STATE OF CONNECTICUT

DEPARTME.!T OF ENVIRO MENTAL PROTECTION

The State of Connecticut and

University ofConnecticut

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Trading Agreement

and Order No. 8115B

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

Cormecticut ("UCONN") 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 (HNOx'1 emissions will achieve this

result in a timely and cost-effective manner.

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

1. ~s Trading Agreement and Order 5upercedes Trading Agreement and Order 8115

issued on November 19, 1996, Trading Agreement and Order 8115 Modification issued

on September 29,1997, Trading Agreement and Order 8115 Modification 2 issued on

April 29, 1999, and Trading Agreement and Order 8115 A issued on April2!, 2002.

2. UCONN is a State oVJ1led institution of higher learning that operates a campus of

buildings in Storrs, Connecticut ("faciliry").

3. At the facility, UCONN operates fuel-burning equipment that consists oftwo (2) dualfuel burning boilers 2 and 7 ("boilers") which are subject to Section 22a· I74-22 ofthe

Regulations ofConnecticut State Agencies ("Regulations'') pertaining to the control of

NOx emissions.

4. Official U.S. Environmental Protection Agency ("EPA") Reference Method 7·E

emission testing performed March 23, 2000 on boiler 2 resulted in NOx emission rates

as follows:

Table 1

UCONN-NOx Emission Rates and Allowable Limits (lbsIM'}.{Btu)

Unit: DEP Fuel Heat Stack No,. Allowable Date of Next

Reg. # Input Test FLER Emission Las! Emission

Rate Limits Emission Test Due

Test

Boiler 2: INo.2 oil I 89 I ~'~ 0.27 I 0.20 I 3123/00 I

3/23105

98·15115 Nat Gas 89 "tH4 . N/A 0.20 3123/00 3123/05

5. When burning No.2 fuel oil, in boiler 2, UCONN exceeds the NOx allowable emission

rate limit specified in Section 22a-174-22(e) 22-1 of the Regulations.

(Printed on Recycled Paper)

79 Elm Streel • Hartford. CT 06106·5127

An equal Opponuntry Employer. htlp:Jldep. stare cr.lIs

Celebrating a Century of Forest Conservation Leadership

1901 2001 ORIGI~JAL
University of Connecticut 2 Trading A2Teemenl and Order 8115 B

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6. Pursuant to Section 22a-174-22(j) of the Regulations UCONN proposes to comply with

Section 22a-174-22(e) ofthe Regulations, when bumin~ No.2 fuel oil in boiler 2,

throuM the use of approved DERCs until April 30, 200 I at the facility in accordance

with ihis Trading Agreement and Order.

7. UCONN proposes to use a full load emission rate ("FLER") identified in table 1 above

for the purposes of calculating DERCs required

8. Section 22a-174-22(k) ofthe Regulations requires that emissions testing to be conducted

when the source is operating at or above 90 percent ofits highest maximum operating

rate, unless allowe4 otheIWlse by the COmmIssioner in a permit or order.

9. UCONN operated boiler 7 during emissions testin,g at less than the required 90 percent

ofmaximum operating capacity. Pursuant to SectIon 22a-I74-22(k) of the Regulations,

UCOl\TN proposes'to comply with the 90 percent ofmaximum operating rate test

requirement for boiler No.7 by accepting an operating restriction limit of 111.1

MMBtuIhr or a corresponding steam output of 80,000 Ibs./hr.

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

No. 8115, 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

UCONN. 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 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.

Table 2

UCONN

Previouslv Aoofoved DERCs

Year Ozone Season NOx DERC Ozone Non-ozone season NOx Non- Expiration

of Gen. serial numbers Season DERC serial numbers ozone Date

DERC, season

DERC,

1996 SIN not assigned 12 12/31/04

1997 SIN Dot assie:ned 13 I SIN Dot assie:ned 28 ; 12f31104

1998 SIN Dot assimed 20.7 I SIN Dot assi~ed 27 12131/04

Pre·J999 12131/04

2000 I

2001 CTOI/8115(] C)NOxoz 1-26 26 12131106

2002

The Commissioner, in accordance with the provisions ofthis Trading Agreement and Order,

pursuant to Section 22a-174-22 of the Regulations, hereby allows UCONN to comply with

Section 22a-174-22(d) of the Regulations at the facility through use ofDERC trading.

