# STATE OF CONNECTICUT DEPARTMENT OF E 'VIRONMENTAL PROTECTION

In the maner of 

### The State ofConnectiCUI 

### and Pfizer, Inc. ) ) ) ) ) Trading Agreement and Order No. 8093C

Whereas, the Commissioner ofEnvironmental Protection ("Commissioner") and the Pfizer, Inc. ("Pfizer") 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 ofdiscrete emission reduction credit ("DERC") trading to reduce nitrogen oxide ("NOx") emissions will achieve this result in a timely and cost-effective manner. A. At the request and with the agreement ofPfizer, the Commissioner finds the following: 1. This Trading Agreement and Order supercedes Trading Agreement and Order 8093B issued on December 5, 2001 and Trading Agreement and Order 8093B Addendum 1 issued on April 29, 2002. 2. Pfizeris a corporation that owns and operates apharmaceutical production and research facility at Eastern Point Road, Groton, Connecticut ("facility"). 3. At the facility, Pfizer operates two (2) dual-fuel fired stearn boilers numbered 5, and 8 ("boilers 5 and 8"), which are the subject ofthis Trading Agreement and Order and are subject fa Section 22a-174-22 ofthe Regulations ofConnecticut State Agencies ("Regulations"). At the facility, Pfizer also operates one (1) dual-fuel fired steam boiler number 4. Boilernumber 4 is only referenced herein with respect to previously generated DERCs as identified in Table 2 of this Trading Agreement and Order. Pfizer monitors NOx emis·sions from boilers 5 and 8 using continuous emission monitors ("CEMs") cenified to 40 Code ofFederal Regulations ("CFR'') Pan 75. 4. Pfizer's boilers 5 and 8 sometimes exceed the NOx allowable emission rate limit specified in Section 22a-l74-22(e) ofthe Regulations. 5. To reduce excess NOx emissions, beginning in 1996, Pfizerhas represented that it monitors and controls the combustion process ofboilers 5 and 8, and bums natural gas, so that emissions frequently can be kept below the NOx emission limitations established by Section 22a-174·22(e) ofthe Regulations of Connecticut State Agencies ("Regulations").

(Printed on RecyCled Piper) 79 Elm Suee( • Hanlord. CT 06106.5127**hllp:lldc?slil(e.c(.~s** An £qutll Opporrunur EmployerPfizer Inc. Trading Agreement and OrderNo. 8093C 6. Pursuant to Section 22a-174-220) ofthe Regulations, during the non-ozone season, Pfizer intends both to acquire and generate approved DERCs until May 1,2005 for boilers 5 and 8 at the facility. Pursuant to Section 22a-174-22Gl of the Regulations, during the ozone season, Pfizerintends both to acquire and generate approved Budget discrete emission reduction credits ("BDERCs") until May I, 2005 ,forboilers 5 and 8 at the facility

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# .... 7. When properly documented by Pfizer, and approved bythe Commissioner, the emission reductions identified above, and as computed in accordance with the terms ofthis Trading Agreement and Order, will confonn to the requirements ofSection 22a-174-22(j)(3) ofthe Regulations. Specifically, the reductions will be: Real because they will result in a reduction ofactual emissions released into the air, net ofany consequential increase in actual emissions resulting from shifting demand. The emission reductions will be properly measured, recorded and reported. Quantifiable because they are based on CEM data as applied in an appropriate reliable and replicableprotocol, providing the rate and total mass amount ofreduction. Surplus because they are not required by any Connecticut statute or regulation mandated by a current State Implementation Plan ("SIP"), and are not currently relied upon 

### in any applicable anainmentplan, any reasonable further progress plan ormilestone demonstration. Pennanent because the 10w-NOx burners, flue gas recirculation and natural gas burning capability will be in place and operating, and an appropriate tracking system is in place to monitor all data required to verify and quantify the creation ofDERCs. Enforceable because the DERCs are approved by the Commissioner retrospectively afterthe submission byPfizer ofarepon that documents their creation. 8. The emissions trading baselines ("baseline emission rate'') and the allowable emission limits for boilers 5 and 8 in pounds permillion British thennal units C'lbslMJvfBtu" ofheat input) when operating on No.6 fuel oil and natural gas are provided on the following Table I:

