United States Environmental Protection Agency
Region III
POLLUTION REPORT

Subject: 

The Consolidated Pharmaceutical Group (CPG)is a  facility just south of Baltimore, Maryland, that formerly manufactured various antibiotics, and had shut down approximately eight years ago.  The facility contains a tank farm of 20 tanks (ranging from 5,000 to 20,000 gallons), some of which still contain hazardous substances.  In addition, over 100 drums of various substances, including alcohols, solvents, acids, and basic solutions, are stored inside the building.  A laboratory on the second floor of the building contained lab bottles of numerous chemicals, most of which were in very poor condition (these have been removed).  Also, hundreds of containers of antibiotics (mostly off specification or quarantined) in pill and powder form are stored throughout the building.  Roof leaks have resulted in many of these containers being in deteriorated condition.

On October17, 2007, EPA issued an action memorandum authorizing and funding a removal action at the site. On October 24, 2007, EPA issued an Administrative Order to CPG requiring them to remove the hydrochloric acid in tank 110 by October 31, 2007, remove all hazardous substances from the site by November 30, 2007, and remove all pollutants and contaminants by December 31, 2007.  CPG has begun to remove hazardous materials, pollutants, and contaminants from the site. To date, the hydrochloric acid has been removed, along with the triethylamine (tank 111) and acetone (tank 113, plus two additional drums).  Three dumpsters of antibiotics and other non-hazardous wastes have been shipped offsite for proper disposal.  In addition, the lab area has been cleaned up and all  lab wastes shipped offsite for disposal, along with lab wastes found stored in the warehouse area.  An additional several drums of lab waste were recently found in another area of the warehouse - these wastes are being prepared for disposal.  Other shipments of waste and materials for reuse are anticipated in the next few weeks.

EPA will continue to monitor activities at the site, and ensure that the hazardous substances, pollutants, and contaminants are removed from the site expeditiously and safely. If CPG does not continue to show adequate progress in meeting the goals of the administrative order, EPA is prepared to complete the removal action.