# STATE ,OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION

In the matter of 

### The State ofConnecticut and PfizerInc. ) ) 

# l ) ) 

### TRADING AGREEMENT AND ORDER NO. 8093B

WHEREAS, the CommissionerofEnvironmental Protection ("Commissioner") and Pfizer Inc. ("Pfizer"), having agreed to the terms and conditions set forth in Trading Agreement and 

### OrderNo. 8093A issued on April 29, 1999, do now, by 

### mutual agreement, supersede said Trading Agreement and Order as follows: A. At the request and with the agreement ofPfizer, the Commissioner finds the following:

79 Elm 1.

2.

3.

4.



### 5. Pfizer is a corporation which owns and operates a pharmaceutical production and research facility at Eastern Point Road, Groton, Connecticut ("facility"). At the facility, Pfizer operates six (6) dual-fuel fired steam boilers ("boilers"), numbered 1, 2, 3, 4, 5, and 8. Pfizer is currently**op~rating** pursuant to Trading Agreement and Order No. 8136 to address excess NOx emIssions from boilers 1, 2 and 3. Boilers 4, 5 and 8 were projected to emit 925 tons per yep.r ofNOx 

### between June I, 1995 and May 31,1996. Pursuant to Section 22a·174-22, Regulations ofCon.necticut State Agencies ("Regulations"), the projected NOx emIssions for boilers 4,5, and 8for that same time period was 632 tons 

### (equivalent to 0,25 pounds permillionl3ritish thennal units ("lbsIMMBtu") of heat input ). In 1996, low-NOx burners, flue gas recirculation and natural gas burning

. capability were installed on/added to boilers 4, 

### 5 and 

### 8, thereby reducing said

bollers' NOx emission rates below their 1995 emission rates. Emission reductions achieved through the installation oflow-NOx burners, flue gas recirculation and the burning ofnatural gasare eligible, pursuant to Section 22a174-220)(3) ofthe Regulations, to be considered surplus emissions reductions for purposes ofgenerating discrete emission red.uction credits ("DERCs"). Separate continuous emissions monitors ("CEMs") measure NOx emissions from each boiler. The CEM operational trial period for boilers 

### 4 and 

### 5 was completed on 

### July 6, 1996 and on October IS, Ig96 forboiler 8. By monitoring and controlling the combustion process ofboilers 4, 

### 5 and 

### 8, and by burning natural gas, Pfizerhas represented that it can minimize NOx emissions so that emissions frequently can be kept below the NOx emission limitations 

### established by Section 22a·174-22(e) ofthe Regulations. 

### In accordance with the tenns and conditions ofthis Trading Agreement and Order, Pfizer may obtain approval ofactual reductions in NOx emissions generated through combustion control and burning natural gas for use 

### as DERCs. Pursuant to Section 22a-174-220) ofthe Regulations, Pfizer intends both to 

### acquire and generate approved DERCs until May I, 2003, at the facility. If DERCs are created during the ozone season by boilers 5 and 8, Pfizer may obtain approval for such reductjons for use as Budget discrete emission 

### 1 / /. (Printed on Recycled Paper) Date: _-,-'

### ''-1--,-)..-'..7-,-'_'_''_.

__ I Street • Hartlord, CT 06106

- 5127 htfp:l/d**ep.stat~.Cf. U~**  A/f Eql.<al Opporll.<niry**Employ~r**

### PfizerInc.



### 6.

7.

8.