2Pfizer Inc. Trading Agreement and Order No. 8093C Table 1 NOx AJlowable Limits and Baseline Emission Rate in Ibs/MJl.1:Btu Emission Fuel Heat Input Emissions AllowablelBaseline emission Unit :M]v(Btulhr Test rate IbsJM:MBtu BoilerNo.5 No.6 399.50 CEM 0.25 Registration No.2 I 399.50 CEM 0.20 070-0012 NatGas 399.50 CEM 0.20 BoilerNo. 8 No.6 266.40 CEM 0.25 Pennit No. No.2 266.40 CEM 0.20 070-0001 NatGas 266.40 CEM 0.20 9. In the future Pfizer intends to use No.2 fuel oil. The baseline emission rate for the boilers 5 and 8 is 0.20 IbslM:MBtu ofheat input when operating on No.2 fuel oil. 1O.Staning on October I, 2003, and during the period from October I through April 

### 3D, inclusive, each year until May 1, 2005, Pfizermay only obtain approval of acrual reductions in 'Ox emissions, generated by operating the boilers 5 and 8 at a rate that is below a non-ozone seasonal average of0.15 IbsIM:MBru. 

### ') 

### I.J 11.The Commissioner, in accordance with the provisions ofTrading Agreement and Order 8093B and Addendum I, pursuantto Section 22a-174-22(d)(3) ofthe Regulations, approved the non-ozone season NOx DERCs referenced in Table 2 of this Trading Agreement and Order. DERC creation serial nwnbers assigned by the Department to these previously approved reductions ofNOx emissions are provided in Table 2 ofthis Trading Agreement and Order. DERCs are subject to the vintage restrictions 

### in this Trading Agreement and Order. Dates that after which the unused DERCs will no longerbe eligible foruse as a result ofthe vintage restrictions are provided in Table 2 ofthis Trading Agreement and Orderin the expiration date column. d)NO DERC Table 2I d d ( I PreVIOUSIV approve 

### to t,eextentnota rea y 

### use 

### x s Year of Non-<lzone se:ason NOx DERC ll'on-Ozone Expiration Generation serial numbers /boiler s 4, 5 & 8) Date 1999 CT99/8093B DC Noxnoz7·14 7 12131/04 2000 CTOO/8093B(DC)NOxnoz1.23 23 12131/05 2000 erOO/8093B DC1Noxnoz24·30 7 12131/05 2001 

## ero 1/8093B(DClNO"-,,oz1-9 9 12131/06

B. The Commissioner, in accordance with theprovisions ofthis Trading Agreement and Order, pursuant to Section 22a-174-22(d)(3) ofthe Regulations, hereby allows Pfizerto: i y. 3

### Pfizer Inc. Trading Agreement and Order No. 8093C



# c. 1. 

### Comply with Sections 22a-174-22(d)(1) and (2) ofthe Regulations through use of BDERC and DERC trading; 2. Ozone season BDERCs may be generated and used in accordance with this Trading Agreement and Order;.and I 

### 3. Upon sufficient docUmentation as prescribed in this Trading Agreement and Order, generate additional BDERCs and DERCs. Upon issuance ofan addendtun to this Trading Agreement and Orderthe Conunissionermay approve the generation of additional BDERCs and DERCs by Pfizerretrospectively. Approved BDERCs and DERCs generated byPfizermay be held by Pfizerortransferred to otherpersons in accordance with this Trading Agreement and Order. With the agreement ofPfizer, the Conunissioner, acting under Sections 22a-6, 22a171, 22a-174, 22a-176, and 22a-177 ofthe Connecticut General Statutes, hereby orders Pfizer as follows: 1. Upon issuance ofthis Trading Agreement and Order, Pfizermay generate approved BDERCs and DERCs as allowed underthis Trading Agreement and Orderuntil May 1, 2005. 2. Upon issuance oftrus Trading Agreement and Order, at the facility, Pfizer shall comply with Section 22a-174-22 ofthe Regulations through emissionreduction trading: Until Pfizer achieves permanent compliance with the emission standard in Section 22a-174- 22(e) ofthe regulation orbyMay 1, 2005, whichever occurs earlier:

a. Pfizer shall use approved DERCs and BDERCs as required underthis Trading Agreement and Order; and b. Pfizer shall have in its possession sufficient approved BDERCs and DERCs to meet applicable NOx emission limits as allowed underthis Trading Agreement and Order. 3. DERC generation.

