Department of Public Services Wastewater Division ton Sect Facty 1415 Nonh Hes Sree Kotaraoo, Meng 190072385 Ph 268-37-8511 re 2683578535, January 18, 2019 Terri Shattuck Environmental Quality Analyst Water Resource Division ‘Michigan Department of Environmental Quality Kalamazoo District Office 7953 Adobe Road Kalamazoo, Michigan 49009-5026 ‘Subject: Pfizer's Methylene Chloride Release 11-118 Enclosed is a summary report of the release of Methylene Chloride from the Pharmacia & Upjohn LLC, 2 subsidiary of Pfizer Inc (Pfizer facility located at 7000 Portage Road ta the Kalamazoo Water Reclamation Plant (KWRP) on November 1, 2918. The report includes descriptions of the events, two letters from Pfizer ‘ith an explanation of the release; KWRP’s sampling results, Pfizer'ssampling results, the corrective actions to be taken by Pfizer and the enforcement actions to be taken by the City of Kalamazoo Industrial Pretreatment Program, Kalamazoo Water Reclamation 2lant (Kalamazoo WWTP) NPDES Permit ~Mil0023299 If you have any questions er concems, please feel free to contact me at (269) 337-8365 or ochows@kalamazoocity.ore. est Regards, Shee fl Kesher ‘Steven M. Rochow Senior Environmental Service Supervisor ity of Kalamazoo — Department of Public Services‘The Loss of Ammonia Treatmert at the Kalamazoo Water Reclamation Plant (On November 2, 2018 (2:00 ar), the Kalamazoo Water Reclamation Plant (KWRP) started to experience ‘rouble with treating ammonia, The plant was able to supply plenty of “ait” to our secondary treatment process but struggled to convertammaniatonitrate. The wastewater operation staffsampled the secondary effluent to confirm the level of ammonia were the same as the process control trends indicated. The city’s Industral Pretreatment Program contacted key industrial contributors but none ofthe facies indicated any “unusual” discharges included Pfizer. The interference withthe ammonia process continued for S days. ‘Attachment #1 isthe trend analysis of the ammonia levelsin the plant's secondary mixliquor and secondary effluent, Kalamazoo Water Reclamation Plant’s Sample Collection Due to the plant interference, cy staf decided to collect samples o test fr pollutant parameters that have historically caused an impact onthe nitrifying bacteria. The staff poured off samples ofthe plant's Municipal Primary influent (MPI), Secondary influent (SIN) and Secondary fluent (SEF) for November 2, 2018. City personne also poured off samples from key industries that are sampled dally for compatible pollutants with 24 hour composite samples for November 1-6, 2018; these industries included Pfizer (UIB), Graphic Packaging International (JC), Kalsec {KSC) and Allnex (ACA). All these samples were tested for EPA 624 \which includes Methylene Chloride, The results of these samples are included in Attachment #2. Pfizer's Monthly Pharmaceutical Monitoring - Sample Collection Pfizer performs monthly self monitoring for pharmaceutical exemption parameters of Acetone, Methylene Chloride and Toluene, Pfizer colected their monthly November sample on November 1, 2018. When Pizer received their sample results beck from this monitoring on November 8, 2018, Robert Osipoff notified the. tity of violations with Acetone ‘monthly ~ pending additional samples during November) and Methylene CChioride (daly and monthly lite - manthly pending adcltional«amplo< during November) within the 24 hour reporting period, Pfizer hal the sample (4 grab composite) re-run to verify the results and each of the grabs tested to determine wher the “slug” might have been discharged, Please see their letter of November 115, 2018 for further information; Attachment #3, Due to QA/QC problems at Trace Analytical Laboratories during the fst analytical procedures, the analytical results were revised bring the results of the Acetone: {monthly} backinto compliance. The revied results for Methylene Chloride still indicated a violation ofthe dally and monthiy limits, Pfizer collected additonal samples during November for Acetone based upon the original sample results. The