# STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

State ofConnecticut and Pfizer Inc. 

### ) ) ) ) 

### Trading Agreement and OrderNo. 8296

WHEREAS, the Commissioner ofEnviromnental Protection ("Commissioner") and Pfizer Inc. ("Respondent") agree thatthe Commissioner may issue a permit or order to allow emissions trading in accordance with Section 22a-174-22(j) ofthe Regulations ofConnecticut State Agencies ("Regulations") as a method ofcompliance with Section 22a-174-22 ofthe Regulations: A. Atthe request and with the agreement ofRespondent, the Commissioner finds the following: 1. This Trading Agreement and Order supersedes Trading Agreement and Orders 8093C and 

### 8136A and all subsequent modifications thereto. 2. Respondent is a corporation that owns and operates a pharmaceutical research and development facility at Eastern Point Road, Groton, Connecticut ("facility"). 3. Atthe facility, Respondent operates the emission units described in Tables 1 and 2 below, which are subject to Section 22a-174-22 ofthe Regulations ofCOlmecticut State Agencies ("Regulations") pertaining to the control ofNitrogen Oxide (NOx) emissions. 4. Forthe purposes ofthis Trading Agreement and Order, the following definitions shall apply:

a. Allowable Emission Limit (AEL): the applicable NOx emission limit set forth in Section 22a-174-22(e) or Section 22a-174-22(f) ofthe Regulations conesponding to each emission unit described in Tables 1 and 2 ofthis Trading Agreement and Order b. Allowance: CAIR NOx Ozone Season allowance originally allocated to a CAIR NOx Ozone Season unit, as defined in Section 22a-174-22c ofthe Regulations, located in the State ofConnecticut or a NOx allowance designated specifically for compliance during Ozone Season control periods and allocated to a CAIR NOx Ozone Season unit located in the State of Connecticut afterthe date ofissuance ofthis Trading Agreement and Order.

c. CAIRNOx Ozone Season unit: shall be as defined in Section 22a-174-22c of the Regulations d. CEMS: Continuous Emissions Monitoring System (Printed on Recycled Paper) 79 Elm Street • Hartford, CT 06106-5127 www.ctgov/dep An Equal Opportunity EmployerPfizerInc. 2 Trading Agreement and Order 8296
e. Discrete Emission Reduction Credit (DERC): a unit that was generated and approved by the Commissionerin accordance with a Trading Agreement and Order issued by the Commissioner or generated and approvedby the Commissionerin accordance with a protocol submitted and approved pursuant to Section 22a-1 74-38 ofthe Regulations. Such unit is equivalentto I ton of NOx emissions and maybe used for emissions trading in accordance with Section 22a-174-220) ofthe Regulations, subjectto the provisions ofPart B of this Trading Agreement and Order. f. Non-Attainment Area: means the geographic area which has been designated as nonattainmentpursuant to 40 CFR 8I in accordance with the provisions of 42 USC 7407 (Section 107 ofthe Act). Pursuant to 40 CFR 81.307, the designated ozone non-attainment areas in the State ofConnecticut are: the Greater Connecticut, CT area and the New York-NorthemNew Jersey-Long Island, NY-NJ-CT area. g. CArRNATS: "CArRNO, Ozone Season Allowance Tracking System" as defined in 40 CFR 96.302. h. Ozone Season: May I through September 30 ofeach calendaryear or such period as defined bythe U.S. Environmental Protection Agency, subsequentto the issuance ofthis Trading Agreement and Order.

I. Non-Ozone Season: the period ofconsecutive calendar months between two successive Ozone Seasons

Table I Non CAIR NOx Ozone Season Units Allowable Limits Ibs/MMBtn, nnless otherwise noted) UNIT- Fnel Heat Inpnt Allowable Emission Limit reg. or permit no. (MMBtn) (AEL) BoilerNo. I No.6 153 0.25 R-070-0007 Nat.Gas 0.20 BoilerNo. 2 No.6 153 0.25 R-070-0008 Nat.Gas 0.20 BoilerNo. 3 No.6 153 0.25 R-070-0009 Nat.Gas 0.20 BoilerNo. 4 No.6 220 0.25 R-070-0010 Nat.Gas 0.20PfizerInc. 

