FFT-SOLUTION®

TECHNICAL PRODUCT BULLETIN #D-17
USEPA, OEM REGULATIONS IMPLEMENTATION DIVISION
ORIGINAL LISTING DATE: NOVEMBER 01, 2011
“FFT-SOLUTION®”
LISTING CHANGES PENDING; VERIFICATION BY MANUFACTURER AND EPA REQUIRED

I. NAME, BRAND, OR TRADEMARK
FFT-SOLUTION® Type of Product: Dispersant

II. NAME, ADDRESS, AND TELEPHONE NUMBER OF MANUFACTURER/CONTACT
Fog Free Technologies, LLC 4365 Dorchester Road Building 300, Suite 301 North Charleston, SC 29405 Product Management Office Phone: (843) 735-6626 Mobile: (478) 697-2588 E-mail: updated information required Website: http://www.ffttechnologies.com/ (Mr. William H. Knight)

III. NAME, ADDRESS, AND TELEPHONE NUMBER OF PRIMARY DISTRIBUTORS
Fog Free Technologies, LLC 4365 Dorchester Road Building 300, Suite 301 North Charleston, SC 29405 Product Management Office Phone: (843) 735-6626 Mobile: (478) 697-2588 E-mail: updated information required Website: http://www.ffttechnologies.com/ (Mr. William H. Knight)

IV. SPECIAL HANDLING AND WORKER PRECAUTIONS FOR STORAGE AND FIELD APPLICATION
1. Flammability: IMO: Non-Flammable, DOT: Non-Hazardous 2. Ventilation: Lowest level of skin protection is acceptable, but no special ventilation is required. 3. Skin and eye contact; protective clothing; treatment in case of contact: Lowest level of skin protection is acceptable. Avoid eye contact. In case of eye contact, immediately flush eyes with large amounts of water for at least 15 minutes. Avoid contact with skin. In case of skin contact, immediately flush with water and soap if available. For open systems where contact is likely, wear long sleeve shirt, chemical resistant gloves and chemical goggles. 4.a. Maximum storage temperature: 170°F 4.b. Minimum storage temperature: 30°F 4.c. Optimum storage temperature range: 40°F to 105°F 4.d. Temperatures of phase separations and chemical changes: None

IV. SPECIAL HANDLING AND WORKER PRECAUTIONS FOR STORAGE AND FIELD APPLICATION

1. Flammability: IMO: Non-Flammable, DOT: Non-Hazardous
2. Ventilation: Lowest level of skin protection is acceptable, but no special ventilation is required.
3. Skin and eye contact; protective clothing; treatment in case of contact: Lowest level of skin protection is acceptable. Avoid eye contact. In case of eye contact, immediately flush eyes with large amounts of water for at least 15 minutes. Avoid contact with skin. In case of skin contact, immediately flush with water and soap if available. For open systems where contact is likely, wear long sleeve shirt, chemical resistant gloves and chemical goggles.
4.a. Maximum storage temperature: 170°F
4.b. Minimum storage temperature: 30°F
4.c. Optimum storage temperature range: 40°F to 105°F
4.d. Temperatures of phase separations and chemical changes: None

V. SHELF LIFE
The shelf life of unopened drums of FFT-SOLUTION® is limited to 60 months. Storage should be in a semi-controlled warehouse, out of direct sunlight.

VI. RECOMMENDED APPLICATION PROCEDURE
1. Application Method: Aerial Spraying – Aircraft provide the most rapid method of applying dispersants to an oil spill and a variety of aircraft can be used for spraying. For aerial spraying, FFT-SOLUTION® is applied undiluted. Typical application altitudes of 30 to 50 feet have been used, although higher altitudes may be effective under certain conditions. Actual effective altitudes will depend upon application equipment, weather, and aircraft. Careful selection of spray nozzles is critical to achieve desired dose levels, since droplet size must be controlled. Many nozzles used for agricultural spraying are of low capacity and product fine a spray. A quarter-inch open pipe may be all that is necessary if the aircraft travels at 120 mph (104 knots) or more, since the air shear at these speeds will be sufficient to break the dispersant into the proper sized droplets. Optimal temperatures for application are between 33°F and 105°F. Boat Spraying – FFT-SOLUTION® may also be applied by workboats equipped with spray booms mounted on the stern of the vessel. (Mounting boom on the stern prevents any over spray from making contact with boat operators.) The preferred and most effective method of application from a workboat is to use a low-volume, low-pressure pump so the chemical can be applied undiluted. Standard agriculture spray equipment is designed to make dosage adjustments or provide different spray tips that effect dosage rates. Natural wave or boat wake action usually provides adequate mixing energy to disperse the oil. A typical agriculture spray boom can be mounted to the stern to get wide coverage. The booms on shrimp boats also can be retrofitted to cover a much wider path during applications. The manufacturer also recommends that in lieu of spray tips on the booms, spray tips be changed into solid tubing for injection of FFT-SOLUTION® 3 to 5 feet below the water surface. This will get the thicker crude slicks injected faster and with better results. FFT-SOLUTION® should be applied as droplets, not fogged or atomized. 2. Concentration/Application Rate: A treatment rate of about 2 to 10 U.S. gallons per acre, or dispersant to oil ration of 1:50 to 1:10 is recommended. This rate varies depending on the type of oil, degree of weathering, temperature, and thickness of the slick. 3. Conditions for Use: FFT-SOLUTION® can be applied to weathered oil as well as light, medium, or heavy oils. Early treatment even at reduced treatment rates, can also counter the foaming tendencies of the spilled oil in turbulent waters. FFT-SOLUTION® can be used on any type oil spills in salt water.