9. Trading Agreement and Order No. 8093B reduclion credits ("BDERCs"). Approved DERCs are defined forpurposes ofthis Trading Agreement and Order as those for which the Commissioner has provided written authorization for use in compliance with Section 22a174-22 oftheRegulations. Priorto receipt ofapproval forDERCs generated at the facility, Pfizerhas acquired 270 tons ofapproved DERCs for use at the facility's boilers 4,5 

### ana 8. Pfizer

### will continue to acquireDERCs on 

### an as-needed basis. Pfizer will provid.e

# an accounting ofactual NOx emissions to theDepanment of Environmental Protection (''Depanment''), based on data recorded by the CEM:s pursuant to paragraph D.7. ofthis Trading Agreement and Order. Ten (10) percent ofthe DERCs generated at the facility shall be retired and permanently removed from all calculations to assure 

### abenefit to the environment. When properly documented byPfizer, and approved by the Commissioner, the enussion reductions identified above, and as computed in accordance with the tenns ofthis Trading Agreement and Order, will conform to 

### the requirements ofSection 22a-174-22(j)(3) ofthe Regulations. SpeCifically, the reductions will be: Real because they will 

### result in areduction ofactual emissions released into the 

### air, net ofany consequential increase in actual emissions**resultin~** 

### from shiftin$ demand. The emission reductions will be properly rneasurea, recorded ana reponed. Quantifiable because they are based on CEM data as applied in an appropriate reliable and replicable protocol, providing the rate and total mass amount ofreduction. Surplus because they 

### are not required by any Connecticut statute or regulation mandated by acurrent State Implementation Plan (SIP), and are not currently relied·upon in any applicable attainment plan, any reasonable further progress plan or milestone demonstration. Pennanent because the low-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 theDERCs are approved by the Commissioner retrospectively after the submission by Pfizer ofa repon that documents their creation. The emissions tradina 

### baseline ("baseline emission rate") forboilers 4,5 and 

### 8 is 0.25

### Jb~tu ofheat input when operating on No.6 fuel oil, and 0.20 Ibs/M?>.1Btu ofheat input when operating on natural gas. Said baseline emission rates are based on 

### the following aDproved stack tests completed 6/26/96-6/27/96 for boiler4, 6/29/96 for-boiler 5 and 9/19/96-9/20/96 for boiler 8:

Inilials:

# ~;j",;>,--v_(; _ 

### 1 

# ///-7/·", Date:

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### OrderNo. 8093B 

### BoilerNo. Emission Rate. (lbs/lv1MBtu) 4 

### Natural Gas 0.14 No.6 Fuel Oil 026 5 

### Natural Gas 0.20 No.6 Fuel Oil 0.25 8 !'Iatural Gas 0.13 

# , No.6 Fuel Oil 0.31 

### PfizerInc. TradingAgreement and

10. As documented in Attachment 1, attached to and incorporated by reference into this Trading Agreement and Order, 76 DERCs and 51.2 BDERCs were created atboilers 4, 5 and 8 between October 1,1998 and October 31, 2000 (20.9 DERCs and 51.2 BDERCs during the ozone season and 55.2 DERCs 

### during the**non~ozone** 

### season). 11. Ten (10) percent ofthese DERCs and BDERCs (7.2 ozone season, 5.5 non

### ozone season) are retired and permanently removed from all calculations to assure abenefitto the environment. The total available for use, after rounding down to the nearest whole numberfor annual serial assignment purposes, is 67 DERCs (18 ozone season, 49 non-ozone season) and 46 ozone season BDERCs. 

### B.1. The Commissioner,

## in accordance with the provisions ofthis Trading Agreement and Order, pursuant to Section 12a-174-22(d)(3) ofthe 

### Regulations, will allow Pfizer and approved sources within Connecticut [Q 

### use 67 tons of

### NOx

### DERCs (18 dunng the ozone season and 49 during the non-ozone season) and 46 tons ofozone season BDERCs referenced in paragraph All. 