With the agreement ofUCONN, the Commissioner, acting under Sections 22a-6, 22a-174,

22a-174, 22a-176, and 22a-l77 of the Connecticut General Statues, hereby orders UCONN

as follows:

ORIGI~IAL
Universitv of Connecticut 3 Tradimz Agreement and Order 8115 B

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

comply with Section 22a-174-22 ofthe Regulations through emission reduction tnding

until UCONN achieves pennanent compliance with the emission standards in Section

22a-174-22(e) of the Regulations or by April 30, 2007, whichever occurs earlier as

follows:

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

Order;

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

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

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

Table I above ofthis Trading Agreement and Order.

2. DERC Use. Umil April 30, 2007, before the first day of each month UCONN shall have

in its possession sufficient approved DERCs for such month for boiler 2 based on the

following calculation:

a. Before the first day of each month, UCONN shall estimate DERCs required for

such calendar month for boiler 2 when burning No.2 fuel oil and using the FLER

from Table 1 as follows:

Estimated DERCs (tons) use = {(Estimated fuel use in MMBru) x «FLER) - (0.95

x NOx allowable emission limit))}.;.2000 pounds.

Where:

• Allowable limit = allowable limit rate in Ibs/MJ\.1Bru shown in Table

1 ofthis Trading Agreement and Order.

• FLER = full load emission rate in IbsJM:MBru as shown in Table I of

this Trading Agreement and Order.

• Discount (0.95) = 5% design margin applied to the allowable limit

rate.

• Fuel heatin. value 138,000 BTU per gallon

b. 0 later than the twentieth day of each month, calculate actual DERCs used in

the preceding calendar month for boiler 2 when burning No.2 fuel oil using the

FLER from Table I above and as follows:

Acrual DERCs (tons) used = {(Acrual fuel use in MMBru) x «FLER) - (0.95 x

NOx allowable limit))}.;.2000 lbs/ton.

d. Maintain documentation to attest to the fact that DERCs used during the ozone

season were generated during the ozone season. Generator certification ofthis

fact shall be sufficient.

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Universitv of Connecticut , Tradine A2reement and Order 81 15 B

8. Boiler 7 Operatinlz Restriction. Upon issuance of this Trading Agreement and Order and up

to and including April 30, 2007, UCONN shall comply during operation of boiler 7 to a

maximum operating limit of 111.1 MNfBtuIhr of heat input or 80,000 1bs/hr ofsteam

production, averaged on a 24-hour basis. However, if at any time after issuance ofthis

Trading Agreement and Order, UCONN exceeds this limit, UCONN shall conduct NOx

emissions testing of boiler 7 on or before sixty (60) days after the exceedance of the above

limits in accordance wirp. the requirements specified in paragraph C.lOofthis Trading

Agreement and OrdeD

9. Boiler 7 Ooerating Restriction Ooerating Records. UCONN shall retain records and

supporting documentation including but not limited to acruallbs/hr ofsteam output, gallons

or cubic feet per hour offuel, heat input per hour, to demonstrate that boiler 7 is operating in

compliance with the maximum operating limit of 111.1 :MJv1BtuIhr of heat input or 80,000

lbs/hr ofsteam production.