### 3 Trading Agreement and Order 8296

Table 2 CAIR NOx Ozone Season UnitsAllowable Limits IbslMMBtu, unless otherwise noted) UNIT- Fuel Heat Input Allowable Emission Limit reg. orpermit no. (MMBtu) (AEL) BoilerNo. 5 No.6 399.50 0.25 R-070-0012 Nat.Gas 399.50 0.20 5. The Respondent agrees that the actual NOx emissions rate from the emission units described in Tables 1 and 2, at times, exceed the corresponding AELs. 6. The Respondent and the Commissioner agree that, at times, the actual 24-hour, block average NOx emission rate from the emissions units described in Tables 1 and 2, maybe less than the corresponding AELs. At such times, the Respondentproposes to generate DERCs. 7. Pursuantto Section 22a-174-22(j) ofthe Regulations, Respondentproposes to comply with Section 22a-174-22(e) ofthe Regulations, when operating the emission units described in Tables 1 and 2 by means ofemissions trading in accordance with the provisions ofthis Trading Agreement and Order. 8. The Respondentproposes to use the actual 24-hour average emissions rate measured by CEMS for the purposes ofcalculating Actual DERCS generated and Actui;ll DERCslAllowances Required for the emissions units described in Tables 1 and 2. The Commissioner, in accordance with Section 22a-174-22(j) ofthe Regulations hereby allows Respondent to comply with Section 22a-174-22 ofthe Regulations at the facility through the use ofemissions trading, subject to the provisions ofthis Trading Agreement and Order. B. With the agreement ofRespondent, the Commissioner, acting under Sections 22a-6, 22a-174, 22a176, and 22a-l77 ofthe ConnecticutGeneral Statutes, hereby orders Respondent as follows: 1. Expiration ofthis Trading Agreement and Order: The Respondent may onlyuse emissions trading, subjectto the provisions ofthis Trading Agreement and Order, until the date of expiration ofthis Trading Agreement and Order. The date ofexpiration ofthis Trading Agreement and Order shall be the earlierof:

a. January 1, 2013; b. The date upon which the Respondent demonstrates to the Commissioner's satisfaction that actual NOx emissions from the emission unit, at all times, do not exceed the corresponding AEL(s);

c. The date specified in any written notice from the Commissioner stating that the Respondent is no longer allowed to use emissions trading due to the Respondent's violation ofany provision ofthis Trading Agreement and Order; orPfizerInc. 4 Trading Agreement and Order 8296 d. The date specified in any written notice from the Commissioner, notifying the Respondent that the Commissionerhas determined the use ofemissions trading as a compliance option has been furtherrestricted, modified ornullified by: (i) the promulgation ofan Act, Statute, or Regulations; or (ii) the issuance ofajudgment or court order. 2. Respondent shall obtain and use sufficientDERCs and/or Allowances in such a manner as to complywith Paragraphs B.7 and B.9 ofthis Trading Agreement and Order. All Allowances used must come from an emission unit that is within the same ozone nonattainment area as the Respondent. Any Allowances used to comply with this Trading Agreement and Ordermust be allocated for the control period that occurs during the same year those allowances are used for compliance with this Trading Agreement and Order. All DERCs used during the Ozone Season for the emissions units described in Table I, shall have been generated during an Ozone Season by the operation ofan emission unit that is not a CAIR NOx Ozone Season unit, as defined in Section 22a-174-22c ofthe Regulations. All DERCs used during the Ozone Season for the emissions units described in Table 2, shall have been generated during an Ozone Season. 3. Priorto using Allowances in accordance with Paragraphs B.7 and B.9 ofthis Trading Agreement and Orderthe Respondent shall obtain a General Account or Compliance Account in the CAIR NATS. 4. Vintage Restriction. Forthe purposes ofcompliance with Section 22a-174-22 ofthe Regulations and the provisions ofthis Trading Agreement and Order, DERCs shall only remain valid for five (5) calendaryears from the year ofthe generation ofsuch DERCs. DERCs olderthan five (5) calendaryears from their creation are not valid for use for compliance with Section 22a-174-22 ofthe Regulations and the provisions ofthis Trading Agreement and Order 5. Ozone Season Fuel Use Restriction: Notwithstanding the provisions ofParagraph B.2 ofthis Trading Agreement and Order, when operating the emission units described in Tables I and 2 during the Ozone Season, the Respondent shall operate those units while firing or co-firing the lowestNOx emitting fuel type or combination offuel types that the units are authorized to bum in accordance with Departmental permit, registration, or applicable regulation. 6. Notwithstanding Paragraph B.5 ofthis Trading Agreement and Order, during the Ozone Season, the Respondent may operate the emission units described above on fuels that result in higher emissions ofNOx, ifeither:

a. the availability offuel oil that complies with Paragraph B.5 is inadequate to meet the needs ofresidential, commercial and industrial users in this state and that such inadequate supply constitntes an emergency; or b. the supply ofgaseous fuels to the emission units is interrupted due to inadequate supply or in accordance with an interruptible supply agreementbetween the Respondent and the gaseous fuel supplier.Pfizer Inc. 5 Trading Agreement and Order 8296 7. DERC/ Allowance Use. On the first day ofeach calendar month, the Respondent shall possess a quantity ofDERCs and/or Allowances that equals or exceeds the quantity ofActual DERCs Required and/or Actual Allowances Required in that month. Compliance with Paragraph B.7 ofthis Trading Agreement and Order shall be determined as follows:

a. Before the first day ofeach month, Respondent shall estimate DERCs and/or Allowances required for such calendar month for each emission unit described in Tables I and 2 as follows: Estimated DERCs/Allowances Reguired = {(Estimated fuel use in MMBtu) x ((estimated 24-hr average emission rate lb/mmbtu)

- (0.95 x AEL))}+2000 lbs/ton Where:

• AEL = Allowable Emission limit, as defined in Paragraph A.4 ofthis Trading Agreement and Order

• Discount (0.95) 

## =5% design margin applied to the AEL. b. No later than the twentieth day ofeach month, Respondent shall calculate actual DERCs and/or Allowances used in the preceding calendar month for each emission unit described in Tables I and 2 as follows:

Actual DERCs/Allowances Reguired 

## = L{(Daily fuel use MMBtu) x ((actual 24-hr average emission rate lb/mmbtu)

- (0.95 x AEL))} + 2000 lbs/ton For all days in the month where actual 24-hr average emissions rate> AEL

8. DERC Generation. No later than the twentieth day ofeach month, Respondent shall calculate actual DERCs generated in the preceding calendar month for each emission unit described in Tables I and 2 as follows: Actual DERCs Generated {Table I emission units (year-round) and Table 2 emission uniteduring ozone season only)} = L{(Daily fuel use MMBtu) x ((AEL)

- actual24-hr average emission rate lb/mmbtu)} + 2000 lbs/ton For all days in the month where actual 24-hr average emissions rate 

### < AEL Where: Daily fuel use and actual 24-hr average emission rate shall not include missing data calculated in accordance with any missing data substitution procedures, including those allowed under Section 22a-174-22c ofthe Regulations and 40 CFR Part 75.PfizerInc. 

### 6 Trading Agreement and Order 8296

9. Non-Ozone Season DERC/Allowance Use. In addition to the requirements ofParagraph 8.7 ofthis Trading Agreement and Order, on the first day ofeach Non-Ozone Season, the Respondent shall possess a quantity ofDERCs and/or Allowances that equals or exceeds the quantity ofNon- Ozone Season Actual DERCs/Allowances Required for that Non-Ozone Season. Compliance with Paragraph 8.9 ofthis Trading Agreement and Order shall be determined as follows:

a. Before the first day ofeach Non-Ozone Season, Respondent shall estimate DERCs and/or Allowances requircd for thatNon- Ozone Season for the emission unit described in Table 2 based on the average actual NOx emission rate from the emission unit and an emission limit of0.15 Ib/mmbtu as follows: Estimated Non-Ozone Season DERCs/Allowances Required = {(EstimatedNon-Ozone Season fuel use in MMBtu) x «estimated average NOx Emission Rate Ib/mmbtu)