### ofthis.Trading AgreeI!lentand Order (or**purpose~** 

### of com'pliance under Secuon 22a-174-220) ofthe Regulauons to achieve a poroon ofthe nitrogen oxide emission reductions required by Section 22a174-22. DERC creation serial numbers assigned by the Depanment to these approved reductions ofNOx emissions are provided in Table 1ofthis TradingAgreement and Order:

Initials:

... Zo:.·

## ~.5~''- 

# _ 3 Date: --,1",1

### ,..-/",J.l-,-;/'---'C"

_Pfizer Inc. TABLE 1 Trading Agreement and Order No. 8093B

1998 

### I 1999 2000 Ozone season NOx BDERC N/A CT99/8093B(BDC) CTOO/8093B(BDC) serial numbers NOxozl-2S NOxozl-IS I (boilers 5 and S)

Ozone season NOxDERC CT9S/S093B(DC) CT99/S093B(DC) CTOO/S093B(DC) serial numbers " NOxoz1·2 NOxozl-S NOxozl-8 (boiler 4 (and boiler 8**on~** during 199 ozone season)) I**Non~ozone**

season NOx CT98/8093B(DC) CT99/S093B(DC) CTOO/8093B(DC) DERC serial NOxnozl-12 NOxnozl-14 NOxnozl-23 numbers**R(~oilers** 4.5 and 8

B.2. Ozone season BDERCs may be generated and used in accordance with this Trading Agreement and Order. B.3. Upon sufficient documentation as prescribed below, the Commissioner may provide written approval ofthe generation ofadditional DERCs by Pfizer retrospectively. Approved DERCs and BDERCs generated by Pfizer may be held by Pfizer or transferred to other persons in accordance with this Trading Agreement and Order. C. The Commissioner, in accordance with the provisions ofthis Trading Agreement and Order, pursuant to Section 22a-174-22(d)(3) ofthe Regulations, hereby allows Pfizer to comply with Section 22a-174-22(d)(1) ofthe Regulations through use ofDERC trading. D. With the agreement ofPfizer, the Commissioner, acting under Sections 22a6, 22a-171, 22a-174, 22a·176, and 22a-177 ofthe Connecticut General Statutes, orders Pfizer as follows: 1. PERC 2eneration.

a. Forpurposes ofgenerating DERCs from boilers 4, 5, and 8 at the facility, Pfizer shall use 0.25 IbsIMMBtu ofheat input when operating on No.6 fuel oil and 0.20 Ibsf!'v.1}.1Btu ofheat input when operating on natural gas as the baseline emission rates for boilers 4, 5 and 8, or the proponioned baseline emission rate set forth in foornote 

### 1 ofparagraph D.Z. ofthis Trading Agreement and Order, when simultaneously operating on more than one fuel. Pfizer shall use the above referenced baseline emission rate(s) when calculating the proportioned baseline emission rate. 'When calculatino DERCs, Pfizer shall use**CEM~** recorded NOx emission rates* fOr boiler4, 5 and 8 and actual fuel use for boiler4,5 and 8 in 1vfl'vffitulday, when detennining heat input. Ten (10) percent ofall DERCs (tons) created by boilers 4, 5 and S shall be
Initials: 

### -i),.!-7-,' Cc.,'

_ 4 Date:

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__Pfizer Inc. Tradine. Ae.reement and OrderNo. 8093B retired by the facility and pennanentlyremoved from all calculations [0 assure: a benefit to the enVIronment.

Initials: "'These rates shall be calculated pursuant to [he methodology described in 40 Code ofFederal Regulations Part 60. b. Non-ozQne Season Restrictions. Non-ozone season NOx DERCs**~enerated** by Pfizer shall be created and approved in accordance with tnis Tradin,s.**~$reement** and Order, and shall remain valid until they are used onmnl May I, 2003, whichever occurs first.