a. Until May 1, 2005, when the boilers 5 and 8 have daily ozone season NOx emissions below the applicable baseline emission rate(s) or the proportioned baseline emission rate, or when boilers 5 and 8 have seasonally averaged NOx emissions below 0.15 Ibsl1v1:MBtu during the**non~ozone** 

### season starting on October 1, 2003, Pfizer shall calculate the amount ofDERCs generated as follows:



# ,, '0 PfizerInc.

b.

c.

d.

e. Trading Agreement and Order No. 8093C DERCs (tons) = {[Total heat input' ofall fuels in MMBru x «proponioned baseline emission rate2 ) - (the CEM-recorded Ox emission rate'))] .;. 2000 Ibs/ton} x (0.90)'

l Heat input shall be calculated using the actual fuel usage data in MMBtu per unit offuel combusted. Fpr the pwposes ofcalculating the non-Qzone season DERCs the total nonozone seasofl beal input shall be used.

nus rate shall be calculated by 1) multiplying the heal inpul ofeach fuel combusted by the baseline emission rate(s) for such fuel; 2) summing those products; and 3) dividing the sum by the total heal input. rfthe boiler is operating exclusively on one fuel. PfIZer may replace the proportioned baseline emission rale with the applicable baseline emission rate, for thar fueL Forpurposes ofcalculating the non-ozone season DERCs the proportioned baseline emission rate shall be 0.15 IbsIMMBru forDERCs generated from October l>l through April 30dl

. ) Forpurposes ofcalculating the non-ozone season DERCs, this rate shall be calculated by dividing the total amOUDt ofNOx generated during the period OClober I" through May 31>1 by the lotal heat input for this same period.

4 Ten (10) percent ofall DERCs (tons) generated by the boiler shall be retired by the facility and permanently removed from all calculations on a seasonal basis to assure a benefit to the environment During the ozone season until Mav 1. 2005: Forpurposes ofcalculating the number ofBDERCs generated from boilers 5 and 8 at the facility, Pfizer shall use the baseline emission rates forboilers 5 and 

### 8. orthe proportioned baseline emission rate set fonh in footnote 2 ofparagraph C.3. of this Trading Agreement and Order, when simultaneouslyoperating on more than one fuel. Pfizer shall use the above referenced baseline emission rate(s) when calculating the proportioned baseline emission rate. During- the non-ozone season until Mav I. 2005: Forpurposes of calculating the number ofDERCs generated from boilers 5 and 8 at the facility, Pfizer shall use 0.15 IbsJM:MBtu ofheat input as the**non~ozone** seasonal average baseline emission rate for boilers 5 and 8. Non-ozone Season Restrictions. Non-ozone season NOx DERCs generated by Pfizer shall be created and approved in accordance with this Trading Agreement and Order, and shall remain valid until they are used oruntil their vintage expiration date, whichever occurs first. Dunne the ozone season until May 1. 2005:' In requesting approval ofBDERCs and DERCs generated by boilers 5 and 8, Pfizer shall provide documentation containing a sample spreadsheet with calculation formulas used to detennine reported numbers; ozone season operating reports ofactual fuel usage for each 5

### Pfizer Inc.



### f. Trading Agreement and OrderNo. 8093C fuel type including the fuel BTU content, for each fuel type; daily M.MBtu for each fuel type; 24-hour actual NOx emission rate; and daily DERCs generated using the baseline emission rate(s), or the proportioned baseline emission rate referenced in 

### paragraph C.3. ofthis Trading Agreement and Order, net ofthe ten (10) percent environmental discount. I 

### During the nOn-ozone season until May 1, 

### 2005: In 

### requesting approval of DERCs generatedbyboilers 5 and 8, Pfizer shall provide documentation containing a sample spreadsheet with calculation formulas used to detennine reported numbers; non-ozone season operating reports ofactual fuel usage including the fuel BTU content, for eachfuel type; daily rvnvmru for each fuel type; non-ozone season actual NOx emissionrate (seven month average); and non-ozone season DERCs generatedusing the 0.15 IbslM:MBtu baseline emissionrate(s), net ofthe ten (10) percent environmental discount. 4. Vv'hen the 24-hour actual NOx emissionrate or**non~ozone** 