- (0.95 x O.l5Ib/mmbtu»)} + 2000 Ibs/ton b. No laterthan thirty (30) days afterthe end ofeach Non-Ozone Season, the Respondent shall calculate Actual Non-Ozone Season DERCs and/or Allowances used by Table 2 emission units during thatNon-Ozone Season for each emission unit as follows: Actual Non-Ozone Season DERCs/Allowances Required 

## = {(Actual Non-Ozone Season fuel use in MMBtu) x «Non-Ozone Season Average Actual NOx Emission Rate Ib/mmbtu)

- (0.95 x 0.15 Ib/mmbtu»)} +2000 Ibs/ton

-**~(DERCS** and/or Allowances Required for all months ofthe Non-Ozone Season calculatedpursuant to Paragraph 8.7) 10. Non-Ozone Season DERC Generation. No laterthan the thirty (30) days after the end ofthe Non-Ozone Season, Respondent shall calculate actual DERCs generated during the NonOzone Season by the emission unit described in Table 2 as follows: {Non-Ozone Season fuel use (MMBtu) x [(0.15 Ib/mmbtu)

- Non-Ozone Season average emission rate (Ib/mmbtu)]} + 2000 Ibs/ton Where: Non-Ozone Season Average Emission Rate < O.l5Ib/mmbtu; and Non-Ozone Season fuel use and Non-Ozone Season Average Emission rate shall not include missing data calculated in accordance with any missing data substitution procedures, including those allowed under Section 22a-174-22c ofthe Regulations and 40 CFR Part 75. II. The Respondent shall retire ten (10) percent ofall DERCs (tons) generated by the emission units identified in Tables I and 2, priorto use, and permanently remove them from all calculations ofavailable DERCs on a monthly ornon-ozone season basis to assure abenefitto the enviromnent.PfizerInc. 7 Trading Agreement and Order 8296
12. On orbefore January 31 ofeach calendaryear, the Respondent shall deduct a quantity of DERCS from the currentbalance ofDERCs possessedby the Respondent and/or transfer a quantity ofAllowances from the Respondent's NOx General and/or Compliance Accounts to the CT State NOx Retirement Account (Account ID CT0000000300 in the CAIR NATS) such that the total is equal to the sum of(Actual DERCs/Allowances Required determined pursuant to Paragraph B.7 for the preceding calendaryear)

- 0.9*(Actual DERCs Generated determined pursuantto B.8 during the preceding calendaryear), rounded up to the nearest whole ton. 13. Not more than thirty (30) days afterthe completion ofthe Non-Ozone Season, the Respondent shall deduct a quantity ofDERCS from the currentbalance ofDERCs possessedby the Respondent and/ortransfer a quantity ofAllowances from the Respondent's NOx General Accountto the CT State NOx Retirement Account (Account ID CT0000000300 in the CAIR NATS) such that the total is equal to 0 or (Actual Non-Ozone Season DERCs/Allowances Required for the most recently completed Non-Ozone Season)

- 0.9*(Actual DERCs Generated in the mostrecently completed Non-Ozone Season), whichever is greater. Notwithstanding the control period limitations ofParagraph B.2 ofthis Trading Agreement and Order, Allowances used to comply with this Paragraph for a Non-Ozone Season must have been originally allocated for the control periods that correspond to the same calendar years within that Non-Ozone Season. 14. Doubling: Ifthe Actual DERCs/Allowances Required for any month, determined in accordance with Paragraph B.7, exceeds the quantity ofDERCs and/or Allowances in the Respondent's possession on the first day ofthat month, then in addition to the deduction or transfer specified in Paragraphs B.12, the Respondent shall also deduct a quantity ofDERCs from the currentbalance ofDERCs possessed bythe Respondent and/or transfer a quantity of Allowances from the Respondent's NOx General and/or Compliance Accounts to the CT State NOx Retirement Account (Account ID CT0000000300 in the CAIRNATS) such that the total is equal to (Actual DERCs/Allowances Required for the that month)

