SIP DESCRIPTION -Pfizer-Tradine Aereement and Order Nn. 8093C Mndification I I. SIP

- DESCRIPTION OF DERC CREATION AND/OR USE SIP SUMMARY TABLE Tradio2 A2reement and Order No. 8093C PfIZer 445 Eastern Point Rd Groton, CT06340 Identifier Client

### £2. Town # 70 Premise # Sequence # 1 Contact Mr.Edward L. Brennan, Tel: (860) 441-6224 Fax (860) 441- 1493 Manager Environmental Health and Safety Edward.brennanla>.ofizer.com Pollutant and Regulatory Standard: NOx 

### I Section 22a-174·22 ofthe Regulations of Connecticut State Agencies. Nonattainment Area Classification Serious Annual DERCs Deeded Estimated <1 ozone and >5 non-ozone. Compliance Time Period Until April 30, 2007. Max. Emission Rate: CEM and full load emission rate (FLER) for Generation and Use. (See Table I below):

Table 1 Pfizer NOx Emission Rates and Allowable Limits in IbsIMM.Btu Unit: OEP Fuel Heat Emission FLER Allowable Date of Next Permit # Input Test Rate Generation Limits Stack Stack

Re•. # and Use Test Test Due Boiler 5 No.60il 399 CEM See 0.25 N/A N/A R070-012 No.2 Oil 399 CEM calculation 0.20 Nat. Gas 399 CEM in order 0.20 Boiler 8 No.60il 266 CEM See 0.25 N/A N/A R070-00l No. 2011 266 CEM calculation 0.20 Nat. Gas 266 CEM in order 0.20

II. SPECIAL REQUIREMENTS



### a. Calculations ofcredits used or generated shall be as specified in Trading Agreement and OrderNo. 8093C issued on April 29, 2003. 

### b. Pfizer is aBudget sources that shall meet anon-ozone season average emission limit of 0.15 IblMMBlU.



### c. Future Compliance Report. On orbefore September 1, 2006, Pfizer shall submit areport in writing to the Commissioner, as directed in tl:Jis Trading Agreement and Order, indicating how the facility shall comply with Section 22a-174-22 ofthe 

### Regulations with respect to the boilers 5 and 8 on and after May I, 2007.

# STATE OF CONNECTICUT 

# ,,y. DEPARTMENT OF ENVIRONMENTAL PROTECTION**,-..~...p** 5TATE OF CONNECTICUT AND PFIZER INC TRADING AGREEMENT AND ORDER NO. 8093C MODIFICATION NO. I

TRADING AGREEMENT AND ORDER MODIFICATION In the matter ofaTrading Agreement and Orderbetween the Commissioner ofEnvironmental Protection ("Commissioner") and PfizerInc. ("Pfizer"). WHEREAS, the Commissioner and Pfizer, having agreed to the tenns and conditions set forth in Trading Agreement and Order No. 8093C signed by the Commissioneron April 29, 2003, do now, by mutual agreement, modify saidTrading Agreement and Order

### as follows: I. Delete the dates May 1,2005, and substitute therefor May I, 2007, in paragraph A.6.



### , 

# ,. 2. Delete the date May 1, 2005, and substitute thereforMay 1,2007, in paragraphs A.lO., Cl., C2., C3.a., C.3.b., C.3.c., C.3.e., C.3.f., and C.6.

I 3. Delete paragraph C.6.b. and substitute the following therefor: During the non-Olone season: 

### In addition to meeting the 24-houremission limit in Table 22-1 ofSection 22a174-22 

### ofthe Regulations, Pfizershall meet a non-ozone season average emission limit of0.15 IblMMBtu. Prior to October 1, 2004, October I, 2005, and October 1, 2006, Pfizer shall estimate and acquire the amount ofDERCs or alJowances required for such non-ozone season needed to comply with Section 22a-174-22(e)(3) ofthe Regulations 

### as follows: Estimated DERCs (tons) 

### = [Estimated fuel use in MMBtu from October 1 through April 30 x (lower ofthe estimated seasonal average NOx emission rate or the proportioned 24- hour allowable emission limit in IblN:llvfBtu during October 1 through April 30

- (0.95 x 0.15 IblMMBtu))] + 2000 pounds/ton. No later than May 31, 2005, May 31, 2006, and May 31,2007, in addition to the DERCs retired pursuant to paragraph C.6.a. ofthis Trading Agreement and Order, Pfizershall calculate and peI1T1anently retire DERCs used in the preceding non-ozone season as follows: (Printed on Recycled Pipet) 79 Elm Street • Hanford, CT 06106·5127 llllp:lldep.Slate,ct.us An Equal Opporrunit'f £mplO'ftr

