FINASOL OSR 52 IBC. National Contingency Plan Product Bulletin

(6) Product storage [§ 300.915(a)(6)]
1. Maximum storage temperature (e.g., ^oF and/or ^oC): 45^oC (113^oF)
2. Minimum storage temperature (e.g., ^oF and/or ^oC): -5^oC (23^oF)
3. Optimum storage temperature (e.g., ^oF and/or ^oC): 5-35^oC (41-95^oF)
4. Humidity (e.g., g/kg):

• Maximum humidity: 90%
• Minimum humidity: 30%
• Optimal humidity: 70%

5. Other relevant conditions for product storage: Direct sunlight, high humidity and saltwater can cause damage to containers; hence, their exposure should be minimized as far as possible. It is, therefore, preferable to store dispersant indoors (i.e., inside warehouse facilities that provide adequate ventilation). If outdoors storage is unavoidable, adequate shelter/cover should be provided. Exposure to temperature extremes and fluctuations should also be avoided wherever feasible. In locations where high or low ambient temperatures are encountered, the use of climate-controlled facilities may be necessary.
6. Description of the consequences to performance if product is not stored within these limits: Phase separation and/or loss of efficiency may occur if the product is not stored within these limits.

(7) Shelf life storage conditions [§ 300.915(a)(7)]
The initial shelf life is 5 years when the containers remain capped and sealed to prevent contamination and evaporation of solvents and are stored as per advised storage conditions. After storage, stir the product and ensure homogeneity before use.

This 5-year value for initial shelf life derives from a study from French laboratory CEDRE presented at Arctic and Marine Oilspill Program (AMOP) 1997. This study, based on the quality controls carried out on French Navy dispersant stockpiles (including periodic control every 5 years after purchase), concludes that FINASOL OSR 52 is stable and keeps its efficiency in the range 0 to 6 years. Another study conducted at CEDRE laboratory on FINASOL OSR 52 samples aged from 7 to 25 years has showed that the efficiency remained unaffected and still within the range required for marine dispersants in France. This is reasonably assumed to be also applicable to FINASOL OSR 52 IBC. Past this five year period, extended shelf life may be granted upon re-testing of the product efficiency (and toxicity if required). Guidance from IPIECA's support document "Dispersant Storage, Maintenance, Transport and Testing" should be [reviewed during] re-testing process:

• Testing should be performed on samples representative of 10% of stock volume (e.g. 1 IBC tote out of 10 for a same production batch)
• Sampling can be performed with the help of a sampling thief
• Samples should be stored in compatible (glass or HOPE) and distinctly labelled bottles, with reference from the original container
• Tests to be performed and pass criteria are the same as those required for product [listing] on NCP Product Schedule

(10) Recommended product use procedures [§ 300.915(a)(10)]

1. Application Method: FINASOL OSR 52 IBC is applied effectively by aircraft or helicopter, from boats, or by subsea injection. Its viscosity has been chosen to be adapted to the usual dispensing systems (nozzles, ramps, nozzle canon, SSDI wand, etc.). FINASOL OSR 52 IBC is intended to be used pure, however, it can be prediluted with up to 10% seawater if needed to reduce its viscosity in cold weather conditions.
Spraying must not give too fine or atomized droplets as in fog. It must be done as moderately coarse droplets, with diameters in the range of 500 - 1000 µm, whether application is by surface vessel or aircraft.

2. Concentration / Application Rate: It is generally recommended to use marine dispersants, including FINASOL OSR 52 IBC in particular, with a 1:5 to 1:50 dispersant-to-oil ratio. A 1:20 ratio would correspond approximately to 15 gallons per ton of oil.
However, this recommendation may be adapted according to the nature of the oil, its state of weathering, temperature, thickness of the slick, and other circumstances of the spill, based on in-situ trials on a small scale.

3. Conditions for Use: When treating a spill with FINASOL OSR 52 IBC, it is recommended to start the treatment as early as possible, to avoid a thickening of the slick due to either evaporation of light fractions or formation of water-in-oil emulsion.