- 0.9*(Actual DERCs Generated in that month). Such additional DERC deduction orAllowance transfer shall be performed at the same time as any DERC deduction and/or Allowance transfer specified in Paragraph B.12 ofthis Trading Agreement and Order. Ifthe Actual DERCs/Allowances Required for any Non-Ozone Season, determined in accordance with Paragraph B.9, exceeds the quantity ofDERCs and/or Allowances in the Respondent's possession on the first day ofNon-Ozone Season, then in addition to the deduction ortransfer specified in Paragraphs B.13, the Respondent shall also deduct a quantity ofDERCs from the currentbalance ofDERCs possessedby the Respondent and/or transfer a quantity ofAllowances from the Respondent's NOx General Accountto the CT State NOx Retirement Account (Account ID CT0000000300 in the CAIRNATS) such that the total is equal to 0 or (Actual Non-Ozone Season DERCs/Allowances Required for the mostrecently completed Non-Ozone Season)

- 0.9*(Actual DERCs Generated in the mostrecently completed Non-Ozone Season), whichever is greater. Such additional DERC deduction or Allowance transfer shall be performed at the same time as any DERC deduction orAllowance transfer specified in Paragraph B.13 ofthis Trading Agreement and Order. Notwithstanding the provisions ofParagraph B.14 ofthis Trading Agreement and Order, any violation ofParagraphs B.7 and B.9 ofthis Trading Agreement and Ordermay be subjectto additional enforcement action as may be deemedappropriate by the Commissioner inPfizerInc. 8 Trading Agreement and Order 8296 accordance with the Department's enforcementresponse policy. 15. Atthe end ofeach calendaryear, the Respondent shall demonstrate that anyAllowances used for compliance with this Trading Agreement and Orderduring the year are surplus, quantifiable, enforceable and permanent. This shall be determined by demonstrating that the actual NOx emissions during the ozone season, as reported to the United States Environmental Protection Agency, from the emission nnitto which the Allowances were originally allocated were equal to or less than the amount ofAllowances allocated to snch unitby the State of Connecticut minus the Allowances used for compliance with this Trading Agreement and Order. 16. Maintenance and Tune-up. Not more than 18 months from the date ofissuance ofthis Trading Agreement and Order, the Respondent shall perform maintenance and inspection ofeach emission unit listed in Tables I and 2. Such maintenance and inspection shall include, butnot be limited to, the following:

a. Inspectthe combustion system, and clean orreplace any components ofthe combustion system as necessary, in accordance with manufacturer's specification or current good engineering practice; b. Inspectthe system controlling the air-to-fuel ratio, and ensure that it is calibrated or functioning in accordance with the manufacturer's specifications orcurrent good engineering practice;

c. Measure the NOx and O2parameters ofthe emission unitused to determine that the emissionunitis operating in accordance with manufacturer's specification or currentgood engineering practice priorto and after any adjustments are made during maintenance, tune-up, orinspection activity; d. Make and keep records including, but not limited to, the following: i. Demonstration that any maintenance, tune-up, and/or inspection activity performed on the emission unitsdescribed in Tables I and 2 in accordance with Paragraph B.l6 ofthis Trading Agreement and Order has been performed in accordance with the manufacturer's specifications orcurrent good engineering practice,

n. The date and a description ofany maintenance, tune-up, and/or inspection activity performed on the emission units described in Tables I and 2 in accordance with Paragraph B.l6 ofthis Trading Agreement and Order,

Ill. The name, title and affiliation ofthe person conducting any maintenance, tune-up, and/or inspection activity performed on the emission units described in Tables I and 2 in accordance with Paragraph B.16 ofthis Trading Agreement and Order, iv. The NOx and O2parameters ofthe emission unit used to determine that the emission unit is operating in accordance with manufacturer'sPfizerInc. 

### 9 Trading Agreement and Order 8296

17. Record Keeping; specification orcurrent good engineering practice priorto and after any adjustments are made during maintenance, tune-up, orinspection activity performed in accordance with Paragraph B.16 ofthis Trading Agreement and Order.