### PfizerInc. 2 

### Trading Agreement and Order No. 8093C Modification No. I 

# o

Actual DERCs (tons) ; [Actual fuel use in MMBtu from October I through 

### April 30 x (lower ofthe actual seasonal average NOx emission rate or the proportioned 24-hour allowable emission 

### limit in IblM:M:Btu during October 1through April 30

- (0.95 , 0.15 IblMMBtu))] + 2000 pounds/ton. 4. Delete paragraph C.9. and substitute the following therefor: 

### Annual DERC Report and Non-Ozone Season Emission Statement. No later than March I for the previous calendar year andJuly 30 (for the Octoberthrough April 

### time period only starting in 2004) ofevery yearafterissuance ofthis Trading Agreementand Order, Pfizershall submit in 

### writing to the Commissioner, a recordofeach sale orothertransfer, and use ofany and all ofthe DERCs approved within and subsequentto issuance ofthis Trading Agreemem and Order until all such DERCs have been used or are no longerin Pfizer's possession. Pfizershall also include actual NOx emissions from the boilers and the amount of all DERCs used (including serial numbers (ifassigned) and approved DERCs 

### generated and/orpurchased from otherfacilities), generated and/or approved for the previous calendar year and October lhrough April time period. These reports shall be on a form prescribed bythe Commissioner and shall be in monthly 

### increments, andby ozone and non-ozone seasons. 5. Delete paragraph C.ll. and substitute the following therefor: DERC Shortfall. At aminimum', DERCs required shall be adjusted upwards by 

### 100% ifDERCs are notin Pfizer's possession for use prior to the first day ofeach month or applicable season. However, nothing in this Trading Agreementand Ordershall affect the Commissioner's authority to institute any proceeding or take any other action to require additional upward adjustment, basedon the gravityof any alleged noncompliance or violation oflaw. Pfizer shall permanently retire the quantityofDERCs equivalentto the excess emissions plus a 100% premium within sixty (60) days ofPfizer's discovery oftheDERC shortfall. Pfizershall 

### certify andreport any suchDERC retirement to the Commissioner in 

### accordance with paragraph C.30 ofthis Trading Agreement and Order. 6. Delete paragraph C.13. and substitute the following therefor: 

### Extension. No later than May 1,2007, with respect to the boilers 5 and 8, Pfizer shall comply with the requirements ofSections 22a-174-22(d)(I) and 22a-174- 22(d)(2)(A) ofthe Regulations. There is no assurance that after full program 

### review ofthis and otherTrading Agreements and Orders that the Commissioner <j



# --

### ,- I

........**~.** Pfizer Inc. 

### 3 Trading Agreement and Order No. 8093C Modification No. I 

### will grant a written extension ofthis Trading Agreement and Order. 7. Delete paragraph C.14. and substitute the following therefor: Future Compliance Report. On orbefore September I, 2006, Pfizershall submit a 

### repon in writing 

### to the Commissioner, 

### as directed in paragraph C.31. ofthis Trading Agreement and Order, indicating how the facility shall comply with 

### Section 22a-174-22 ofthe Regulations with respect to the boilers 5 and 8 on and afterMay 1,2007. 8. Delete paragraph C.17. and substitute the following therefor: 

### 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 arepresentative ofthe Commissioner; "Non-olone season" means the period from October 1through April 30 in any given calendar year. 9. Delete paragraph C.18. and substitute the following therefor: Dates. 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, whicheveris earlier. The date ofsubmission to the Commissionerof any documentrequired by this Trading Agreement and Order shall be the date 

### such document is received by the Commissioner. The date ofany notice by the Commissionerunderthis Trading Agreement and Order, including butnot limited to 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 Ordermeans calendarday. 

### Any document or action which is required 

### by this Trading Agreement and Order to be submitted orperformed by adate which falls on aSaturday, Sunday ora Connecticut or federal holiday shall be submitted orperformed by the next day which is not aSaturday, Sunday orConnecticut or federal holiday. 

### 10. Delete the word "individual" and substitute therefor the word "Unit" in paragraph C.30. 11. Delete the name ''Mrs. Elizabeth McAuliffe" from paragraph C.3I.PfizerInc. 

### 4 Trading Agreement and Order No. 8093C Modification No.1 All other tenns and conditions ofTrading Agreement and Order no. 8093C issued by [he Commissioner acting under Chapter446c, Sections 22a-6, 22a-171, 22a-174, 22a-176, and 22a177 ofthe Connecticut General Statutes shall remain in effect Pfizer hereby consents to the entry ofthis modification to the Trading Agreement and Order without funher notice. Pfiz Signature: 

### Type Name: Type Title: Date: Sj 

### te Dj 

### rector

Issued as a modification ofan Order ofthe Commissioner ofEnvironmental Protection.

Date

MAILED CER1IFIED MAll.,

RETURN RECEIPT REQUESTED CertifiedDocument No.