STATE OF CONNECTICUT

DEPARTMENT OF ENVIRONMENTAL PROTECTION

In the matter of

The State of Connecticut and

Cytec Industries, Inc.

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Trading Agreement

and Order No. 8114A

Modification I

Whereas, the Commissioner of Environmental 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 of boilers 1 and 3, one hot oil

furnace, and one spray dryer, ("units") which are subject to Section 22a-I74-22 of

the Regulations of Connecticut 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 Order No. 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:

Document that sufficient approved DERCs are available for the units no later than

the first of each calendar month to assure compliance for, at a minimum, that

calendar month. DERCs required shall be adjusted upwards by 100% if DERCs are

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

oflaw. Cytec shall permanently retire the quantity of DERCs equivalent to 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 retirement to

the Commissioner in accordance with paragraph 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

burning No.6 oil with emission rates in excess of allowable 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)-

Debit FLER in IbsIMMBtu)] + 2000 Ibs/ton.
Cytec Industries, Inc. 3 Trading Agreement

and Order No. 8114A

Modification I

8. Delete paragraph C.3.a. and substitute the following therefor:

For the hot oil furnace and spray dryer heat inputs, Cytec shall multiply the rated

capacity in MMBtu/hour by the hours of operation. For boilers I, and 3, Cytec shall

calculate the total monthly heat input by 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 of operation for the hot oil furnace and

spray dryer; heat input for boilers I and 3; and 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 of DERCs 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-ozone 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. Cytec shall maintain and submit such records to the

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

10. Delete paragraph C.II. and substitute the following therefor:

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% premium. The true up in tons of DERCs shall be equal to the

FLER exceedance in Ibs/MMBtu, multiplied by the 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 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 oflaw. Cytec shall permanently retire DERCs calculated in

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

discovery ofthe FLER exceedance. Cytec shall report any FLER exceedance to the

Commissioner in accordance with paragraph C.3I. ofthis Trading Agreement and Order.
Cytec Industries, Inc. 4 Trading Agreement

and Order No. 8114A

Modification 1

II. Delete paragraph C.14. and substitute the following therefor:

Extension. No later than May I, 2009, with respect to the units, Cytec shall comply with

the requirements of Sections 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 other Trading Agreements and Orders that the Commissioner will

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 substitute therefore the word "section" in paragraph

C.31. .

14. Delete the name "Mr. Roland L. Severance Jr., PE" in paragraph C.32.

All other terms and conditions ofTrading Agreement and Order No. 8114A issued by the

Commissioner acting under Chapter 446c, Sections 22a-6, 22a-171, 22a-174, 22a-176, and 22a-177

ofthe Connecticut General Statutes shall remain in effect.

Cytec hereby consents to the entry ofthis modification to the Trading Agreement and Order

without further notice.

Signature: ->£>",,~=--~=-f,fJ-.JlJ~~""::"-_----

Name: _-=~:::......:.!...:::::.~_'\...:..I_---=_...:.......;..--.:.... _

Title: 1> I~L J FA-c..-r\l\2.1 r-J6!;"

Date: of U:::tJ>-"9_1-=---- _
Cytec Industries, Inc. 5 Trading Agreement

and Order No. 8114A

Modification 1

Issued as a modification of an Order ofthe Commissioner ofEnvironmental Protection

~/Gina ~~McCarthy a

Commissioner

CITY OF WALLINGFORD LAND RECORDS

MAILED CERTIFIED MAIL,

RETURN RECEIPT REQUESTED

Certified Document No.

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