### seasonal average NOx emissionrate is used to calculate DERCs generatedbyboilers 5 and 8, Pfizer shall not include missing data calculated in accordance with any missing data substitutionprocedures, including those allowed under Section 22a-174-22b ofthe Regulations and 40 CFRPart 75. 5. Upon sufficient documentation, as determined by the Commissioner, thatPfizer has met the requirements ofthis Trading Agreement and Order, the Commissionermay provide written approval ofBDERCs orDERCs generatedby Pfizer retrospectively. Requests for approval ofall subsequent BDERCs and DERCs created shall be submitted in 

### writing to the Commissioner. Such requests shall be compiled on amonthly or seasonal (during the non-ozone season only starting on October 1, 2003) basis and shall be submitted at least on an annual basis. Approved BDERCs and DERCs generatedby Pfizerunder this Trading Agreement and Ordermay be held ortransferred to otherpersons. 6. DERC use. Until May 1, 2005, before the first day ofeach month, and starting on October 1, 2003, also before the first day ofeach non-ozone season, Pfizer should have in its possession sufficient approved DERCs for the boilers 5 and 8 based on the following:

, j**,~** a. 

### At all times: Before the first day ofeach month, calculateprojected DERCs required for that calendarmonth as follows: Estimated DERCs (tons) = 

### {[estimated 24-hourNOx emission rate in Ibs/MMBtu

- ((0.95) x (24-hourNOx allowable 6

### _.

J J PfizerInc.

b. Trading Agreement and Order No. 8093C emission limit orproportioned emission rate calculated pursuant to Section 22a-I74-22(f)(2)(A) of the Regulations in IbsIMMBtu))J x (Estimated fuel use in MMBtu)) .., 2000 poundsltons. No laterthan the twentieth day ofeach month, Pfizer shall calculate and permanentlyretire DERCs used in the preceding calendarmonth, as follows: (i) Forboilers 5 and 8 on each day, determine whether the 24·hoUI actual Ox emission rate· is greater than the NOx allowable emission limit. (ii) When the boilers 5 and 8 have a 24-hoUI actual NOx emission rate exceeding the NOx allowable emission limit, calculate the amount ofDERCs used, as follows: Actual DERCs (tons) {[(24-hour actual NOx emission rate in IbslMMBtu*)

- «0.95) x (NOx allowable emission limit orproportioned emission rate calculatedpursuant to Section 22a-174· 22(f)(2)(A) ofthe Regulations in IbsIMMBtu))J x (actual fuel use in MMBtu)} .2000 pounds/tons. "'This rate shall be calculatedpursuant to the methodology described 

### in 40 CFRPart 75.

(iii) With the exception ofBDERCs, excess DERCs from previous months can be applied to subsequent months. BDERCs are subject to the limitations set forth in paragraph C.? 

### oftms Trading Agreement and Order. During the non-ozone season starting on October 1. 2003: In addition to meeting the 24-hour emission limit 

### in Table 22-1 ofSection 22a-174-22 oftheRegulations, meet a non-ozone season average emission limit of0.15 IbsIMMBtu. Priorto October 1, 2003 and October 1, 2004, Pfizer shall estimate and acquire the amount ofDERCs or allowances required for such non·ozone season needed to comply with Section 22a174-22(e)(3) ofthe Regulations as follows: Estimated DERCs (tons) = [Estimated fuel use in :M1vffitu from October I through April 30 x (lower ofthe seasonal average NOx emission rate orthe proportioned 24-hour allowable

7

### Pfizer Inc. Trading Agreement and Order No. 8093C 

### emission limit in Ibs/MJvfBru during October 1 through April 30

- (0.95 

### x 0.15 IbslMMBtu))J "" 2000

### pounds/ton. No later than May 31, 2004, and May 31,2005, in addition to the DERCs retired pursuant to paragraph C.6.a. ofthis Trading Agreement and Order, calculate and permanently retire DERCs used in 

### the preceding non-ozone season as follows: 

# , Actual DERCs (tons) [Actual fuel use in MMBtu from October I through April 30 x (lowerofthe seasonal average NOx emission rate or the proportioned 24-hour allowable emission limit in IbsIMMBtu during October I through April 30

