Document BRvYBJ1YJjE9daYG905pxJvmE

SUPPLEMENT TO OUTLINES OF OPINIONS Amoco Sugar Creek Refinery Cases By Stephen E. Petty, P.E., C.I.H. April 15, 2005 Energy & Environmental Solutions, Inc. 2 April 15, 2005 Plaintiffs: Lon Walter's Sugar Creek Plaintiffs Defendants: BP Corporation North America Inc. and BP Products North America Inc. et.al Former American Oil Company (AMOCO) Site. Scope of Work: This scope of work was to determine Mrs. Ryan's likely benzene exposure while she lived in/near her two homes from 1956 to 1980. Introduction: The Sugar Creek, MO neighborhoods, where the plaintiffs lived, were located primarily to the south of the former American Oil Company (AMOCO) refinery. This refinery covered approximately 430 acres and operated from 1904 until about 1982. The Amoco Refinery, addressed in this report, is located at 1000 North Sterling Road, in the City of Sugar Creek, Missouri, and was opened in 1904. The refinery closed in 1982. Dismantling began in 1986 and was completed in 1991. Storage tanks in Gerber Tank Farm are still used as product storage and transfer facility. During its seventy-eight (78) years of operation, the crude refining capacity expanded from about 12,000 barrels per day to a final capacity of some 100,000 barrels per day. Sugar Creek, MO has a population of 3,982 in 1990; is located in Jackson County on the Missouri river, is located east/northeast of Kansas City, Mo., and is located at 3908'N 9424'W As early as 1908, a water plant official form the city of Independence, Missouri, reported that the refinery was discharging materials to Sugar Creek, which were negatively impacting their Missouri River water supply. Ultimately, as a result of a shifting sand bar and wintertime conditions, the situation worsened, resulting in a lawsuit on/about 1920 against the refinery (known as Standard Oil at that time). By early as March 6, 1950, internal American Oil Company (later Amoco and now BP-Amoco) correspondence notes that oil (later identified more properly as gasoline) was reported in a spring on Burton Street in the Sugar Creek neighborhood south of the refinery. By 1953, tank leaks were documented as being responsible for oil leaks seen in this spring and creek (Sugar Creek) that flowed through the neighborhood. Available documentation that residents were complaining of gasoline odors, and of visible oil seen in the neighborhood, can be found as early as April 6, 1964. By 1982, it was estimated that as much as 8,232,000 gallons of oil had leaked into the ground and that approximately 1,900,000 gallons of free product had been recovered by various means from 1988 to 1995. A considerable amount of oil apparently remains in the ground. Data strongly suggests that the term "oil", as it applies to oil contamination in/near Sugar Creek was premium leaded gasoline, known to contain up to 5% benzene. Other products have been shown to contain upwards of 15% benzene. Even after the initiation of remedial activities in 1997, groundwater benzene concentrations in the center of the petroleum plume were reported to be at levels up to 21.7 mg/L. Peak concentrations in groundwater under homes were up to 0.5 mg/L. Energy & Environmental Solutions, Inc. 3 April 15, 2005 In forming these supplemental opinions on Mrs. Ryan's benzene exposure, I have depended on information from the offices of Mr. Lon Walters, interviews with Mr. Ryan and her daughter Janie Everly and information from the published literature. The information that I have primarily considered and/or relied on is summarized in Appendix A. I have also relied on my knowledge and experience and training as a chemical engineer and Certified Industrial Hygienist (CIH), textbooks and reports on practices by industry for the design of oil/gas unit operations and systems and the control of petroleum contaminants and wastes and my risk assessment and work experience on petroleum contaminated sites. I leave open the possibility of adding to or modifying my opinions, based on additional information I may receive or review. Energy & Environmental Solutions, Inc. 4 April 15, 2005 Opinions: My opinions regarding exposure are: 1. Mrs. Ryan's benzene exposure while living at her homes on Evans and Huttig from 