Apart from its direct influence on both oil and dispersant viscosities, which are treated separately in Application Method (above) and Application Restrictions (below), water temperature (and ice coverage if relevant) have not been identified as having a decisive influence on FINASOL OSR 52 IBC efficiency, as can be observed in efficiency results at 5^oC and inferred from extrapolating from results obtained with FINASOL OSR 52 in a study conducted by Arctic Response Technology. Use only receptacles, joints, pipes, etc. which are resistant to hydrocarbons. Do not spray at high pressure (> 3 bar).

Application Restrictions: It is generally considered for marine dispersants in general, including FINASOL OSR 52 IBC in particular, that:

• Use should be restricted to pollutants with a viscosity not higher than 10000 mm²/s, preferably not higher than 5000 mm²/s (at sea temperature at the location of the spill). For pollutants whose viscosity is enclosed between 5000 and 10000 mm²/s, result is uncertain, and testing is recommended before treating a spill.
• Sea conditions must allow sufficient energy for breaking the oil into droplets small enough to be dispersed. Oil spill dispersion is considered difficult if not impossible for sea conditions below Beaufort 3 level. Inversely, high winds and/or rough sea (Beaufort 7 or above level) will make dispersant application difficult if not impossible both by boat or aircraft (this is usually taken into account in the decision matrixes for dispersant use). FINASOL OSR 52 IBC has been optimized to treat spills in salty water. Efficiency may be reduced in case of application in low salinity water (below 20 psu).
• Although this may depend on local policies and On Scene Coordinator appreciation, it is usually recommended to use marine dispersants at sea and not too close from the shore (or from fish/shell farms) and/or in too shallow waters.

Containment, Collection, Recovery, and Disposal: FINASOL OSR 52 IBC is designed to be used as dispersant. As such, it is readily dispersed in sea water and aims at dispersing oil into small droplets and dilute it in sea water. As a consequence, there is no need to consider containment, collection, recovery or disposal for FINASOL OSR 52 IBC after use. Disposal of unused (e.g. expired) product should at all times comply with the requirements of environmental protection and waste disposal legislation and any regional local authority requirements. Disposal should be made via a licensed waste disposal contractor.

(12) Physical/chemical properties [§ 300.915(a)(12)]

(13) Identification and concentration of product components [§ 300.915(a)(13)] 
Under § 300.950, you may only claim as Proprietary Business Information (PBI) the concentration, the maximum, minimum, and average weight percent; and the units of each component of the total formulation as identified in § 300.915(a)(13) and (14) and as applicable. All other product information submitted to EPA as required under § 300.915 and § 300.955 will be available for public disclosure upon submission, without further notice to the submitter.

(15) Data, methodology and supporting documentation for levels of the following [§ 300.915(a)(15)]:

(21) International product testing, data, and/or certifications [§ 300.915(a)(21)]
Used as a marine dispersant in France and Spain based on the below results:

Dispersant efficacy test and listing criteria [§ 300.915(b)(1)]
Listing Criteria: Dispersant must demonstrate for each temperature a Dispersant Effectiveness (DE) at the 95% lower confidence level (LCL95) greater than or equal to:

• ≥70% for Strategic Petroleum Reserve Bryan Mound test oil at 5^oC; and
• ≥75% for Strategic Petroleum Reserve Bryan Mound test oil at 25^oC.

Dispersant toxicity tests and listing criteria [§ 300.915(b)(2)] 
Listing Criteria: Dispersant tested alone must demonstrate:

• For acute toxicity a median lethal concentration for 50% of the test species (LC50) at the lower 95% confidence interval greater than 10 ppm.
• For developmental toxicity the inhibition concentration for 50% of the test species (IC50) at the lower 95% confidence interval greater than 1 ppm; and
• For sub-chronic toxicity the No Observed Effect Concentration (NOEC) greater than 1 ppm.