a. By the close ofeach calendar day, the Respondent shall record the actual 24-hour average NOx emission rate for any emissionunit equipped with an approved CEMS and the actual fuel type and the actual quantity ofeach lype offuel in units ofvolume per day orMMbtu per day for each fuel used on the preceding day in any ofthe emission units described in this Trading Agreement and Order; b. On ofbefore the first day ofeach calendar month, the Respondent shall record the number ofDERCs and corresponding serial numbers and vintagesJor all DERCs in its possession on the first calendarday ofthat calendarmonth,

c. On orbefore the first day ofeach calendarmonth, the Respondent shall record the number ofAllowances and corresponding identification numbers and allocation control periods for all Allowances in its possession on the first calendar day ofthat calendarmonth, d. On orbefore the first day ofeach calendarmonth, the Respondent shall record the number ofDERCs and corresponding serial numbers, vintages, purchasc/sales dates, and sellerlbuyerfor all DERCs purchased or sold during the preceding calendarmonth,

e. On orbefore the first day ofeach calendarmonth, the Respondent shall record the number ofAllowances and corresponding identification numbers, purchase/sales dates, allocation years, and sellerlbuyer for all Allowances purchased or sold during the preceding calendarmonth, f. On orbefore the first day ofeach calendarmonth, the Respondent shall record the Estimated DERCs/ Allowances Required for that calendarmonth determined in accordance with Paragraph B.7 ofthis Trading Agreement and Order. g. On orbefore the twentieth calendarday ofeach calendarmonth, the Respondent shall record the Actual DERCs/Allowances Required for the preceding calendarmonth determined in accordance with Paragraph B.7 of this Trading Agreement and Order; h. On orbefore the twentieth calendar day ofeach calendarmonth, the Respondent shall record the Actual DERCs/Allowances Generated for the preceding calendar month determined in accordance with Paragraph B.I0 of this Trading Agreement and Order and DERCs retired for environmental benefit in accordance with paragraph B.II ofthis Trading Agreement and Order;

l. On orbefore January 31 ofeach calendaryear, the Respondent shall recordPfizerInc. 10 Trading Agreement and Order 8296 the quantity ofDERCs deducted in accordance with Paragraphs B.12 and B.l4 ofthis Trading Agreement and Order for the preceding month. Such records shall include the serial number and vintage ofeach DERC deducted from the Respondents currentbalance pursuantto Paragraphs B.12 and B.l4 ofthis Trading Agreement and Order. 

### j. On orbefore January 31 ofeach calendaryear, the Respondent shall record the quantity ofAllowances transferred in accordancewith Paragraphs RI2 and RI4 ofthis Trading Agreement and Order. Suchrecords shall include the identification number and allocation control period ofeach Allowance transferred pursuant to Paragraphs B.l2 and RI4 ofthis Trading Agreement and Order. 

### k. Not more than thirty (30) days afterthe completion ofeach Non-Ozone Season, the Respondent shall record the Non-Ozone Season average NOx emission rate for the emissions unit described in Table 2, the quantity DERCs and/or allowances possessed on the first day ofthe Non-Ozone Season, the quantity ofDERCs deducted and/or Allowances transferred in accordance with Paragraphs Rl3 and B.l4 ofthis Trading Agreement and Order, the quantity ofDERCs generated in accordance with Paragraph RIO ofthis Trading Agreement and Order, and the quantity ofDERCs generated during the Non-Ozone Season and retired for environmental benefit in accordance with Paragraph B.II ofthis Trading Agreement and Order; I. For each month ofthe Ozone season, the Respondent shall maintain records attesting to the fact that any DERCs deducted from its balance in accordance with Paragraphs RI2 and B.l4 ofthis Trading Agreement and Order satisfY the requirements ofParagraph R2. Generatorcertification of this fact shall be sufficient.

m. On each day during the ozone season that the Respondent operates in accordance with Paragraph R6 ofthis Trading Agreement and Order, the Respondent shall make and keep Records ofall emission unit operation in accordance with Paragraph R6 ofthis Trading Agreement and Order, including copies ofany written correspondence from the Respondent's fuel supplier detailing the duration and circumstances ofthe inadequate fuel oil supply or interruption ofgaseous fuel supplyto the emission units. 18. Respondent shall retain records and supporting documentation required by this Trading Agreement and Order for a minimum offive years, commencing on the date such records were created. Respondent shall provide the records specified above to the Commissioner within thirty (30) days ofreceipt ofa written request from the Commissioner. All records shall be maintained in accordance with Sections 22a-174-4 and 22a-174-22 ofthe Regulations. 19. Reporting: No laterthan March I ofevery year after issuance ofthis Trading Agreement and Order, the Respondent shall submitto the Commissioner a written report containing copies of all ofthe records required pursuantto Paragraphs R17.a