- (0.95 

### x 0.15 IbsIMMBtu))]"" 2000 

### pounds/ton.

\

'......;;/ 

### c. When the daily ornon-ozone season CEM-recordedNOx emission rate is used to 

### calculate DERCs used by boilers 5 and 8, Pfizer shall include missing data calculated in accordance with missing data substitution procedures Under40 CFRPan 75. 7. BDERCs shall only be used by otherNOx Budget Program sources located in Connecticut. BDERCs shall only be used to offsetozone season excess emissions, and shall notbe used for compliance during the non-ozone season. BDERCs generated during a given year shall only be used during the following ozone season. BDERCs are subjectto all DERC requirements set forth in this Trading Agreement and Order except for those requirements pertaining solely to non-ozone season DERCs and as otherwise maybe provided. 8. Record Keeping. Pfizer shall make and keep records forboilers 5 and 8 of: daily fuel use and fuel type; the 24-hour actual NOx emissionrate; starting on October 1,2003 non-ozone seasonal average NOx emission rates; number ofoperating hours perday; the number ofinvalid datahours ofthe total operating hours perday; the number of DERCs created and used each day in accordance with the appropriate emission rates and limits in this Trading Agreement and Order; the number ofDERCs in its possession and purchased (by serial numberifassigned) each month; the number ofDERCs used during the ozone season and non-ozone season (by serial number ifassigned); as well as documentation attesting to the fact that approved DERCs used during the ozone season were generated during the ozone season. Generatorcertification oftrus fact shall be sufficient. Pfizer shall maintain such records 

### in accordance with Section 22a-174-22 of the Regulations. Pfizer shall retain records and supporting documentation as described in this Trading Agreement and Order for a minimum offive years, commencing on the date suchrecords were created. Pfizer shall provide the records specified above to the Commissionerwithin thirty (30) days ofreceipt ofawrinen request from the Conunissioner.
BPfizerInc. Trading Agreement and OrderNo. 8093C

9. Armual Emission Statement. No laterthan March 1 ofevery year after issuance ofthis Trading Agreement and Order, Pfizer shall include with the ArulUal Emission Statement provided to the Commissioner, a record ofeach sale or othertransfer, and use ofany and all ofthe DERCs approved within and subsequent to issuance ofthis Trading Agreement and OrderJuntil all such DERCs have been used or are no longerin Pfizer's possession. Pfizer Shall also include actual. Ox emissions from each ofthe boilers and the amount ofall approved DERCs used (including serial numbers (ifassigned) and approved DERCs generated andlorpurchased from otherfacilities), generated and/or approved for the previous calendaryear. These reports shall be on a form prescribed by the Commissioner and shall be in monthly increments. Should Pfizerchoose to discontinue the generation ofDERCs, Pfizerwill notify the Commissionerupon discontinuance. 10. Allowance Use. Pursuant to Section 22a-174-22(d)(3) ofthe Regulations, Pfizermay use NOx allowances, pursuant to Section 22a·174-22(j) ofthe Regulations to achieve all or aportion ofthe reductions required by Section 22a-174-22 ofthe Regulations. Anyallowance used for compliance with Section 22a-174-22(e) ofthe Regulations shall be subject to all restrictions and/orrequirements applicableto DERCs contained in this Trading Agreement and Order. Each allowance used for compliance with Section 22a174-22 ofthe Regulations shall be equivalent to one discrete emission reduction credit and shall be deducted from Pfizer's NOx Budget Program compliance account upon such use. Allowances shall be considered used for compliance with Section 22a-174-22 ofthe Regulations when they are transferred. from the facility's compliance account or overdraft account to a State ofConnecticutNOx allowance retirement account, account ID CTOOOOOOO300 in the NOx Allowance Tracking System. 11. DERC Doubling. At a minimum, approved DERCs required for compliance with this Trading Agreement and Ordershall be adjusted upwards by 100% ifDERCs are not in Pfizer's possession for use priorto the first day ofeach month or applicable season. However, based on the gravity ofthe noncompliance, the Commissionermay require additional upward adjustment. 12. VintalZe Restriction. For the pwposes ofcompliance with Section 22aR 174-22 ofthe Regulations, DERCs/allowances shall only remain valid for five (5) calendaryears from the yearofthe generation/allocation ofsuch DERCs/allowances. DERCs/allowances generated/allocated more than five (5) calendaryears ago are not valid for use for compliance with Section 22a-174-22 ofthe Regulations. Notwithstanding the above the DERCs/alJowances generated/allocated prior to calendar year 2000 shall be valid for use until December 31, 2004.