c. Ozone SeasQn Restrictions. Boilers 5 and 8 are subject to Section 22a174-22a ofthe Regulations ("NOx BudgetProgram") in 1999 and every year thereafter. Boiler 5 and 8 may generate ozone season BDERCs tQ comply with Section 22a-174-22 ofthe Regulations in accordance with paraeraph D.l.a. and the following conditions and restrictions: 1) BDffiCs shall only be generated by boilers 5 and 8 from May I**throu~h** September 30 ofa given year, 2) BDERCs shaJl only be used by otner NOx BudgetProgram sources located in Connecticut, 3) BDERCs shall only be used to offset ozone season excess emissions, and shall not be used for compliance during the nonozone season; and 4) BDERCs generated during a given year shall only be used during the following ozone season, with theexception of BDERCs generated**durin~** 1999, which may be used in the 2001 ozone season. For example, BD.l::.RCs O'enerated during the 1999 ozone season may be used during the 2501 ozone season. However, BDERCs generated during the 2000 ozone season may only be used durin$. the 2001 ozone season. BDERCs may be $enerated until May I, 20v3. BDERCs are subject to all DERC reqwrements set forth in this Trading Agreement and Order except for those requirements pertaining solely to non-ozone season DERCs and as otherwise may be provided. 2. When boilers 4,5 and 8 have daily NOx emissions below the applicable baseline emission rate(s), or the proportioned baseline emission rate, Pfizer shall calculate the amount ofDERCs generated, as follQws: DERCs (tons) 

### = {[Total heat input ofall fuels in MJvlBtu x «proportioned baseline emission rate1 )

- 

# 1 the CEM-recorded NOx emission rate2 ) ) ] + 2000 pounds/ton} x (0.90)." lThis rate shall 

### becalculated by 1) multiplying me heat input ofeach fuel combusted by the baselineemission rate{s) for such fuel; 2) summing those producu:; and 3) dividing the sum by the total heat input. Ifboilers 4, 5 or 8 are operating exclusively on one fuel, Pfizermayreplace the proponioned baseline emission rate with the applicable baseline emisslOn rate for that fuel.

### ~his rate shall be calculated pursuant to the methodology described in 40 Code of Federal Regulations Pan 60. 2Ten (10) percent ofall DERCs (tons) created by boilers 4, 5 and 8 shall beretired by the facility and pennanently removed from all calculations on adaily basis to assure abenefit to the environment. 3. In order to consider a Daily NOx Averaging Period valid for DERC 

# ,0/ [j 

# 5 D . 11!;"7/'"

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### ate. ---'--"-_---'

_PfizerInc.

4.



### 5.

6.



### 7.

8. Trading Agreement and Order No. 8093B approval, It must contain valid data hours for seventy-five percent (75%) of the operating hours in that daily period (example: minimum 18 valid hours for a full 24-hour operating day; minimum 12 hours for 16 operating hours, etc.). A DailyNOx Averaging Period is defined as the total ofall operating hours in a day during which fuel is being fed to boilers 4, 5 and 8. Additionally, for a data hour to be considered a valid hour, seventy-five percent**(759'0~** minimum data capture requirements must be met for each one-hourblockperiod. All NOx and CO';O, CEMs must comply with the 40 CFR

# Pan 60 AppendiX F drift criteria. Pfizer shall maintain records forboilers 4, 5 and 8 showing daily NOx mass emissions, actual NOx emission rates (24-hour average), numberof operating hours per day, and numberofinvalid data hours ofthe total operating hours per day. Pfizer shall also maintain records showing a monthly total ofall DERCs generated net ofthe ten (l0) percent environmental discount. 

### In requesting DERC approval, Pfizer shall provide documentation comaming a sample spreadsheet with calculation fonnulas used to determine reponed numbers; monthly operating reports. ofactual fuel usage includin

# r o the fuel BTU content, number ofgallons, and cubic feet used for each fue type; daily M:MBtu for each fuel tyPe; daily NOx emission rates (24-hour average); and DERCs generated, usmg the baseline emission rate(s), or the proportioned baselineemission rate, net ofthe ten (10) percent environmental discount. When the daily CEM-recorded NOx emission rate is used to calculate DERCs generated by boilers 4, 5 and 8, Pfizer shall not include missing data calculated in accordance with any missing'data substitution procedures, including those allowed under Section 22a·174·22a ofthe Regulations. When the daily CEM:-recorded NOx emission rate is used to calculate DERCs used by boilers 4, 5 and 8, Pfizer shall include missino data calculated in accordance