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10. Upon issuance ofthis Trading Agreement and Order, ifUCONN has reason to believe it

may be exceeding the operating restriction level in above or exceeding the operating

restriction specified in paragraph C.8. ofthis Trading Agreement and Order, UCONN shall

conduct NOx emissions testing ofthe corresponding boiler on or before sixty (60) days after

the exceedance of the above limits in accordance with the following:

i. UCONN shall submit to the Commissioner for his review and wrinen

approval an Intent-To-Test ('1TT') protocol not less than thirty (30) days

pnor to the emissions testing required pursuant to this paragraph and

paragraph C.17 ofthis Tradmg Agreement and Order. The ITT protocol

shall include at least:

11 The Department's Bureau of Air Management Test Form No. I, "Intent to Test".

lll. System operating parameters indicative ofthe hi~est operating 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,

temperature and pressure, fuel firing rate, and NOx emissions rate.

IV. The lIT protocol shall provide that UCONN shall perform testing as

specified in Sections 22a-I74-5 and 22a-I74-22 of the Regulations,

including operating boiler 7 at not less than ninety percent (90%) ofits

maximum rated capacity limit or highest operating rate since its

last/previous emissions test, whichever is higher.

UCONN shall perform all testing required by this Trading Agreement and

Order in accordance with the approved IIT protoco!.

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

Agreement and Order, and analyzing the results ofsuch testing, UCOr-..T'N

shall adhere to methods specified in Sections 22a-174-5 and 22a-I74-22 of

the Regulations and as approved by the United States Environmental

Protec{Jon Agency ("EPA") and the Commissioner.

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Universitv ofConnecricut 5 Trading A2Teement and Order 8115 B

Vll. UCONN shall schedule all emissions testing so as to allow the

Co~issione~ to be present ~uring such tes~ing and to independently v~rify

facilIty operanons, au pollutlOn control eqUipment parameters, and testmg

procedures.

viii. Within 30 days after completing any emissions testing required by this

Trading Agreement and Order, UCONN shall submit to the Commissioner

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

notice from the Commissioner indicating any defiCIencies in such report,

UeONN sb~1 submit a revised report. .,

11. UeONN sban make and keep records of: daily fuel use and fuel type; excess NOx

emissions; the number ofDERCs in its possession, created, purchased and used (by serial

number if assigned) each month. as in accordance with the appropriate emission rates and

limits in this Trading Agreement and Order; the number ofDERCs used in the ozone season

and non-ozone season (the remainder ofthe year); well as documentation attesting to the

fact that approved DERCs used in the ozone season were created during the ozone season.

Generator certification ofthis fact shall be sufficient. UCON"N shall maintain and submit

such records to the Commissioner in accordance with Section 22a-174-22 of the

Regulations.

12. Record Keeping. UCONN shall retain records and supporting documentation as described in

this Trading Agreement and Order for a minimum offive years, commencing on the date

such records were created. UCONN shall provide the records specified above to the

Commissioner within thirty (30) days ofreceipt of a wrinen request from the Commissioner.

All records shall be maintained in accordance with Sections 22a-174-4 and 22a-174-22 of

the Regulations.

13. Annual Emission Statement. No later than March I, of every year after issuance of this

Trading Agreement and Order, UCONN 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

of the DERCs approved within and subsequent to issuance oftrus Trading Agreement and

Order until all such DERCs have been used. UCONN shall also include NOx emissions

from each boiler using or generating DERCs, and the amount of all DERCs used including

serial nwnber (if assigned) and approved DERCs generated and/or purchased from other

facilities), generated and/or approved for the previous calendar year. These reports shall be

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

UCONN" choose to discontinue the generation ofDERCs, UCONN will notify the

Commissioner upon discontinuance

14. Allowance Use. Pursuant to Section 22a-174-22(d)(3) of the Regulations, UeONN may use

NOx allowances, through April 30, 2007, pursuant to Subsection (j) of Section 22a-174-22

ofthe Regulations to achieve all or a portion of the reductions required by Section 22a-174-

22 ofthe Regulations. Any allowance used for compliance with Section 22a-174-22(e) of

the Regulations shall be subject [0 all resn1ctions and/or requirements applicable to DERCs

contained in this Trading Agreement and Order;

a. In order for UeONN to use NOx allowances, UeON- sball create a general

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

ORIGINAL
Universitv of Connecticut 6 Tradine Agreement and Order 8115 B

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

account in the. ATS to the CT State NOx Retirement Account (Accowlt ill

CTOOOO000300 in the NATS).

