CONTAINS CONFIDENTIAL BUSINESS INFORMATION

**Exposure**

At blendi ng sites, the notified substance will be transferred from drums, rail cars , and tank trucks into storage ta nks. (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 ai r 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 packag e containing ≤10 wt% of the notified substance is blende d into

the finished lubricant

. Depending on the end u s es of the finished lubricant, t his translates

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

. The blending process occurs in a close d 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 lubrican ts 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 i s 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 fully

automat ed 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 wi ll take samples of the notified chemical in the additive package as well as the blended oil products for testing. (A),(C) Durin g 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 distrib uted in th e following manner: 67% in small packages

and 33 % in drums

.

The bulk of the finished prod uct 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 mostl y by consume rs who buy small containers off the shelf atCONTAINS CONFIDENTIAL BUSINESS INFORMATION

serv ice 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 indust rial 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 routine ly 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 delive ry 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 s ubstance will be unloaded

f rom tank trucks u sing 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 o n

- 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 subst ance 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 sen t 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 biodi sk filter followed by sand filtration before the treated water is r eleased to the environment . This additional process will remove another 80% of the spilled additive package. Altogether up to

8 g/year wil l be released to the environment

.

Release to the e nvironment 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 min imal 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 typ ically 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

- siteCONTAINS CONFIDENTIAL BUSINESS INFORMATION

waste

- water treatment facilities where residua l hydrocarbon based products will be separated from the aqueous stream by the American Petroleum Industry (API) process, with

a cl aimed removal of greater than 90% . Before being released to the sewage system, the aqueous waste undergoes further treatment i nvolving 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 o n

- 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 t reater.

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 s ent 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 pr ocess 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

.