### with missing data substitution

### proc~ures approved by the Commissioner. No later than March 1 ofevery year after issuance ofthis Trading Am-cement and Order, Pfizer shall include with the Annual Emission statementprovided to the Commissioner, arecord ofeach sale orother transfer, and use ofany and all oftheDERCs approved within and subsequent to issuance ofthis Trading Agreement and Order until all such DERCs have been used. Pfizer shall also include actual NOx emissions from boilers 4, 5 and 8 and the amount ofall DERCs used (including serial numbers (ifassigned) and approved DERCs generated and/or purchased from otherfacilities), generated and/or approved for the previous calendar year. TheserepoI1s shall be on a fonn prescribed by the Commissioner and shall be in monthly increments. This reponing may cease ifa central registry is approved by the Commissioner. Should Pfizer choose to discontinue the generation ofDERCs, Pfizer will notify the Commissioner upon discontinuance. Upon sufficient documentation, as detennined by the Commissioner, that Pfizer has met the requirements ofparagraphs D.l., D.2., D.3., D.5., D.6.,

Initials: 

# )71 __P'--'--

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### 6 Date: _--,,"-/,

# !--,;;t.--'-i71,-,-~·__ I 

### II 

### Should Pfizerchoose to**~enerate** 

### additional DERCs, repons documenting these DERCs shall be 

### sUDmined to the Commissioner on an ozone season, non-ozone season (January throuo-h April and/or Ocroberthrough December), or annual basis. Such reports shall be compiled on a monthly basis and shall be submined at least on an annual basis. PfizerInc.

9.

10. Trading Agreemem and Order No. 8093B D.9., and D.I0. ofthis Trading Ao-reemem and Order, the Commissioner !J1ay

### p~C!vide wrinen approval.ofBERCs generated by Pfizerretrospectively, In 

### additIOn to 

### those approved In 

### paragraph B. ofthis Trading Agreement and Order. Requests for approval ofall subsequent DERCs created shall be submined in writing to the Commissioner. Approved DERCs o-enera[ed by Pfizermay be held ortransferred to 

### otherpersons. Such DERCs shall remain valid until they are used oruntil May 1, 2003, whichever occurs first.

DERC use. Approved DERCs shall be acquired for compliance with the emission standards in Section 22a-174-22 ofthe RegulatIons for the period beginning June 1, 1995 and continuing until Pfizer achieves pennanem compliance for boilers 4, 5 and 8 with the emission standards in Section 22a-174-22(e) of[he Regulations oruntil May I, 2003, whichever occurs first. Pfizer shall acquire approved DERCs, and document and record the amounts ofNOx emissions and DERCs used by serial number (ifassigned) by boilers 4, 5 and 8 each day, and shall maintain and provide such records in accordance with the following and Section 22a-174-4 ofthe Regulations, until May I, 2003:

a. Before the first day ofeach month, calculate projected worst case DERCs required for that calendarmonth as follows: DERCs (tons):::: {[estimated worst case emission rate in IbsfM}..1Btu

- ((0.95) x (NOx RACT limit orproportioned emission rate calculatedpu"uanllo Section 22a-174-22(f)(2)(A) ofthe Regulations in Ibs/MJ\1Btu»)] x (Estimated fuel use in :MMBtu)}

... 