- B.l7.j, B.17.! and R17.m ofthis Trading Agreement and Order. Not laterthan July 30 ofeach calendaryear, the Respondent shall submit a written report containing copies ofall records requiredpursuant to Paragraph R17.k ofthis Trading Agreement and Order. The Commissionermayprescribe the forms to be used for the submission ofthese reports. The Respondent shall submit these reports on such forms, ifprescribedby the Commissioner.Pfizer Inc. 

### 11 Trading Agreement and Order 8296 20. Full compliance. Respondent shall notbe considered in full compliance with this Trading Agreement and Orderuntil all actions required by this Trading Agreement and Orderhave been completed as approved and to the Commissioner's satisfaction. 21. Approvals. Respondent shall use best efforts to submitto the Commissioner all documents required bythis Trading Agreement and Order in a complete and approvable form. Ifthe Commissionernotifies Respondent that any document or other action is deficient, and does not approve it with conditions ormodifications, itis deemed disapproved, and Respondent shall correctthe deficiencies and resubmit it within the time specifiedby the Commissioner or, ifno time is specifiedby the Commissioner, within 30 days ofthe Commissioner's notice ofdeficiencies. In approving any document or other action lUlder this Trading Agreement and Order, the Commissioner may approve the document or other action as submitted or performed or with such conditions ormodifications as the Commissioner deems necessary to carry out the purposes ofthis Trading Agreement and Order. Nothing in this paragraph shall excuse noncompliance or delay. 22. Definitions. As used in this Trading Agreement and Order "Commissioner" means the Commissioner or a representative ofthe Commissioner; The date of"issuance" ofthis Trading Agreement and Order is the date the Trading Agreement and Order is deposited in the U.S. mail orpersonally delivered, whichever is earlier. 23. Dates. The date ofsubmission to the Commissionerofany document required by this Trading Agreement and Order shall be the date such document is received by the Commissioner. The date ofany notice by the Commissionerunder Trading Agreement and Order, including butnot limitedto notice ofapproval or disapproval 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 Agreement and Orderto be submitted orperformedby a date which falls on a Saturday, Sunday or a Connecticut or federal holiday shall be submitted orperformedby the next day which is not a Saturday, Sunday or Connecticut or federal holiday. 24. Certification ofdocuments. Any document, including butnot limited to any notice, which is required to be submitted to the Commissionerunder this Trading Agreement and Order shall be signedbythe Respondent or, ifRespondent is not an individual, by an individual, employed by the Respondent, who satisfies the criteria set forth in Section 22a-174-2a(a)(I) ofthe Regulations ofConnecticut State Agencies and by the individual(s) responsible for actually preparing such document. Each individual who signs documents in accordance with this Paragraph shall certify 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 ofthose individuals responsible for obtaining the information, that the submitted information is true, accurate and complete to the best ofmy knowledge and belief. Iunderstand that any false statement made in the submitted information may be punishable as a criminal offense under Section 53a-157b ofthe Connecticut General Statutes and any other applicable law."PfizerInc. 12 Trading Agreement and Order 8296 25. Noncompliance. This Trading Agreement and Order is a final order ofthe Commissioner with respect to the matters addressed herein, and is nonappealable and immediately enforceable. Failure to comply with this Trading Agreement and Ordermay subject Respondent to an injunction and penalties. 26. False statements. Any false statement in any information submittedpursuant to this Trading Agreement and Ordermay be punishable as a criminal offense under Section 53a-157b ofthe Connecticut General Statutes and any other applicable law. 27. Notice oftransfer; liability ofRespondent. Until Respondent has fully complied with this Trading Agreement and Order, Respondent shall notifY the Commissioner in 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 Order or after obtaining a new mailing or location address. Respondent's obligations under this Trading Agreement and Order shall notbe affected bythe passage oftitle to anyproperty to any otherperson or municipality. 28. 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 for past, present, or future violations oflaw. Ifat anytime the Commissionerdetermines that the actions taken by Respondent pursuantto this Trading Agreement and Orderhave not successfully corrected all violations, fully characterized the extent or degree ofany pollution, or successfully abated orpreventedpollution, the Commissionermay institute anyproceeding to require Respondent to undertake further investigation or further action to prevent or abate violations orpollution. 29. Respondent's obligations under law. Nothing in this Trading Agreement and Order shall relieve Respondent ofother obligations under applicable federal, state and local law. 30. No assurance by Commissioner. No provision ofthis Trading Agreement and Order and no action or inaction by the Commissioner shall be construed to constitute an assurance bythe Commissionerthat the actions takenby Respondent pursuantto this Trading Agreement and Orderwill result in compliance orprevent or abate pollution. 31. Access to premises. Any representative ofthe Department ofEnvironmental Protection may enterthe withoutprior notice for the purposes ofmonitoring and enforcing the actions required or allowed by this Trading Agreement and Order. 32. No effect on rights ofotherpersons. This Trading Agreement and Orderneither creates nor affects any rights ofpersons or municipalities that are notparties to this Trading Agreement and Order. 33. No Creation ofProperty Rights. This Consent Order does not create any property rights with respect to these DERCs orAllowances.PfizerInc. 13 Trading Agreement and Order 8296

