BASED ON THE MULTI-MEDIA INSPECTION AND EPA;S REVIEW OF INFORMATION SUBMITTED BY PFIZER IN RESPONSE TO EPA'S INFO REQUEST, EPA IS PROPOSING TO SEEK PENALTIES FOR THE FOLLOW- ING VIOLATIONS: RCRA: FAILURE TO LABEL AND DATE CONTAINERS OF HAZARDOUS WASTE; FAILURE TO KEEP CONTAINERS OF HAZARDOUS WASTE CLOSED; STORAGE OF INCOMPATIBLE WASTES; FAILURE TO HAVE SECONDARY CONTAINMENT; FAILURE TO PROPERLY INSPECT HAZARDOUS WASTE CONTAINERS; FAILURE TO OBTAIN A SEPARATE EPA IDENTIFICATION NUMBER FOR PFIZER'S RESEARCH AND DEVELOPMENT FACILITY WHICH IS LOCATED ACROSS THE STREET FROM ITS MANU- FACTURING FACILITY; INCOMPLETE HAZARDOUS WASTE MANIFAESTS AND LAND DISPOSAL RESTRICTON NOTIFICATIONS; FAILURE TO CON- DUCT HAZARDOUS WASTE TRAINING FOR PERSONNEL OR FAILURE TO DOCUMENT HAZARDOUS WASTE TRAINING; FAILURE TO CONDUCT INPEC- TIONS FOR EQUIPMENT LEAKS FROM PUMPS AND VALVES; AND FAILURE TO MAKE PROPER HAZARDOUS WASTE DETERMINATIONS. IN ADDITION, THE REGION HAS IDENTIFIED A NUMBER OF POTENTIAL VIOLATIONS WHICH WILL BE RESEARCHED AND POSSIBLY INCLUDED IN A SUPPLEMENTAL REFERRAL TO DOJ. CWA: SINCE 1989, PFIZER HAS EXCEEDED EFFLUENT LIMITATIONS FOR PH, BIOLOGICAL OXYGEN DEMAND (BOD), TOTAL KJELDAHL NITROGEN (TKN), TEMPERATURE, FLOW AND TOTAL SUSPENDED SOLIDS (TSS) SET FORTH IN PFIZER'S NPDES PERMIT ON AT LEAST 110 OCCASIONS. IN ADDITIN, PFIZER HAS DISCHARGED AT LEAST 32 SPILLS AND BOILER BLOWDOWN THROUGH ITS