9Pfizer lnc. Trading Agreement and OrderNo. 8093C



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' 13. Extension. No laterthan May 1, 2005, with respect to the boilers 5 and 8, Pfizer shall comply with the requirements ofSubdivision 22a-174-22(d)(l) ofthe Regulations. However, after full program review ofthis and otherTrading Agreements and Orders and, ifdetermined to be appropriate, the Commissionermay grant awritten extension of this Trading Agreement and Order. I 14. Future ComplianceReport. On orbefore September 1, 2004, Pfizer shall submit a report indicating how the facility shall comply with Section 22aM I74 M22 ofthe Regulations with respect to the boilers 5 and 8 on and afterMay I, 2005. IS. Full compliance. Pfizer shall notbe 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. 16. ADprovals. Pfizer shall use best efforts to submitto the Commissioner all documents required by this Trading Agreement and Order 

### in acomplete and approvable form. If the Commissionernotifies Pfizer that any document or other action is deficient, and does not approve it with conditions ormodifications, it is deemed disapproved, and Pfizer shall correct the deficiencies and resubmit it within the time specified by the Commissioner or, ifno time is specified bythe Commissioner, within 30 days ofthe 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 submitted orperformed or with such conditions ormodifications as the Commissionerdeems necessary to carry out the purposes ofthis Trading Agreement and Order. Nothing in this paragraph shall excuse noncompliance or delay. 17. Definitions. As used 

### in this Trading Agreement and Order, "ApprovedDERCs" are those for which the Commissionerhas provided written authorization for use in compliance with Section 22a-174-22 ofthe Regulations; "Commissioner" means the Commissioneror 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 Orderis deposited 

### in the U.S. mail orpersonally delivered, whichever is earlier. 18. Dates. The date ofsubmission to the Commissionerofany documentrequired by this Trading Agreement and Order shall be the date such document is received by the Commissioner. The date ofany notice by the CommissionerunderTrading Agreement and Order, including'but not limited to notice ofapproval ordisapproval ofany 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 otherwise specified in this Trading Agreement and Order, the word "day" as used in this Trading Agreement and Order means calendarday. Any document or action which is required by this Trading 10

## -. Pfizer Inc. Trading Agreement and Order No. 8093C



# J. .. Agreement and Order to be submitted orperformed by a date which falls on a Saturday, Sunday or a Connecticut or federal holiday shall be submitted orperformed by the next day which is not a Saturday, Sunday or Connecticut or federal holiday. 19. Certification ofdocuments. Any document, including but not limited to anynotice, which is requiredto be submitted to the Commissioner\Ulder this Trading Agreement and Order shall he 

### Signed hy Pfizer or, ifPfizeris not an individual, by an individual who is an authorized representative ofPtiler, in accordance with Section 22a-174-2a(a) ofthe Regulations ofCormecticut State Agencies, and bythe individual(s) responsible for actually preparing such document, and each such individual shall certify in writing as follows: 

### "1 have personally examined and am familiar \\ojth the information submitted in this document and all attachments thereto, and 

### 1cemfy, based on reasonable investigation, including my inquiry ofthose individuals responsible for obtaining the information. that the submitted information is true, accurate and**co~plete** to the best ofmy knowledge and belief. I understand that any false statementmade in the submitted information is punishable as a criminal offense under Section 53a-157b ofthe Connecticut General Statutes and any other applicable law." 20. Noncompliance. This Trading Agreement and Orderis a final orderofthe Commissioner with respect to the matters addressed herein, and is nonappealable and immediately enforceable. Failure to comply with this Trading Agreement and Order may subjectPfizerto an injunction and penalties. 21. False statements. Any false statement in any information submitted pursuantto this Trad.ing Agreement and Orderis punishable 

### as a criminal offense under Section 53a157b ofthe Connecticut General Statutes and any other applicable law. 22. Notice oftransfer; liability ofPfizer. Until Pfizerhas fully complied with this Trading Agreement and Order, Pfizer shall notifythe Commissionerin writing no laterthan 15 days after transferring all or anyportion ofthe facility, the operations, the site orthe business which is the subject

### ofthis Trading Agreement and Order or after obtaining a new mailing or location address. Pfizer's obligations under this Trading Agreement and Order shall not be affected by the passage oftitle to any property to any otherperson or municipality. 23. Commissioner's powers. Nothing in this Trading Agreement and Order shall affect the Commissioner's authority to institute any proceeding ortake 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, orfuture violations oflaw. 