### 2000 pounds. b. Acquire sufficient approved DERCs no laterthan the first ofeach month to 

### assure compliance with the emission standards in Section 22a-174-22 ofthe Regulations for, at a minimum, thatcalendar month. With the exception ofBDERCs, excess DERCs from previous months can be 

### applied to subsequent months. BDERCs are subject to the limitations set fonh in paragraph D.!.e. ofthis Trading Agreement and Order. At aminimum, DERCs required shall be adjusted upwards by 100% ifDERCs are not in Pfizer's possession pnor to the first day ofeach month.

c. No later than the twentieth day ofeach month, calculate DERCs used in the precedingcalendarmonth, as follows: I) Forboilers 4, 5 and 8 on each day, determine whether the 24- hour average NOx emission rate'" is less than the baseline emission rate or greaterthan the NOx RACT limit. 2) ""'hen boiler4,5 or 8 has a daily. TOX 

### emission rate (24-hour

Initials: 

# --,5t""Y,-'""S<--

__ 7 

### Date: -"I

# {,+/_~--,-:" --"D...:,_'

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# ,Pfizer Inc.

d. Trading Agreement and Order No. 8093B average) exceeding the NOx RACT limit, calculate the amount ofDERCs used, as follows: DERCs (tons) 

### = 

## I[(CEM-recorded NOx daily average emission rate in IbslMMBtu*)

- (0.95) x (NOx RACT limit orpropor-Joned emission rate calculated pursuant to Section 22a-174-22(1)(2)(A) of the Regulations in IbslMMBtu»] x (actual fuel use in MMBtu») + 2000 pounds.


# , *This rate shall be calculated pursuant to the methodology described in 40 Code ofFederal Regulations Part 60.

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## l.......................

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## _ :> the ozone season were generated durina the ozone season. Generatorcertification ofthis fact shalibe sufficient.

f. 

### e.

Initials: luterfull pro!ffi1IIl review, and ifthe Commissioner deems it appropriate, the Commissioner may allow the survival and use of approved DERCs beyond April 30, 2003, subject to the limitations set forth in paragraph D.l.c. ofthis Trading Agreement and Order. Pursuant to Section 22a-174-22(d)(3) oftheRegulations, Pfizer may use NOx allowances, pursuant to Subsection

## G) ofSection 22a-174- 22 ofthe Regulations to achieve all or a portion ofthe reductions required by Section 22a-174-22 ofthe Regulations forboilers 

### 5 and 8. Any allowance used for compliance with Section 22a-174-22(e) ofthe Re!i!Ulations for boilers 5 and 8 shall be subject to all restrictions and/orrequirements applicable to DERCs contained in this Trading Agreement and Order. 11. Pfizer shall retain records and supporting documentation as described in this Trading Agreement and Orderfor a minimum offive years, commencing on the date such records werecreated. Pfizer shall provide the records specified above to the Commissioner within 

### thiny (30) days ofreceipt ofa wrinen request from the Commissioner. 12.**Pri?~** to .11ay 

### },}003,**Pfi~e~** shall**cO,!?..E.l~_ ~2** **~.uri.ng .operatio~**  ofboilers 4 ana J WHn a rUll load emiSSIOn nne 

### Cru:..K. ) mnnation of

### 0,.:>66 IbsIMMBtu heat input for no, 

### 6 fuel oil andlor natural**~~veraged** on a 24-hourbasis, and b) during operation ofboiler 

### 8 with ru::.R limitations of 0.3661bsIMMBtu heat input for no. 6 fuel oil and 0.20 IblMMBtu heat input for natural gas, averaged on a 24-hourbasis. 13. No later than May I, 2003, Pfizer shall comply with the requirements of Section 22a·I74-22(d)(I) ofthe Regulations unless this Trading Agreement and Orderis otherwise extended by the Commissioner. 14. Each allowance used for compliance with Section 22a-174·22 ofthe Re$Ulations shall be equivalent to one discrete emission reduction credit ana shall be deducted from Pfizer's NOx Budget Program compliance aCCount upon such use...6Jlo.wances 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

## ~,~(J 8

## ,/~1/. Date: 

### II -, ,.. ; i /Pfizer Inc. Trading Agreement and Order No. 8093B State ofConnecticm NOx allowance retirement account. 15. Approvals. Pfizer shall use best efforts to submit to the Commissioner all documents required by this Trading Agreement and Orderin a complete and approvable fOITI1. If the Commissioner notifies Pfizer that any document or other action is deficient, and does not approve it with conditions or modifications, it is deemed disapproved, and Pfizer shall correct the deficiencies and resubmit it within the time specified by the Commissioner or, ifno timelis specified by the Commissioner, within 

### 30 days ofthe Commissioner's notice ofdeficiencies. 

### In approving any document or other action underthis Trading Agreement and Order, the Commissioner may approve the document or other action as submitted orperfoITI1ed 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. 