34. Notice to Commissionerofchanges. Within IS days ofthe date Respondentbecomes aware ofa change in any information submitted to the Commissionerunder this Trading Agreement and Order, orthat any such information was inaccurate ormisleading or that anyrelevant information was omitted, Respondent shall submitthe correct or omitted information to the Commissioner. 3S. Notification ofnoncompliance. In the eventthat Respondentbecomes aware that it did not or may not comply, or did not ormaynot comply on time, with any requirement ofthis Trading Agreement and Order or ofany documentrequired hereunder, Respondent 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 (S) days ofthe initial notice, Respondent 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 of the Commissioner, dates bywhich compliance will be achieved, and Respondent shall complywith any dates which maybe approved in writing by the Commissioner. Notification byRespondent shall not excuse noncompliance or delay, and the Commissioner's approval of any compliance dates proposed shall not excuse noncompliance or delayunless specifically so statedby the Commissioner in writing. 36. Submission ofdocuments. Any document required to be submitted to the Commissioner under this Trading Agreement and Order shall, unless otherwise specified in this Trading Agreement and Order or in writing bythe Commissioner, be directed to:

Supervisor Administrative Enforcement Group Engineering and EnforcementDivision Bureau ofAirManagement DepartmentofEnvironmental Protection 79 Elm Street, Sth Floor Hartford, Connecticut 06106 (860) 424-3702PfizerInc. 14 Trading Agreement and Order 8296 Respondent consents to the issuance ofthis 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 Respondent to the terms and conditions ofthe Trading Agreement and Order. 

# /7 Respondent Signature: 

# C

# tf~**~~./)** Type Name: Cameron Mackenzie P.E., Executive Director Type Title: PfizerInc, Global Operations, East Area Date: April 26, 20I0

Issued as a final consent order ofthe Commissioner ofthe Department ofEnvironmental Protection. 

## 04 

# -.2.7-

- :Lore Date

. Ro e Director Engi eering & Enforcement Division Bureau ofAir Management

CITY OF GROTON MAILED CERTIFIED MAIL, RETURN RECEIPT REQUESTED Certified DocumentPfizerInc. 15 Trading Agreement and Order 8296

[Note: This sheet is not apart ofthe order and is only attached to the original order which is retained in separate DEP files which are accessible to the public with close supervision. The order mustbe mailed to the Userby certified mail, return receipt requested. Ifthe User is abusiness, send a certified copy to the attention ofaperson atthe business.] Certification ofMailing On ,2010, at

_ A.M./P.M., I mailed a certified copy ofTrading Agreement and OrderNo. 8296 to the following, by placing it in the [U.S. mail/interdepartmental mail]:

On ,2010, at

_ A.M./P.M., I mailed aplain copy ofTrading Agreement and OrderNo. 8296 to the following, by placing it in the [U.S. mail/interdepartmental mail]:

Signature: Name: Title: Date: