CONTAINS CONFIDENTIAL BUSINESS INFORMATION

Manufacturing Process Description

Manufacturing

The notified substance will be manufactured by a toller in the United States. 

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CONTAINS CONFIDENTIAL BUSINESS INFORMATION

Handling of component (at the Toller facility)

Laboratory Staff

(A) Exposure to workers can occur during sample removal for laboratory analysis. After 

manufacturing, the product is sampled from the storage tank by one worker wearing eye 

protection, protective clothing, rubber gloves and a hardhat to ensure the physical and chemical 

properties of the product are met. The analysis is done in a laboratory by one worker and takes 

only a few minutes.

Cleaning Reactor 

The reactor will be cleaned approximately once every quarter. (B) Two operators will use 

aluminum rods to scrape out the material which has built up in the reactor. Exposure can occur 

during this cleaning, so the operators will wear eye protection, protective clothing, rubber gloves 

and a hardhat. The cleaning process should take less than 30 minutes. The sludge will be 

collected and treated in the chemical waste and storm water systems. This process takes 

approximately 12 hours. It is estimated that 5 kg of sludge is obtained from each cleaning, for a 

maximum annual total of 20 kg/yr of the notified substance. The sludge is sent to the storm water 

system. The storm water system is an on-site chemical waste water system that includes an API 

water and oil separator to separate the oil waste from the water. Approximately 90% of the sludge 

will be removed from the waste water by the API. The waste oil containing the notified substance 

is sent to a used oil recycler who re-refines the waste oil into fresh lubricant base stock using 

hydrocracking technology. The bottoms product containing the notified substance from the rerefining process becomes asphalt. The waste water is then sent to a pond where it is further 

treated by induced air floatation and biological treatment. The waste biological sludge from the 

biological treatment is sent off site for incineration. (1) After biological treatment, the waste water 

is sent through a biodisk filter followed by sand filtration before the treated water is released to 

the local waterways. This additional process will remove another 80% of the notified substance. 

Altogether 0.4 kg/year will be released to the local waterways. [ ]
CONTAINS CONFIDENTIAL BUSINESS INFORMATION

At our blending facility, we will blend the notified substance into automotive engine oil 

additive packages. The blending process is a fully-automated in-line blender system whereby the 

components are fed into the blender by automated systems which control the flow of the 

component being fed from the tank to the blender based on the percentage of that component 

going into the final package. Typically, the notified substance will be blended at approximately 

≤10 wt%. In addition to the notified substance, the additive package will contain highly refined 

neutral oil, dispersants, corrosion inhibitors, friction modifiers, and other additives.

Once the components are blended in-line, they run down to a finished package customer tank, 

where the specifications of the product are tested. This run-down tank is reserved for families of 

products; therefore they will not be cleaned after each batch. These tanks are serviced every one 

to five years, depending on the type of product and maintenance schedules. The finished 

additive packages are loaded into drums, tank trucks, or rail cars. 

Laboratory Staff

(C) After blending, the product is sampled from the finished product tank by one worker wearing 

eye protection, protective clothing, rubber gloves and a hard hat to ensure the physical and 

chemical properties of the product are met. The analysis is done in a laboratory by one worker 

and takes only a few minutes.

Loading Trucks/Rail Cars

The product will be sold as part of an additive package containing ≤10% notified substance. We 

estimate that 50% of the product will be delivered by tank truck or rail car and 50% will be

delivered in drums. 

(D) The filling of tank trucks and rail cars is done with a minimum of worker exposure. The 

lubricant additive package containing the notified substance will be loaded by one worker wearing 

protective clothing, rubber gloves, safety glasses and a hardhat. The top of the rail car or tank 

truck is opened and the product is pumped from a storage tank through hard piping. The area 

around and under the rail car/tank truck is cement with an open drain that has a steel grate on top. 

After the rail car/tank truck is loaded, the hose is automatically pigged to the rail car or tank truck. 

Using ISO 9001 procedures, spills and leaks are less than 50 grams of additive package or a 

maximum of 5 grams of the notified substance per tank truck shipment. Assuming 50% of the 

additive package will be shipped by tank truck or rail car, this translates to 0.38 kg/year of the 

notified substance which will be sent to waste water treatment. The hose end is kept on an oily 

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CONTAINS CONFIDENTIAL BUSINESS INFORMATION

drain when not in use. Any spills or leaks are sent to the storm water system. The storm water 

system is an on-site chemical waste water system that includes an API water and oil separator to 

separate the oil waste from the water. Approximately 90% of the additive package will be 

removed from the waste water by the API. The waste oil containing the notified substance is sent 

to a used oil recycler who re-refines the waste oil into fresh lubricant base stock using 

hydrocracking technology. The bottoms product containing the notified substance from the rerefining process becomes asphalt. The waste water is then sent to a pond where it is further 

treated by induced air floatation and biological treatment. The waste biological sludge from the 

biological treatment is sent off site for incineration. (2) After biological treatment, the waste water 

is sent through a biodisk filter followed by sand filtration before the treated water is released to 

the This additional process will remove another 80% of the spilled additive 

package. Altogether up to 8 g/year will be released to the 

Cleaning Rail Cars and Tank Trucks

Rail cars and tank trucks delivering the additive packages are generally not cleaned after every 

delivery. When cleaned, (~six times per year) rail cars and tank trucks would be cleaned with 

steam at the facility with the waste being released to the storm water system. The 

storm water system is an on-site chemical waste water system that includes an API water and oil 

separator to separate the oil waste from the water. Approximately 90% of the notified substance 

will be removed from the waste water by the API. The waste oil containing the notified substance 

is sent to the used oil recycler who re-refines the waste oil into fresh lubricant base stock using 

hydrocracking technology. The bottoms product containing notified substance becomes asphalt. 

The waste water is then sent to a pond where it is further treated by induced air floatation and 

biological treatment. The waste biological sludge from the biological treatment is sent off site for 

incineration. (3) After biological treatment, the waste water is sent through a biodisk filter and 

sand filtration before the treated water is released to the This additional 

process will remove another 80% of the notified substance. Altogether, a maximum of 0.24

kg/year will be released to the 

Loading Drums

The drumming facility uses automated weight scales to fill the drums, and worker exposure may 

occur as the operator watches (from about 3-6 feet away) to ensure the drum filling mechanism 

properly enters the drum before the drum is filled. The bungs and labels are put on by the 

operators. 

Cleaning Drums

Empty drums which deliver the additive package to the lubricant blender containing residual 

notified chemical would be steam cleaned, with the resultant aqueous waste sent to on-site 

waste-water treatment facilities. Assuming 50% of the volume is delivered by drum, and that 

0.1% of the finished product remains in the container after use, we estimate worst case 153 kg/yr 

of the notified substance will be sent to the wastewater treater. 

The water system includes an API water and oil separator to separate the oil waste from the 

water. Approximately 90% of the notified substance will be removed from the waste water by the 

API. The waste oil containing the notified substance is sent to the used oil recycler who re-refines 

the waste oil into fresh lubricant base stock using hydrocracking technology. The bottoms product 

containing notified substance becomes asphalt. The waste water is then sent to a pond where it 

is further treated by induced air floatation and biological treatment. The waste biological sludge 

from the biological treatment is sent off site for incineration. (4) After biological treatment, the 

waste water is send through a biodisk filter and sand filtration before the treated water is released 

to waterways. This additional process will remove another 80% of the spilled additive package. 

Therefore, the maximum amount of the notified substance released to the environment from 

drums is expected to be 3.05 kg/yr. 

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