### 16. Definitions. As used in this Trading Agreement and Order, "Commissioner" means the Commissioneror arepresentative of the Commissioner; "Ozone season" means the period from May 

### 1 through September 30 in any given calendar year, and "NOx 

### R.l\CT" means NOx Reasonably Available Control Technology. The date of"issuance" ofthis Trading Agreement and Order is the date theTrading Agreement and Orderis deposited in the U.S. mail or personally delivered, whichever is earlier. 17. Dates. The date ofsubmission to the Commissioner ofany 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 Commissioner under this Trading Agreement and Order, including but not 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 Tradin¥ Agreement and Order, the word. "day' 

### as used in this Trading Agreement 

### ana Order means calendar day. Any document or action which is required by this Trading Agreement and Order to be submitted or performed by a date which falls on a Saturday, Sunday or

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

### lB. Ce:1:ificatio!'l ofdocuments. Any c.ocument, includi!!g

### bur not limited to any notice, which is required to be submitted to the Commissionerunder this Trading Agreement and Order shall be sismed by Pfizer or, ifPfizeris not an individual, by Pfizer's chiefexecutive officer or a duly authorized representative ofsuch officer, as those terms are defined in §22a-430-3(b)(2) ofthe Regulations ofConnecticut State Agencies, and by the individual(s) responsible for actually preparing such document, and Pfizer or Pfizer's chiefexecutive officer and each such individual shall certify in writing as follows: 

### "I have personally examined and 

### am familiar with the infoITI1ation submitted in this document and all anachments 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. 

### I understand that any false statement made in the submitted infoITI1ation is punishable as a criminal offense under §53a·157b ofthe Connecticut General Statutes and any other applicable law."**r~** ,,7 Initials: _--",,"-'--'.'

_ 

### 9 Date:

# _-'-I:;./_>----!.7+/---'()_·_~

### 23. PfizerInc. Trading Agreement and Order No. 8093B 19. Noncomoliance. This Trading Agreement and Orderis afinal order ofthe Commissioner with respect to 

### the matters addressed herein, and is nonappealable and immediately enforceable. Failure to comply with this Tradmg Agreement and Ordermay subject Pfizer to an injunction and penalties. 

### 20. False statements. Any false statement in any infonnation submitted pursuant to 

### this Tradi.ng'Agreement and Orderis punishable as acriminal offense under §53a-157B ofthe Connecticut General Statutes and any other applicable law. 21. 

### Notice oftransfer: liabilirv ofPfizer. Until Pfizerhas fully complied with this Trading Agreement and Order, Pfizershall notify the Commissionerin writing no laterthan 15 days after transfening all or

### any portion ofthe facility, the operations, the site orthe business which is the subject ofthis Tradin$ A$reemenl and Order or after obtaining anew mailing orlocation adaress. P!lzer's**obli~ations** 

### under this Trading Agreement and Order shall not be affected by the passage oftitle to 

### any property to 

### any mher person or municipality. 22. Commissioner's powers. Nothing in this Trading Agreement and Order shall affect the Commissioner's authority to institute anyproceedinCl" ortake any other action to prevent orabate violations oflaw, prevent or abate pollution, recovercosts and natural resource damages, and to impose penalties for past, present, orfuture violations oflaw. If

### at any time the Commissioner detennines that the actions taken byPfizerpursuant to 

### this Trading Agreement and Orderhave not successfully corrected all violations, fully characterized the extent or degree ofany pollution, or successfully abated orprevented pollution, the CommissionermayInstitute anyproceeding to require Pfizerto undenake funher investigation orfurther action to prevent or abate violations or pollution. Pfizer's obliQ:ations underlaw. Nothing in 

### this Trading A2Teement and Order shall relieve Pfizer ofother obligations under applicable federal, state and local law. 24.