1956 to 1980 was 412 PPM-YRS. 2. Using a Monte Carlo simulation based on variations of exposure times, odor levels and the benzene content of gasoline, the range of likely exposures varied from 237 to 656 PPM-YRS. Exposure Estimates: An exposure estimate, resulting in PPM-YRS of benzene exposure was completed. The analysis is based on an assessment of Mrs. Ryan's exposure times while at/near her homes on 10317 Evans and 111 S. Huttig in Independence, MO along with benzene levels in air. The benzene levels in air are based on recollections of gasoline odors in air, odor thresholds, and the benzene content of gasoline. Details on the basis of these estimates, along with results of estimates, follow. Estimates of Exposure Times: Based on interrogatory responses and interviews, data on the time Mrs. Ryan spent at each location, along her work history, are summarized in Table 1. Background Information: Resident History: Living Location: Years: Units 10317 Evans 111 S. Huttig TOTAL 3.8 years 44.2 years 48.0 years Work History: Employer: Years: Units BMA - Pershing Rd. Not working Sears 0.4 0.5 0.3 years years years Timeframe: 12/56 to 9/60 9/60 to 11/04 Timeframe: Hours/Week 11/52 to 4/53 4/53 to 10/53 10/53 to 2/55 40 0 40 Energy & Environmental Solutions, Inc. 5 April 15, 2005 Background Information: Not working H.E.M. Not working Montgomery Ward Not working Montgomery Ward Not working Loft Drive In Not working IRS Not working Milbank Manufacturer 10.2 0.4 1.5 0.3 0.5 0.3 1.4 0.6 0.5 2.0 3.0 4.0 years years years years years years years years years years years years 2/55 to 4/65 4/65 to 9/65 9/65 to 3/67 3/67 to 6/67 6/67 to 1/68 1/68 to 5/68 5/68 to 10/69 10/69 to 5/70 5/70 to 1/71 1/71 to 1/73 1/73 to 1/76 1/76 to1/80 0 40 0 40 0 40 0 20 0 40 0 40 Table 1: Time History at Residences and Work History To calculate equivalent years for PPM-YRS for estimating exposures, a PPM-YR was estimated to be 124,800 minutes. This was based on the following assumptions: Minutes per hour Hours per day Days per week Weeks per year 60.0 8.0 5.0 52.0 The total minutes in a year was estimated to be 525,600. Estimated exposure times at each resident are summarized in Table 2: Energy & Environmental Solutions, Inc. Exposure Times At Residences: Assume # of work weeks was 50 per year Evans Location: Time frame Years Total Minutes Work Hrs/Week 12/56 to 9/60 TOTAL 3.8 2,014,800 0 Huttig Location: Time frame Years Total Minutes Work Hrs/Week 9/60 to 4/65 4/65 to 9/65 9/65 to 3/67 3/67 to 6/67 6/67 to 1/68 1/68 to 5/68 5/68 to 10/69 10/69 to 5/70 5/70 to 1/71 1/71 to 1/73 1/73 to 1/76 1/76 to1/80 TOTAL 4.6 0.4 1.5 0.3 0.6 0.3 1.4 0.6 0.7 2.0 3.0 4.0 2,409,000 219,000 788,400 131,400 306,600 175,200 744,600 306,600 350,400 1,051,200 1,576,800 2,102,400 0 40 0 40 0 40 0 20 0 40 0 40 6 April 15, 2005 Work Min./Year Net Home Min. % Time @ Home 0 2,014,800 90% % Time Smelled Gasoline 90% Minutes @ Home Smelling Gasoline 1,631,988 Years (PPM) @ home 13.1 13.1 Work Min./Year Net Home Min. % Time @ Home 0 120,000 0 120,000 0 120,000 0 60,000 0 120,000 0 120,000 2,409,000 99,000 788,400 11,400 306,600 55,200 744,600 246,600 350,400 931,200 1,576,800 1,982,400 85% 85% 85% 85% 85% 85% 85% 85% 85% 85% 85% 85% % Time Smelled Gasoline 90% 90% 90% 90% 90% 90% 90% 75% 75% 75% 75% 75% Minutes @ Home Smelling Gasoline 1,842,885 75,735 603,126 8,721 234,549 42,228 569,619 157,208 223,380 593,640 1,005,210 1,263,780 Years (PPM) @ home 14.8 0.6 4.8 0.1 1.9 0.3 4.6 1.3 1.8 4.8 8.1 10.1 53.0 TOTAL YEARS (PPM-YEAR BASIS) Table 2: Exposure Time Estimates and Assumption 66.1 Energy & Environmental Solutions, Inc. 7 April 15, 2005 The total exposure time, in PPM-based years, was 66.1 years, accounting only for the period from December 1956 to January 1980. No exposure time was used beyond January 1980. These times account for the time Mrs. Ryan worked, and assume no exposure while at work. They also account for the amount of time she was at home discounted for time she may have been away from the home and the time odors were present. She was home 90% of the time while at the Evans residence and home 85% of the time while at the S. Huttig residence. The percentage of times gasoline odors were smelled was reported to be 90% at