Ptizer Inc 235 East 42nd Street New York, NY 1OOl7-5755 March 25,2008 Steven Reynolds Director U.S.Nuclear Regulatory Commission Division of Nuclear Material Safety 2443 Warrenville Road, STE 2 10 Lisle, IL 60532-4352 -Re: Parent Company Guarantee for Pharmacia & Upjohn Co. (Kalamazoo, MI) Dear Mr. Reynolds: I am the Chief Executive Officer of Pfizer Inc. located at 235 East 42ndStreet in New York, NY 10017. This letter is in support of this firm's use of the financial test to demonstrate financial assurance, as specified in 10 CFR Part 30. I hereby certify that Pfizer Inc. is currently a going concern, and that it possesses positive tangible net worth in the amount of $23,129,000,000. This firm is required to file a Form 10K with the U.S. Securities and Exchange Commission for the latest fiscal year. The fiscal year of this firm ends on December 3 1. I hereby certify that the content of this letter is true and correct to the best of my knowledge. ofthe ~oard Chief Executive Officer RECEIVED MAR 2 8 2008 .' . Pfizer Inr 235 East 42nd Street New lork. NY 10007-5755 March 25, 2008 Steven Reynolds Director U .S . N uc I ear Reg u la t ory C om m i ss i on Division of Nuclear Material Safet) 2443 Warrenville Road, STE 2 IO Lisle, IL 60532-4352 -Re: Financial Assurance for Pharmacia & Upjohn Company LLC (Kalainazoo, MI) Dear Mr. Reynolds: 1 am the chief financial officer of Pfizer Inc.. 235 East 42'IdStreet, New York. Ne\\ Yorh 1001 7. a corporation. This letter is in support ofthis firm's use of the parent coinpan\ guarantee financial test to demonstrate financial assurance, as specified in IO CFR Part 30. This firm guarantees, through the parent company guarantee submitted to demonstrate compliance under 10 CFR Part 30, the decoinmissioning of the following facilities owned or operated bq this firm. The current cost estimates or certified amounts for decommissioning, so guaranteed, are show for each fac i 1 i ty : Certified Amount or Name of Facility Location of Facility Current Cost Estimates Pliarmacia & Upjohn 7000 Portage Road, $17.133.000 Company LLC Kalamazoo, MI 4900 1 License #2 1-00 182-03 I hereby certify that Pfizer Inc. is currently a going concern, and that it possesses p0sitiL.e tangible net worth in the amount of $23,129,000,000. The fiscal year ofthis firm ends on December 3 1. The figures for the foIIo\~ingitems niarhed \vith a11 asterisk are derived from this firm's independently audited, year-end fliiancial statements and footnotes for the latest completed fiscal year ended December 3 I, 2007, or from the firm's internal accounting records underlying such financial statement. A copy of this firm's most recent financial statements is enclosed. This firm is required to file a Form IO-K with the U.S. Securities and Exchange Commission for the latest fiscal year. This firm has at least one class of equity securities registered under the Securities Exchange Act of 1934. Alternative 2 1 Current decommissioning cost estimates or certified amounts: a. Decommissioning amounts covered by this parent $17,133,000 compaiiy guarantee b. All decommissioning amounts covered by other $3,987.1 38 NRC or Agreement State parent company guarantees or self-guarantees. c. All amounts covered bl parent company guarantees, $l35,7 13,646 self-guarantees, or financial tests of other Federal or State agencies (e.g., EPA) TOTAL $I 56,833,784 2. Current bond rating of most recent unsecured issuance of Rating: Name of Rating this firm. Senrice A AA/Aa 1 Standard & Poor's and Moody's 3. Date of issuance of bond 05/14/07 & 12/13/07 4. Date of maturity of bond 05/15/17 & 12/15/14 *5. Tangible net worth (If any portion of estimates for $23,129,000,000 decommissioning is included in total liabilities on your firm's financial statements, you may add the amount of that portion to this line.) *6. Total assets' in United States (required only if less than $29.5 12.000,000 90 percent of firm's assets are located in the United States) YES NO 7. Is line 5 at least 10 times line I? X *8. Are at least 90 percent of firm's assets located in the United States? If not. X complete line 9. 9. Is line 6 at least IO times line I? X IO. Is the rating specified on line 2 "A" or better X 1 I. Does the licensee have at least one class of equity securities registered X under the Securities Exchange Act of 1934? I Represents identifiable assets only which includes net accounts &r notes receivable. inventories, net fixed assets, goodwill, and net intangibles. 