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

"DERCs are not in UCQNN's possession prior to the first day of each month of use.

However, based on the gravity of noncompliance, the Commissioner may require additional

upward adjustment.

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

Regularions, DERCs/allowances shall only remain valid for five (5) calendar years from the

year of the generation/allocation ofsuch DERCs/allowances. DERCsiallowances older than

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

with Section 22a-174-22 ofthe 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.

17. FLER Exceedance. Noncompliance with an established FLER shall subject UCONN to

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

plus a 100% premium. The true up in tons ofDERCs shall he equal to the FLER

exceedance in IbslM:MBtu, multiplied by the total heat input during the period of

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

time period from the completion of the lasUprevious Department 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.

18. FLER Modification. FLERs set forth in Table 2 of this Trading Agreement and Order may

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

Trading Agreement and Order.

19. Emissions Testing. Pursuant to Section 22a-174-22(k) ofthe Regulations, UCONN shall

conduct NOx emission tests of boilers 1,2,3,4,5,6,7 and 8 at least once every five years

commencing from the dates ofthe applicable year 2000 emissions tests for boilers 1,2,3,4,

5,6,7 and 8. Notwithstanding this emission testing requirement, boiler 4,5, and 6 are

scheduled to be taken out ofservice with the startup of Boiler 9 and, therefore, will not

require funher testing beyond the date they are officially removed from service as

deEennined by the Commissioner.

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20. Arumal Emission Statement. No later than March 1, of every year after issuance of this

Trading Agreement and Order, UCOl\TN shall include with the Annual Emission Statement

provided to the Commissioner, a record of each sale or other tran.sfer, and use of any and all

of the DERCs approved within and subsequent to issuance of this Trading Agreement and

Order until all such DERCs have been used. UCONN shall also include NOx emissions

ORIGINAL
University of ConnecticuI 7 Trading A!2reement and Order 8115 B

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 and/or approved for the previous calendar year. These reports shall be

on a fonn prescribed by the Conunissioner and shall be in monthly increments. Should

UCONN choose to discontinue the generation ofDERCs, UCONN will notify the

Commissioner upon discontinuance.

21. Program Review. After April 30, 2007 for the boilers, UCONN shall comply with the

. requirements ofSecti~n 22a-174-22 oftbe Regulations. However, after full program review

oftrus and other Trading Agreements and Orders and if determined to be appropriate, the

Corrunissioner may grant written extension ofthis Trading Agreement and Order. After full

program review, and if the Commissioner deems it appropriate, the Commissioner may

allow the survival and use ofthese DERCs, subject to the vintage restriction, beyond April

30,2007.

22. Future Compliance Report. On or before September 1, 2006, UCONN shall submit a report

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

April 30, 2007.

Full compliance. UCONN 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.

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

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

Commissioner notifies UCONN that any document or other action is deficient, and does not

approve it with conditions or modifications, it is deemed disapproved, and UCONN 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 ofthe Commissioner's notice of

deficiencies. In approving any document or other action ~nder-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 ofthis Trading Agreement and Order. Nothing in this paragraph

shall excuse noncompliance or delay.

Definitions. As used in this Trading Agreement and Order, "Approved DERCs" are those

for which the Commissioner has provided \VIitten authorization for use in compliance with

Section 22a-174-22 ofthe Regulations; "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" 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.

Dates. The date ofsubmission 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

ORIGINAL
University of Connecticut 8 Tradine A2Teement and Order 8115 B

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other action, shall be the date such notice is deposited in the U.S. mail or is personally

delivered, whichever is earlier. Except as otherv.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 perfonned by a date which falls on a Sarurday, Sunday or a Connecticut or

federal holiday shall be submitted or performed by the next day which is not a Saturday,

Sunday or COIU1ecticut or federal holiday.