### Ifat any 11

### Pfizer Inc. Trading Agreement and OrderNo. 8093C



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### time the Commissionerdetermines that the actions taken by Pfizerpursuant to this Trading Agreement and Orderhave not successfully corrected all violations, fully characterized the extent ordegree ofany pollution, or successfully abated orprevented pollution, the Commissionermay institute any proceeding to require Pfizer to undertake further investigation or further action to,prevent or abate violations orpollution. 24. Pfizer's oblilZationsunder law. Nothing in this Trading Agreement and Order shall relieve Pfizerofotherobligations under applicable federal, state and local law. 25. 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 Commissioner that the actions taken by Pfizerpursuant to this Trading Agreement and Orderwill result in compliance orprevent or abate pollution. 26. Access to facility. Any representative ofthe Department ofEnvironmental Protection may enterthe facility withoutpriornotice for the purposes ofmonitoring and eniorcing the actions required or allowedby this Trading Agreement and Order. 27. No effect onrights ofotherpersons. This Trading Agreement and Orderneithercreates nor affects any rights ofpersons ormunicipalities that are notparties to this Trading Agreement and Order. 28. No Creation ofProperty Rie:hts. This Trading Agreement and Order does not create anypropertyrights with respect to these BDERCs and DERCs. 29. Notice to Commissionerofchanges. Within 15 days ofthe date Pfizerbecomes aware ofa change 

### in any information submitted to the Commissionerunderthis Trading Agreement and Order, or that any such iniormation was inaccurate ormisleading,or that any relevant information was omitted, Pfizer shall submitthe correct oromitted information to the Commissioner. 30. Notification ofnoncompliance. In 

### the eventthat Pfizerbecomes aware that it did not or may not comply, ordid not ormay not comply on time, with any requirement ofthis Trading Agreement and Orderorofany docwnent required hereunder, Pfizer shall immediately notify by telephone the individual identified in the nextparagraph and shall take all reasonable steps to ensure that any noncompliance or delay is avoided or, ifunavoidable, is minimized to the greatest extentpossible. Within five (5) days ofthe initial notice, Pfizer shall submit in writing the date, time, and duration ofthe 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 Pfizer shall comply with any dates which may be approved in v,rr1ting by the Commissioner. Notification byPfizer shall not excuse noncompliance or delay, and 12PfizerInc. Trading Agreement and 

### Order o. 8093C



# "J'

'" the Commissioner's approval ofany compliance dates proposed shall not excuse noncompliance or delay unless specifically so stated by the Commissioner in writing. 31. Submission ofdocuments. Any documentrequired to be submined to the Commissionerunder this Trading Agreement and Order shall, unless otherwise specified in this Trading Agreement and Order orin writing by the Commissioner, be directed to:
.... 

### Mrs. ElizabethMcAuliffe Emissions Trading Unit Compliance and Field Operations Division 5th Floor Bureau ofAirManagement DepartmentofEnvironmental Protection 

### 79 Elm Street Hartford, Connecticut 

### 06106

13

### Pfizer Inc. Trading Agreement and OrderNo. 

### 8093C

Pfizerconsents to thejssuance ofthis 

### Trading Agreement and Order without further notice. The undersigned certifies that he/she is fully authorized to enter into this TradingAgreement and Order and to legallybind Pfizer to the terms and conditions ofthe TradingAgreement and Order. Pfizer, mc. 

# ,

Type arne: -lIl'-O:L!i....!!>le.t:t.ellSi'l<in 

### Type Title: Site Director 

### Date: Apr; 1 24, 2003



### Issued as a

### final order ofthe 

### CommissionerofEnvironmental 

### Protection



### on 

# 1fJ;(9 .2003 

# Cl;(did/ .Artllur 1. 

### Rocque, Jr. .' c6mmissioner 

### ///1 CITY OF GROTON LAND RECORDS MAILED CERTIFIED MAlL, RETIJRN RECEIPT REQUESTED 

### Certified DocumentNo. 

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