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Consolidated Pharmaceutical Group

All POLREP's for this site Consolidated Pharmaceutical Group
Brooklyn Park, MD - EPA Region III
POLREP #4 - Wastes Removed
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On-Scene Coordinator - Gregory Ham 3/20/2008
Time-Critical - Removal Action Pollution Report (POLREP) #4
Pollution Report (POLREP) #4
Site Description
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.

Current Activities
As of the date of this polrep, all wastes have been removed from the site, except for the wastewater in a sump tank on the property, and a small amount (1,000 gallons) of rinse water from cleaning the empty tanks.  Over the last few weeks, all of the remaining drums of material were either sold or shipped offsite for disposal.  On February 15, 2008, EPA and an EPA contractor collected samples from the two remaining tanks with materials in them, and also collected samples from several drums onsite.  EPA was preparing to dispose of these remaining wastes, but the responsible party was able to arrange for offsite disposal of all the drums and all the liquids except for those in tank 102 (the tank cleaning rinsewater).  However, upon reviewing the quantities of material removed from the site, there is a discrepancy between what had reportedly been in tank 109 (reported by CPG as 13,000 gallons, and confirmed by observation during the sampling event on February 15, 2008) and the waste quantity actually shipped (between five and six thousand gallons).  EPA is investigating this discrepancy.

The responsible party is also conducting a soil/groundwater investigation under the terms of a consent agreement with the Maryland Dept. of the Environment.  EPA will evaluate the results of that study and will offer assistance to MDE as needed.


Next Steps
Continue to oversee removal of the remaining wastes.  Determine the cause for the discrepancy in waste quantities.