CONTAINS CONFIDENTIAL BUSINESS INFORMATION

Exposure

At blending sites, the notified substance will be transferred from drums, rail cars, and tank 

trucks into storage tanks. (B) During connection and disconnection of lines, incidental skin 

contact from splashes, drips, and spills is possible. The transfer process from the tank truck

occurs by use of a 10 cm hosing. Connection of the hose takes 10 minutes. A special air 

back flush system is used to prevent spillage during transfer. By adhering to ISO 9001 

procedures, spills and leaks will be minimized. 

Transfer from storage tanks to blend tank will be automated, using computer controlled 

valves. The additive package containing ≤10 wt% of the notified substance is blended into 

the finished lubricant. Depending on the end uses of the finished lubricant, this translates 

into a maximum of 1.0 wt% of the notified substance in the finished oil. The blending 

process occurs in a closed system at 60 deg. C and is computer controlled, thereby 

excluding the potential for occupational exposure. The blended lubricant (containing a 

maximum of 1.0 wt.% notified substance) is transferred automatically to a storage tank. The 

finished lubricants are packaged for shipment in drums. 

(D) Workers may be exposed to the finished lubricant (containing a maximum of 1.0 wt% of 

notified substance) during the filling operations. 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. Bulk tank truck 

or rail car filling is performed by a transfer hose. Dermal exposure to drips and spills of 

blended lubricant is possible during the connection and disconnection of transfer hoses 

during the filling of bulk containers. The small container packaging machine is a fullyautomated machine and will fill quarts. 

The repackaging facility uses automated weight scales to fill the containers, and worker 

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

mechanism properly enters the container before it is filled. 

The blending facilities are well ventilated, with control systems for accidental spills and 

wastewater treatment. Workers involved in the blending activities receive training in the 

handling of additive packages, and wear personal protective equipment such as gloves, eye 

protection, protective clothing and hard hats. 

Laboratory Staff

Laboratory staff will take samples of the notified chemical in the additive package as well as 

the blended oil products for testing. (A),(C) During sampling and analysis of the additive 

package there may be skin contact. However, minimal exposure will occur during the 

laboratory testing since it will occupy only a few minutes per batch.

End Users

We expect the finished oil to be distributed in the following manner: 67% in small packages 

and 33% in drums. 

The bulk of the finished product will be sold in small containers to automotive customers. 

The finished lubricants containing a maximum concentration of 1.0 wt% of the notified 

substance will be used mostly by consumers who buy small containers off the shelf at 
CONTAINS CONFIDENTIAL BUSINESS INFORMATION

service stations and lubricate their own automotive engines. We assume only some of these 

users will recycle their used oil.

The drums will be sold to commercial automotive and industrial engine service outlets. A 

pump will be inserted into the drum which will pump the finished lubricant. It is estimated it 

will take one worker 10 minutes to insert the pump. In many cases, any stationary engines

involved will be routinely lubricated using dedicated lubricating oil reservoirs and piping to 

add fluids directly without human intervention. For automotive applications, workers will 

check lubricant levels in the engine manually and top-off as needed using fluids added via 

pneumatic delivery equipment. We assume that all of the commercial end users will recycle 

their used oil. 

 Activity Workers 

Exposed

Duration of 

Exposure

Protective 

Equipment/Eng. 

Controls

% in 

Formulation

Commercial >1000 7 hr, 250 

day/yr

Coveralls, gloves 1.0

Release

The additive package containing up to 10 wt% of the notified substance will be unloaded 

from tank trucks using ISO 9001 procedures, which limit spills and leaks to 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 382 g/year of the notified substance which will be sent to waste water 

treatment. The hose end is kept on an oily 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 re-refining 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 environment. This 

additional process will remove another 80% of the spilled additive package. Altogether up to 

8 g/year will be released to the environment.

Release to the environment may also occur in the unlikely event of an accident during 

transport, an accidental leak, or improper disposal of used oil. We encourage proper 

recycling, but understand that some used oil will end up in the environment. The notified 

chemical will be transported in drums, rail cars, and tank trucks to the blending facilities. 

The blending operations will take place at specially constructed sites owned and operated by 

the major lubricant manufacturers. It is anticipated that there will be minimal release of the 

notified chemical during transfer from the storage containers to the blending tanks, as a 

special air back flush system prevents any spillage. Blending occurs in fully enclosed 

automated systems. Blending tanks will be cleaned with lube oil, which will typically be 

recycled during subsequent blending, or incinerated. Any spills incurred in the blending 

operations will be contained within concrete bunds and either reclaimed or sent to on-site 
CONTAINS CONFIDENTIAL BUSINESS INFORMATION

waste-water treatment facilities where residual hydrocarbon based products will be 

separated from the aqueous stream by the American Petroleum Industry (API) process, with 

a claimed removal of greater than 90%. Before being released to the sewage system, the 

aqueous waste undergoes further treatment involving pond aeration and sand filtration. The 

remaining oily waste will be incinerated. 

Drums

Empty drums which distribute the finished lubricant containing residual notified chemical 

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

treatment facilities. Assuming 33% 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 101 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. 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. (2) Therefore, amount of the notified substance released to 

the environment from drums is expected to be no more than 2 kg/yr.