VI. RECOMMENDED APPLICATION PROCEDURE

1. Application Method: Aerial Spraying – Aircraft provide the most rapid method of applying dispersants to an oil spill and a variety of aircraft can be used for spraying. For aerial spraying, FFT-SOLUTION® is applied undiluted. Typical application altitudes of 30 to 50 feet have been used, although higher altitudes may be effective under certain conditions. Actual effective altitudes will depend upon application equipment, weather, and aircraft. Careful selection of spray nozzles is critical to achieve desired dose levels, since droplet size must be controlled. Many nozzles used for agricultural spraying are of low capacity and product fine a spray. A quarter-inch open pipe may be all that is necessary if the aircraft travels at 120 mph (104 knots) or more, since the air shear at these speeds will be sufficient to break the dispersant into the proper sized droplets. Optimal temperatures for application are between 33°F and 105°F.

Boat Spraying – FFT-SOLUTION® may also be applied by workboats equipped with spray booms mounted on the stern of the vessel. (Mounting boom on the stern prevents any over spray from making contact with boat operators.) The preferred and most effective method of application from a workboat is to use a low-volume, low-pressure pump so the chemical can be applied undiluted. Standard agriculture spray equipment is designed to make dosage adjustments or provide different spray tips that effect dosage rates. Natural wave or boat wake action usually provides adequate mixing energy to disperse the oil. A typical agriculture spray boom can be mounted to the stern to get wide coverage. The booms on shrimp boats also can be retrofitted to cover a much wider path during applications. The manufacturer also recommends that in lieu of spray tips on the booms, spray tips be changed into solid tubing for injection of FFT-SOLUTION® 3 to 5 feet below the water surface. This will get the thicker crude slicks injected faster and with better results. FFT-SOLUTION® should be applied as droplets, not fogged or atomized.

2. Concentration/Application Rate: A treatment rate of about 2 to 10 U.S. gallons per acre, or dispersant to oil ration of 1:50 to 1:10 is recommended. This rate varies depending on the type of oil, degree of weathering, temperature, and thickness of the slick.

3. Conditions for Use: FFT-SOLUTION® can be applied to weathered oil as well as light, medium, or heavy oils. Early treatment even at reduced treatment rates, can also counter the foaming tendencies of the spilled oil in turbulent waters. FFT-SOLUTION® can be used on any type oil spills in salt water.

VII.TOXICITY AND EFFECTIVENESS

a. Toxicity:

Material Tested	Species	LC50 (ppm)
FFT-SOLUTION®	Menidia beryllina Mysidopsis bahia	5.34 96-hr 2.72 48-hr
No. 2 Fuel Oil	Menidia beryllina Mysidopsis bahia	40.80 96-hr 5.19 48-hr
FFT-SOLUTION® & No. 2 Fuel Oil (1:10)	Menidia beryllina Mysidopsis bahia	5.14 96-hr 2.75 48-hr
Reference Toxicant (SDS)	Menidia beryllina Mysidopsis bahia	2.42 96-hr 6.97 48-hr

b. Effectiveness:
SWIRLING FLASK DISPERSANT EFFECTIVENESS TEST WITH SOUTH LOUISIANA (S/L) AND PRUDHOE BAY (P/B) CRUDE OIL

Oil	Effectiveness (%)
Prudhoe Bay Crude	49.97%
South Louisiana Crude	48.87%
Average of Prudhoe Bay and South Louisiana Crudes	49.42%

VIII. MICROBIOLOGICAL ANALYSIS
NA

IX. PHYSICAL PROPERTIES
1. Flash Point: 170°F 2. Pour Point: 23°F 3. Viscosity: 450 SUS @100°F 4. Specific Gravity: 1.0302 @60°F 5. pH: 9.96 6. Surface Active Agents: CONFIDENTIAL 7. Solvents: None 8. Additives: None 9. Solubility: Product is 100% soluble in water

X. ANALYSIS FOR HEAVY METALS, CYANIDE, AND CHLORINATED HYDROCARBONS

Compound	Concentration (ppm)
Arsenic	ND
Cadmium	ND
Chromium	ND
Copper	ND
Lead	ND
Mercury	ND
Nickel	ND
Zinc	ND
Cyanide	ND
Chlorinated Hydrocarbons	ND

FFT-SOLUTION®

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