adcitional Methylene Chioride samples did not bring the parameter backinto compliance with the monthly Imit, lease see thei letter of December 7, 2018 for further information; ‘Attachment #4, bifference in Methylene Chloride Release Loadings ‘With the revised sample data from Trace Analytical Laboratories, Pfizer re-established the level of the ‘Methylene Chloride released on November 1"to 1,000 pounds bases upon the change in the results of the ‘ourth grab sample (18:00), The cy disputes this new estimate bases upon the city’s sample taken on that ‘day at the monitoring point UB with a 24 hour flow proportional sample with 133 aliquots. The city estimated the Methylene Chior de loading was 2,693 pounds based upon the sample result of 130 mg/L and a flow of 2.48 milion gallons for November 1°. The Cty of Kalamazoo believes the Pfizer estimation does not include several peaksincluded on the LEL graph from Sanitary tation #2 that were significant higher than the level of fourth grab sample: Attachment #5Pfizer Corrective Action Plan Pizer’s investigation was not able to determine the exact location of the release or the amount of Methylene Chloride Pfizer usedestimatesto calculate the volume of Methylene Chloride that was released ‘on November 1" Under normalconditions, the sanitary retention basin (uilding 381) should have captured the release based upon the LEL alarms at Sanitary Station #2. During the meeting on November 29, 2018, Pfizer explained that “operator 2rrar” was the reason why the sanitary retention basin was not placed into capture mode due tothe operator believing the alarms tobe false. Pfizer's corrective actions are outlined in, their December 7, 2018 leer. Enforcement Actions Notice of Violations: Local Limits ‘The City of Kalamazoo has isued a Notice of Violation to Pfizer for exceeding their daly maximum and ‘monthly average for Methylene Chiride. Daily Limit: 10.5 mg/L Pfizer 11/1/18 result: 70 me. ‘Monthly Limit: 3.8 me/t Pfizer Novernber 2018 result: 8.88 me/L No Notice of Violation was isued to Pfizer for Acetone (daly or monthly) based upon the revised Acetone level on the Novernber 2" sample and the additional samples for the monthly limit raken in November. Significant Non-Compliance: Pass-through 40 CFR 403.8 (C {The sample taken on Noverbe* 2, 2018 from the KWAP Secondary Effluent for Methylene Chloride of 3.8, img/t demonstrates pass-through. While the sample was not taken atthe Tertiary Effluent (outfall of the WAP, the treatment processes downstream of the Secondary Effluent sample point would not remove Methylene Chloride and therefcre the pollutant would have passthrough the remaining portion of he plant into the Kalamazoo River, The methylene chloride result exceeded the Kalamazon Water Reclamation Plant's ‘Water Quality Based Effluent Liits(WOBELs) for monthly average WOBEL (ug/L), Daily Maximum WOBEL Lit: 17,000 ug/L. Result: 3,800 ug/L. Compliant Daily Maximum Load Limit: 7,600 Ibs/day Result: 839 bs/day CCompkant ‘Monthly Average WOBEL (ug/L) Limit: 3,000 ug/L Result: 3,800 ug/L. Violation ‘Monthly Average Load LUmnit 1400 tbs/day Result: 839 lbs/day Compkant oad: 3.8 mg/L x 8.34 x26.47 MGD = 839 Ibs/doy Please note that the November, 2018 sample was the only sample taken atthe secondary effluent and/or, tertiary effluent during Novemaer 2018 and tested for methylene chloride. “Therefore, the City of Kalamazoo Is placing Pfizer into Significant Non-Compliance (SNC) for Pass-through due oa violation ofthe Monthly Average WOBEL (concentration based) and Part 31 of the Water Resources Protection regulations as applied under the Natural Resources and Environmental Protection Act 45 of 1994 per MDEQ -Terri Shattuce's email on January 15, 2019, 40CFR 403.3 (p) The term Pass Through means a Discharge which exits the POTW into woters of the United Statesin quantities or concentrations which alone or in conjunction with a discharge or discharges{rom other ‘sources is cause ofa violation of any requirement of the POTW's NPDES permit including an increase in ‘magnitude or duration ofa veiation).