# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

In the matter of The State ofConnecticut and Cytec Industries, Inc. ) ) ) ) ) Trading Agreement and OrderNo. 8114A Modification I

Whereas, the Commissioner ofEnvironmental Protection ("Commissioner") and Cytec Industries, Inc ("Cytec") having agreed to the terms and conditions set forth in Trading Agreement and Order 8l14A issu"ed on April 24, 2003, do now, by mutual agreement, modify said Trading Agreement and Order as follows: 1. Delete the date April 30, 2007, and substitute therefor the date May 1,2009, in paragraphs A.6., e.l., C.2., e.S., and e.I5. 2. Delete paragraph A.3. and substitute the following therefor: At the facility, Cytec operates equipment that consists ofboilers 1 and 3, one hot oil furnace, and one spray dryer, ("units") which are subject to Section 22a-I74-22 of the Regulations ofConnecticut State Agencies ("Regulations"). 3. Delete paragraph A.4. and substitute the following therefor: Official U.S. Environmental Protection Agency ("EPA") Method 7 stack tests performed on the dates specified in Table 1, resulted in NOx emissions rates as follows:
Table 1 Cytec

- NOx Test rates, FLERs and Allowable Rates in LbslMMBtu Unit Fuel Heat Input Emission FLER Allowable Stack Next Registration (R) or MMBtuJhr Test Rate (credit or Limits Test Test

Permit (P) No. debit) Date Due Boiler 1 No.6 oil 80 0.39 0.39 0.25 2/2/05 2/2/10 R-I08 Nat. Gas 80 0.07 0.09 0.20 1131105 1/31110 Boiler 3 No.6 oil 89 0.29 0.30 0.25 11/29106 11129/11 R-110 Nat. Gas 89 0.17 N/A 0.20 1131105 1131/10 Hot Oil Furnace No.2 oil 11 0.08 0.16 0.20 211105 211/10 P-9 Nat. Gas 11 0.08 0.11 0.20 5/27/05 5/27/10 Spray Dryer No.2oil 10 0.17 0.17 0.25 2/2105 2/2110 R-173 Nat. Gas 10 0.05 0.13 0.19 5/26/05 5/26110

(Printed on Recycled Paper) 79 Elm Street • Hartford. CT 06106

- 5127 An Equal Opportunity Employer

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# .. Cytec Industries, Inc. 2 Trading Agreement and OrderNo. 8114A Modification I
4. Delete paragraph A.9. including table 2, in its entirety.

5. Delete paragraph C.I.c. and substitute the following therefor: Cytec shall comply during the operation ofthe units with the FLERs shown in Table I ofthis Trading Agreement and Order.
6. Delete paragraph C.9. and substitute the following therefor: Documentthat sufficient approved DERCs are available for the units no laterthan the first ofeach calendar monthto assure compliance for, at a minimum, that calendarmonth. DERCs required shall be adjusted upwards by 100% ifDERCs are not in Cytec's possession for usepriorto the first day ofeach month. However, nothing inthis Trading Agreement and Order shall affectthe Commissioner's authority to institute any proceeding or take any otheraction to require additional upward adjustment, based on the gravity ofany alleged noncompliance or violation oflaw. Cytec shall permanently retire the quantity ofDERCs equivalentto the excess emissions plus a 100% premium within sixty (60) days ofCytec's discovery ofthe DERC shortfall. Cytec shall certify and report any such DERC retirementto the Commissionerin accordance withparagraph C.20. ofthis Trading Agreement and Order.

7. Delete paragraph C.2.ii. and substitute the following therefor: Total Monthly Averaging Debits ("MADs") generated from boilers I and 3 when burningNo.6 oil with emission rates inexcess ofallowable limits in the Averaging Set shall be the sum ofthe MADs during that month calculated for each unit in the Averaging Set as follows: MADs (tons) "" [heat input in MMBtu x ((0.85 x allowable limit in IbsfMMBtu)- DebitFLER in IbsIMMBtu)] + 2000 Ibs/ton.Cytec Industries, Inc. 3 Trading Agreement and OrderNo. 8114A Modification I 8. Delete paragraph C.3.a. and substitutethe following therefor: Forthe hot oil furnace and spray dryerheat inputs, Cytec shall multiply the rated capacity in MMBtu/hourby the hours ofoperation. Forboilers I, and 3, Cytec shall calculate the total monthly heat inputby allocating the overall fuel use by the individual steam production from each boiler.
9. Delete paragraph C.S. and substitute the following therefor: Cytec shall make and keep records of: hours ofoperation for the hot oil furnace and spray dryer; heat input for boilers I and 3; andNOx emissions for eachunit in the averaging set on a monthly basis in accordance withparagraph C.2., and will maintainrecords 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-ozone season (the remainder ofthe year); as well as documentation attesting to the fact thatapproved DERCs used during the ozone season were generated during the ozone season. Generator certification ofthis fact shall be sufficient. Cytec shall maintain and submit such records to the Commissionerin accordance with Section 22a-174-22 ofthe Regulations.
10. Delete paragraph C.II. and substitutethe following therefor: 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% premium. The true up in tons ofDERCs shall be equal to the FLER exceedance in Ibs/MMBtu, multiplied bythe total heat inputduring the period of noncompliance dividedby 2000 lbs/ton. Iftheperiod ofnoncompliance is not known, the time period from the completionofthe last/previous Commissioner witnessed emissiontest 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 affectthe Commissioner's authority to institute any proceeding ortake any other action to require additional upward adjustment, based onthe gravity ofany alleged noncompliance orviolation oflaw. Cytec shall permanently retire DERCs calculated in accordance with the above plus a 100% premium within sixty (60) days ofALC's discovery ofthe FLERexceedance. Cytec shall reportany FLER exceedance to the Commissionerin accordance with paragraph C.3I. ofthis Trading Agreement and Order.Cytec Industries, Inc. 4 Trading Agreement and OrderNo. 

### 8114A Modification 1

II. Delete paragraph C.14. and substitutethe following therefor: Extension. No later than May I, 2009, with respectto the units, Cytec shall comply with the requirements ofSections 22a-174-22(d)(I) and 22a-174-22(d)(2)(A) ofthe Regulations and amendments thereto. There is no assurance that after full program review ofthis and otherTrading Agreements and Orders thatthe Commissionerwill grant a written extension ofthis Trading Agreement and Order.
12. Delete the date September 1,2006, and substitute therefor the date September 1,2008 in paragraph C.IS.
13. Delete the word "individual" and substitutetherefore the word "section" in paragraph C.31.
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14. Delete the name "Mr. Roland L. Severance Jr., PE" inparagraph C.32.
All otherterms and conditions ofTrading Agreement and OrderNo. 8114A issued by the Commissioner acting underChapter446c, Sections 22a-6, 22a-171, 22a-174, 22a-176, and 22a-177 ofthe Connecticut General Statutes shall remain 

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Cytec hereby consents to the entry ofthis modificationto the Trading Agreementand Order without further notice.
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_Cytec Industries, Inc. 5 Trading Agreement and OrderNo. 8114A Modification 1
Issued as a modification ofan Orderofthe CommissionerofEnvironmental Protection

# ~~**~/Gina** McCarthy 

# a Commissioner

CITY OF WALLINGFORD LAND RECORDS MAILED CERTIFIED MAIL, RETURN RECEIPT REQUESTED Certified DocumentNo. 

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