EPA v. PFIZER PHARMACEUTICALS LLC

Case summary

* 06/30/01 - AUDIT POLICY DISCLOSURE DATE. AS A RESULT OF THE INTERNAL AUDIT AND SUBSEQUENT DETAILED CHEMICAL ANALYSIS OF THE CHEMICAL REACTIONS OCCURRING IN THEIR COGENERATION STACKS, PFIZER DETERMINED THAT IT WAS MANUFACTUR'G AMMONIUM HYDROXIDE AT THE ELEVATED TEMPERATURES IN ITS COGENERATION STACK CAUSING IT TO DISSOCIATE TO AMMO- ONIA AND WATER. THE FAILURE TO SUBMIT IN A TIMELY MANNER COMPLETE AND CORRECT FORMS R FOR AMMONIA FOR THE CALENDAR YEARS 1998 AND 1999 CONSTITUTES A FAILURE TO COMPLY WITH SECTION 313 OF EPCRA, 42 U.S.C. SECTION 11023, AND WITH 40 C.F.R.  372.30. THE NEW FORM R REPORTS WERE MAILED TO THE USEPA ON JUNE 30, 2001. PHIZER ALSO DETERMINED AS A RESULT OF THE INTERNAL AUDIT THAT THE AMOUNT OF SULFURIC ACID THAT WAS TREATED(NEUTRA- LIZED) IN THEIR WASTEWATER TREATMENT SYSTEM WAS NOT SUBJECT TO EPCRA SECT/313 REPORTING REGULATIONS. THESE AMOUNTS OF SULFURIC ACID WERE OVER REPORTED FROM 1994 TO 1999 AND RANGED FROM AROUND 60,000 TO 20,000 POUNDS PER YEAR. AS A RESULT OF THE CHEMICAL PROCESS ANALYSIS CONCERNING THEIR COGENERATION STACKS, IT WAS DETERMINED THAT SULFURIC ACID AEROSOL STAK RELEASES NEEDED TO BE ADDED TO THE FORM R RE- PORTS FOR SULFURIC ACID. THE FAILURE TO REPORT A REASONABLE ESTIMATE OF THE ANNUAL RELEASE OF SULFURIC ACID AEROSOLS TO AIR (0 TO 500 LBS) AS A STACK EMISSION AND THE INCORRECT RE- PORTING OF THE QUANTITY OF SULFFURIC ACID TREATED ON-SITE ON THE FORMS R FOR 1996, 1997, 1998, AND 1999 CLALENDAY YEARS COSTITUTE A FAILURE TO COMPLY WITH SECTION 313 OF EPCRA, 42 U.S.C. SECT 11023, AND WITH 40 C.F.R. SECTIONS 372.30 AND 372.85. THE REVISED FORM R REPORTS WERE SUBMITTED ON JUNE 30, 2001. * NOTE THE INDEX NUMBER IS NOT THE SAME AS THE CASE NUMBER. THE INDEX NUMBER IS: EPCRA-02-2002-0856 8

Defendants (1)

• PFIZER PHARMACEUTICALS LLCNamed in settlement

Facilities (1)

• PFIZER PHARMACEUTICALS INC

  KM 58.2 RTE 2, BARCELONETA, PR, 00617

  Registry ID: 110008472063

Statutes cited

• EPCRA 313 — Toxic Chemical Release Reporting (TRI)

Enforcement conclusions (1)

• PFIZER PHARMACEUTICAL LLCentered 2002-02-21

  Primary law: EPCRA

Timeline (3 milestones)

• 2001-09-04Enforcement Action Data Entered
• 2002-02-21Final Order Issued
• 2002-02-21Enforcement Action Closed