earlier. Except as**other~rise** specified 

### in this Trading Agreement and Order, the word "day" as used in this Trading Agreement and Ordermeans calendarday. Anydocument or action which is required bythis Trading Agreement and Orderto be submitted orperformed by a date which falls on a Sarurday, Sunday or a Connecticut·or federal holiday shall be submined orperformedby the next day which is not a Sarurday, Sunday or Connecticut orfederal holiday. 20. Certification ofdocuments. Any document, including but not limited to anynotice, which is required to be submitted to the Commissionerunder this Trading Agreement 

### and Order shall be signedby CYTEC or, ifCYTEC is not an individual, by CYTEC's chiefexecutive officer or a duly authorized representative ofsuch officer, as those terms 

### are defined in §22a-430-3(b)(2) ofthe Regulations ofConnecticut State Agencies, and by the individual(s) responsible for actuallypreparing such document, and CYTEC or CYTEC's chiefexecutive 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 inquiryofthose individuals responsible for obtaining the information, that the submined information is true, accurate and complete to the best ofmy knowledge and belief Iunderstand that any false statement made in the



### ........

j submitted information is punishable as a criminal offense under §53a-157b ofthe Connecticut General Statutes and any other applicable law." 21. Noncompliance. This Trading Agreement and Orderis a final order ofthe Commissioner with respect to the matters addressed herein, and is nonappealable andCYTEC 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 submittedpursuant to this Trading Agreement and Order is punishable as acriminal 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 Conunissionerin writing no later than 15 days-after transferring all or anyportion ofthe facility, the operations, the site orthe business which is the subject ofthis Trading Agreement and Orderor after obtaining a new mailing orlocation address. 

### CYTEe's obligations under this Trading Agreement and Order shall not be affected by the passage oftide to anypropeny to any otherperson or municipality. 24. Commissioner's powers. Nothing 

### in this Trading Agreement and Order shall affect the Commissioner's authority to institute anyproceeding ortake any other action to prevent or abate violations oflaw, prevent or abate pollution, recover costs and natural resource damages, and to impose penalties forpast, present, orfuture violations oflaw. Ifat any time the Commissionerdetermines that the actions taken by CYTEC pursuant to this Trading Agreement and Orderhave not successfully corrected all violations, fully characterized the extent or degree ofanypollution, or successfully abated orprevented pollution, the Commissionermay 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 ofother obligations under applicable federal, state and local law

. 26. No assurance bv Commissioner. No provision ofthis Trading Agreement and Order and no action orinaction·by the Commissioner shall be construed to constitute an assurance by the Commissionerthat the actions taken by CYTEC pursuant to this Trading Agreement and Order will result in compliance orprevent or abate pollution. 

### 27. Access to facility. Anyrepresentative oftheDepartment ofEnvironmental Protection may enter the facility withoutprior notice for the purposes ofmonitoring and enforcing the actions required or allowed by this Trading Agreement and Order. 

### 28. No effect on rights ofotherpersons. This Trading Agreement and Orderneither creates nor affects anyrights ofpersons ormunicipalities that are not panies to this Trading Agreement and Order. 

### 29. No Creation ofPropertv Ri2hts. This Trading Agreement and Order does not create any· propertyrights with respect to these DERCs. 30. Notice to Commissioner ofchanges. Within fifteen (15) days ofthe date CYTEC becomes aware ofa change in any information submined to the Commissionerunder this Trading Agreement and Order, or that any such infonnation was inaccurate or misleading orthat 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



## -. 31. Notification ofnoncomoliance. 

### 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 ofthis Trading Agreement and Order or ofany 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 anynoncompliance or delay is avoided or, 

### ifunavoidable, is minimized to the greatest extentpossible. 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, forthe review and written approval ofthe Commissioner, dates bywhich compliance 

### will be achieved, and CWEC shall comply 

### with any dates which may be approved 

### in writing 

### bythe Commissioner. Notification

### by CYTEC shall not excuse noncompliance or delay, and the Commissioner's approval ofany compliance dates proposed shall not excuse noncompliance or delay unless specifically so stated bythe Commissioner 

### in writing. 32. Submission ofdocuments. Any document required to be submitted to the Commissionerunder this Trading Agreement and Order shall, unless otherwise specified in this TradingAgreement and Orderor 

### in writing by the Commissioner, be directed to: Mr. Roland 

### L. Severance, Jr., P.E. 

### DepartmentofEnvironmentalProtection Bureau ofAirManagement Compliance and Field Operations Division Emissions and Credit Trading Section 79 Elm Street Hartford, Connecticut 06106'. CYTEC Industries, Inc. II 

### TradingAgreement and Order No. 8114 A



### CYTEC consents to the issuance ofthis Trading Agreement and Order without funher notice. The undersigned certifies that he/she is 

### fullyauthorized 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 afinal order ofthe 

### Commissioner ofEnvironmental 

### Protectio

on

__

# -,tf,..;/ 24 ,2003. 

# /

Arthur J. 

### Rocq 

# e Jr. 

### Commissioner 

# L-) (

CITY OF WALLlNGFORD LAND RECORDS
MAILED CERTIFIED 

### M.tUL, RETUR."1 RECEIPT REQUESTED

'

...,) Certified Document No.

G'\.T'RADING·RLS\-TRADINGORDERS'CvTEC\8II.::....CYTECorderFimal{3·j ().()j).doc