FINASOL® OSR 52. 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 20 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.

A study has been mandated to CEDRE laboratory on FINASOL OSR 52 samples aged from 7 to 25 years. It showed that the efficiency remained within the range required for marine dispersants in France.

Additionally, data from stockpile monitoring (using the LR448 method performed at a single laboratory using Medium Fuel Oil (MFO) cut with kerosine to a viscosity of 2,000 mPa s) of 75 different batches in five different countries (France, UK, Bahrain, Singapore, and South Africa) confirms that efficiency is retained on all batches after 10 years of storage, with an average efficiency measured on all tested samples at 90.9% and a yearly average of tested batches fluctuating by no more than 2% from this value.

Finally, a study from French laboratory CEDRE has been presented at Arctic and Marine Oilspill Program (AMOP) 1997. It is based on the quality controls carried out on French Navy dispersant stockpiles (including periodic control every 5 years after purchase) and concludes that FINASOL OSR 52 is stable and keeps its efficiency in the range of 0 to 6 years (no older samples of FINASOL OSR 52 were available at the time of this study).

Past this 20-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 sought in re-testing process:

• Testing should be performed on samples representative of 10% of stock volume (e.g. 1 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 HDPE) 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 acceptance on NCP Product Schedule.

(10) RECOMMENDED PRODUCT USE PROCEDURES [§ 300.915(a)(10)]

Marine dispersants are one tool among several others available to mitigate the consequences of an oil spill. The response to such situations is managed by relevant authorities under the supervision of an On Scene Coordinator and the decision to use (or not use) a marine dispersant in a given situation (depending on location, weather, spill conditions, etc.) depends on complex decision matrixes that exceed the responsibilities of dispersant suppliers may differ depending on local regulations, policies, and practices.

1. Application Method: FINASOL OSR 52 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 is intended to be used pure, however it can be prediluted in seawater down to a concentration of 10% if need be to reduce its viscosity in cold water conditions or to allow use on spraying systems designed for older dispersant chemistries with higher flow rates.
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 – 1,000 μm, whether application is by surface vessel or from the air.

2. Concentration / Application Rate: It is generally recommended to use marine dispersants, including FINASOL OSR 52, 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, 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 oil viscosities, which is treated separately in Application Restrictions (below), water temperature (and ice coverage if relevant) have not been identified as having a decisive influence on FINASOL OSR 52 efficiency, as can be observed in efficiency results at 5 °C 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, including FINASOL OSR 52 in particular, that:

• Use should be restricted to pollutants with a viscosity not higher than 10,000 mm²/s, preferably not higher than 5,000 mm²/s (at sea temperature at the location of the spill). For pollutants whose viscosity is enclosed between 5,000 and 100,00 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 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 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 after use.

Disposal of unused (e.g. expired) product should, at all times, comply with the requirements of environmental protection, 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)]
FINASOL OSR 52 is approved for use as a marine dispersant in France and UK.

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.