# ,- 

# -,.

26.

27. No assurance bv Commissioner. No provision ofthis Trading Agreement and Order and no action orinaction bv the Commissioner shall be construed to constitute an assurance by the COInmissionerthat the actions taken byPfizer pursuant to this Trading Agreement and Order will result in compliance or prevent or abate pollution. Access to facilirv. Anyrepresentative ofthe Department ofEnvironmental Protection mayenterthe facility without prior notice for the purposes of monitoring and enforcing the actions required or allowed by this Trading Agreement and Order. No effect on rig-hts ofotherpersons. This Trading Agreement and Order neithercreates nor affects anyrights ofpersons or municipalities that are not parties to this Trading Agreement and Order. No Creation ofProperrv Rights. This Trading Asrreement and Order does nOl create any property rights with respect to 

### these D"ERCs.

Initials:

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### 7 1 !--,-;;c.---'-,7

### /L:1J",I

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### PfizerInc. Trading Agreement and Order Noo 8093B 

### 28. Notice to Commissionerofchancres. Within 15 days ofthe date Pfizer becomes aware ofachange in any information submitted to the Commissioner under this Trading Agreement and Order, orthat any such information was inaccurate ormisleading orthat anyrelevant information was omitted, Pfizer shall submit the correct or omitted information to the Commissioner. 

### 29. Notification ofnoncompliance. In the event that Pfizerbecomes aware that it did not or"rriay not comply, or did not ormay not comply on time, with any requirement ofthis Trading Agreement and Order or ofany documentrequired hereunder, Pfizer shall immediately notify by telephone the individual identified in the next paragraph and shall take all reasonable steps to 

### ensure that 

### ,my noncompliance or delay is avoided or, ifunavoidable, is minimized to the**~eatest** 

### extent possible. 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 ordelay 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 writing by the Commissioner. Notification by Pfizer shall not excuse noncompliance or delay, and the Commissioner's approval ofany compliance dates proposed shall not excuse noncompliance or delay unless specifically so statedby the Commissionerin writing. 30. 

### Submission ofdocuments. Any document required to be submitted to the Commissionerunder this Trading Agreement and Order shall, unless otherwise specifiedin this Trading Agreement and Order orin writing by the Commissioner, be directed to: Wendy Jacobs Department ofEnvironmental Protection Bureau ofAirManagement Emissions and CreditTrading Section 79 Elm Street Hartford, Connecticut 06106-5127



### Initials: 

### --,/o;f4 L o _0"o(Se./

_ 11 

### Date:

# _-,-i,-;,r;!...!_-~_'**~7** /,--"_1

__

### PfizerInc. Trading Agreement and Order '0. 

### 8093B



### Pfizerconsents to 

### the issuance ofthis Trading Agreement and Order without funher notice. The**undersi~ed** 

### cenifies that he/she is fully authorized to enler into this Trading AgreemeOl and Order and to 

### legally bind Pfizerto the terms and conditions ofthe Trading Agreement and Order. 

# , PfizerInc.Signature: Em.-ard L. Brennan 

### Type Na!ne:



### Type Title: Director I EB&S 

### Date:

# _-,-!,-;/,-/-,-?-~7T;'-,-J-,j _ I .; 

### Issued as afinal order ofthe CommissionerofEnvironmental Protection**~-::::~'U~",,~~SL**

## __ 2001.



## .i\rthur**J'1:9"~:Jr** I**Comrrus~** 

### CITY OFGROTON LAND RECORDS MAILED CERTIFIED MAlL, RETURN RECEIPT REQUESTED 

### Cenified Document No.



### J2