2 I hereby certify that the content of this letter is true and correct to the best of my knowledge. Effective Date: March 25, 2008 Pfizer Inc. Fa7 J'c2L-h Frank A. D'Amelio Senior Vice President and Chief Financial Officer Signature of witness or notary: @M& cc: Dee L. Clernent (Kalarnazoo, MI) 3 KPMG LLP Telephone 212 758 9700 345 Park Avenue Fax 212 758 9819 NewYork. NY 10154 Internet www.us kpmg corn Independent Accountants’ Special Report on Confirmation of Letter from Chief Financial Officer The Board of Directors and Management of Pfizer Inc.: We have audited the consolidated financial statements of Pfizer Inc. (“the Company”) for the year ended December 3 I, 2007, and have issued our report thereon dated February 29,2008. Our work did not extend from the period of February 29,2008 through the date herein. We conducted our audit in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. As audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the consolidated financial statements. An audit also includes assessing the accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. The Company acquired Pharmacia Corporation on April 16, 2003. Pharmacia & Upjohn Company is a subsidiary of Pharmacia Corporation. Pfizer Inc has prepared documents to demonstrate its financial responsibility under the United States Nuclear Regulatory Commission’s (“NRC”) financial assurance regulations, 10 CFR Part 30. This letter is furnished to assist the following licensee in complying with these regulations and should not be used for other purposes: Pharmacia & Upjohn Company 7000 Portage Road Kalamazoo, MI 4900 1 License Nos.: 2 1-001 82-03 We have performed the procedures enumerated below, which were agreed to by management of Pfizer Inc., solely to assist management of the Company in complying with the NRC - Division of Waste Management financial assurance regulations, Title 10, Chapter 1 of the Code of Federal Regulations, part 30 (“10 CFR part 30”) Appendix C, Criteria Relating to the Use of Financial Tests and Self Guarantees for Providing Reasonable Assurance of Funds for Decommissioning, as of and for the year ended December 3 1,2007. Management of the Company is responsible for Pfizer Inc.’s compliance with those requirements. This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of management of the Company. Consequently, we make no representations regarding the KPMG LLP a U S limited liability pannership IS the U S member firm of KPMG Internatmnal. a Swiss cmperatlve sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The attached schedule, which was prepared by management of the Company, reconciles the specified financial information furnished in the Company Chief Financial Officer’s (“CFO’s”) letter in response to the regulations with the Company’s audited financial statements (“the Letter”) as of and for the year ended December 3 1,2007. In connection therewith, we have: 1. Compared the amounts in the column “Per Financial Statements” to the amounts contained in the Company’s audited financial statements for the year ended December 3 I, 2007 and found them to be in agreement; 2. Compared the amounts in the column “Per CFO’s Letter” to the amounts set forth in the Letter prepared in response to the NRC’s request and found them to be in agreement; 3. Compared the amounts in the column “Reconciling Items” to the amounts in the Company’s Computron general ledger as of and for the year ended December 3 1,2007 and found them to be in agreement; and 4. Recomputed the mathematical accuracy of the totals set forth in the attached schedule. We were not engaged to, and did not, conduct an examination, the objective of which would be the expression of an opinion on the specified amounts in the Letter. Accordingly, we do not express such an opinion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you. This report is intended solely for the information and use of the Board of Directors and management of Pfizer Inc., and is not intended to be and should not be used by anyone other than the Board of Directors and management of Pfizer Inc. March 25,2008 PFIZER INC. Year Ended December 3 I, 2007 Dollar amounts in millions Schedule of Reconciling Amounts Contained in Chief Financial Officer’s Letter with Amounts in Financial Statements Per Line Number Per Financial Reconciling CFO’s in CFO’s Letter Statements Items Letter 5 Total Shareholder’s Equity $65,009 Less: Goodw i I I ($21,382) Less: Identifiable intangible assets, less accuin u I ated aiiiort izatio ri ($20,498) Accrued decommissioning costs included in current liabilities Tangible Net Worth $23,129 6 Total Assets $I 15,268 Less: Assets held outside the U.S.