.Certification of docume~ts. Any document, including hut not limited to any notice, which is

required to be submitted to the Commissioner lU1der this Trading Agreement and Order shall

be signed by UCONN or, ifUCONN is not an individual, by UCONN's chief executive

officer or a duly authorized representative ofsuch officer, as those terms are defined in

Section 22a-430-3(b)(2) ofthe Regulations ofConnecticut State Agencies, and by the

individual(s) responsible for acrually preparing such document, and UCONN or UCONN's

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

"I have personally examined and am familiar with the information 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 submitted information is true, accurate and complete to the best

ofmy knowledge and belief. I understand that any false statement made in the

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

the Connecticut General Statutes and any other applicable law."

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

UCONN to an injunction and penalties.

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

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

Connecticut General Statutes and any other applicable law.

Notice oftransfer; liability ofUCONN. Until UCONN has fully complied with this Trading

Agreement and Order, UCOl\TN shall notify the Commissioner 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. UCONN's obligations under this Trading Agreement and Order

shall not be affected by the passage of title to any property 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 UCONN pursuant to this Trading
Universitv ofConnecticut 9 Tradin!2 Agreement and Order 8115 B

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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 UCONN to unden.ake fun.her

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

32. UCONN's obli2ations under law. othing in this Trading Agreement and Order shall

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

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33. . No assurance by Commissioner. No provision ofthis Trading Agreement and Order and no

action or inaction by the Commissioner shall be consnued to constitute an assurance by the

Commissioner that the actions taken.by UCOl\TN pursuant to this Trading Agreement and

Order will result in compliance or prevent or abate pollution.

34. Access to premises. Any representative of the Department of Environmental Protection may

enter the without prior notice for the purposes ofmonitoring and enforcing the actions

required or allowed by this Trading Agreement and Order.

35. No effect on ri2hts 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.

·0 Creation ofPropertv Rie:hts. This Consent Order does not create any property rights

with respect to these DERCs.

37. NotIce to Commissioner of chan!2es. Within 15 days ofthe date UCONN becomes aware of

a change in any information submined to the Commissioner under this Trading Agreement

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

information was omined, UCQNN shall submit the correct or omitted information to the

Commissioner.

38. Notification of noncompliance. In the event that UCONN 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, UCONN shaH

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, UCONN 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 wrinen

approval of the Commissioner, dates by which compliance will be achieved, and UCONN

shall comply with any dates which may be approved in writing by the Commissioner.

Notification by UCONN 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.

ORIGINAL
University of Connecticut 10 Trading A2Teement and Order 8115 B

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39. Submission of documents. Any document required to be submined to the Commissioner

under this Trading Agreement and Order shall, unless otheiWise specified in this Trading

Agreement and Order or in writing by the Commissioner, be directed to:

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

Emissions Trading Unit

Compliance and Field Operations Division

5th Floor

" Bureau ofAir Management

Department ofEnvironmental Protection

79 Elm Street

Hartford, COIUlecticut 06106

ORIGINAL
University of Connecticut 11 Tradin2: Agreement and Order 8115 B

Date: /"arch 7, 2003

TOWN OF STORRS LAND RECORDS

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UCONN 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 UCONN to the terms and conditions ofthe Trading Agreement and Order.

Type Name: larry G. Schilling

Type Title: Executive Director of Architectural & Engineering services

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Issued as a final order ofthe C~s1fr ofthe Department of , . / /

Environmental Protection on ( ,2003. (/~J/

~'4~ ="=z;n

MAILED CERTIFIED MAIL,

RETURN RECEIPT REQUESTED

Certified Docwnent No.

G:\-TRADlNG·R!.S\.TRADINGORDERS\UCONN.RLS\UConn 8115B(2-II'()J).dot

ORIGINAL