both locations. I have been more conservative, dropping the percentages to 75% during the 1970s to reflect a period where environmental regulations began to take hold. Cells shaded in green were cells that contain a range of values for use in Monte Carlo analysis. The range used in the Monte Carlo analysis for these cells was always the value plus or minus five percent. Estimates of Benzene Exposure PPM-YRS: Using the exposure times discussed earlier, combined with odor threshold data from Drinker (see Appendix B for summary), and gasoline benzene content data collected from the literature (see Appendix C), a benzene exposure calculation was completed. Results of this calculation are shown in Table 3. In interviews, both Mr. Ryan and his daughter repeatedly describe the gasoline odor as being "very strong". A summary of odor responses by concentration (gasoline) from Drinker is shown below: Concentration (ppm) Odor Response(s) 140 - 160 270 500 900 2,600 10,700 - 11,200 Detectable odor; loss of odor beginning in as little as 1 hour; at 140 described as disinfectant by some subjects. Detectable odor entire 8 hours; one subject had loss of odor after 6 hours Detectable odor by all nine subjects; described as weak by 5 of 8 and strong by 3 of 8. Detectable odor by all six subjects; 4 of 6 describe as strong. Described as "very strong" by six subjects. Detectable odor immediately Based on the Drinker data, I have developed the following summary of concentrations by odor response for use in modeling Mrs. Ryan's benzene exposure: Energy & Environmental Solutions, Inc. 8 April 15, 2005 Concentration (ppm) Odor Response(s) 150 Weak, detectable odor 300 Moderate, detectable odor 600 Strong odor This classification should be conservative based on the actual Drinker observations vs. concentrations. A summary the input and output of Mrs. Ryan's benzene exposure is provided in Table 3: Energy & Environmental Solutions, Inc. Living Location: 10317 Evans 111 S. Huttig 111 S. Huttig 111 S. Huttig 111 S. Huttig 111 S. Huttig 111 S. Huttig 111 S. Huttig 111 S. Huttig 111 S. Huttig 111 S. Huttig 111 S. Huttig 111 S. Huttig Time frame 12/56 to 9/60 9/60 to 4/65 4/65 to 9/65 9/65 to 3/67 3/67 to 6/67 6/67 to 1/68 1/68 to 5/68 5/68 to 10/69 10/69 to 5/70 5/70 to 1/71 1/71 to 1/73 1/73 to 1/76 1/76 to1/80 Exposure Years: Units 13.1 years 14.8 years 0.6 years 4.8 years 0.1 years 1.9 years 0.3 years 4.6 years 1.3 years 1.8 years 4.8 years 8.1 years 10.1 years Described Odor Level Very strong Very strong Very strong Very strong Very strong Very strong Very strong Very strong Very strong Very strong Very strong Very strong Very strong 9 April 15, 2005 Gasoline Conc. (ppm) 375 225 225 225 225 225 225 225 225 150 150 150 150 Basis Use range of 150 to 600 Use range of 150 to 300 Use range of 150 to 300 Use range of 150 to 300 Use range of 150 to 300 Use range of 150 to 300 Use range of 150 to 300 Use range of 150 to 300 Use range of 150 to 300 Use value of 100 to 200 Use value of 100 to 200 Use value of 100 to 200 Use value of 100 to 200 Benzene Conc. (%) 2.75% 2.75% 2.75% 2.75% 2.75% 2.75% 2.75% 2.75% 2.75% 2.75% 2.75% 2.75% 2.75% Basis Amoco MSDS: 4% (Used range of 0.5% to 5%) Ignores other feeds with higher %s Enhancement Factor 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 PPM-YRS 134.9 91.4 3.8 29.9 0.4 11.6 2.1 28.2 7.8 7.4 19.6 33.2 41.8 TOTAL Enhancement Factor: Factor to multiple concentration in liquid to determine concentration in vapor Table 4: Input and Output of Mrs. Ryan's Benzene Exposure 412.1 Energy & Environmental Solutions, Inc. 10 April 15, 2005 The total predicted benzene exposure was 412 PPM-YRS. Note that this assumes declining, conservative values for gasoline concentrations with time. Also, the percent benzene value used was 2.75% rather than the 4.0% seen in Amoco MSDS sheets. This reflects a range of values seen in the literature (see Appendix C). Again, the green-color cells contain a range of values discussed later in the Monte Carlo exposure section below. Estimates of Benzene Exposure PPM-YRS Monte Carlo Analysis: It is constructive to look at the effect of varying key parameters to determine their impact on results, in this case benzene exposure. To accomplish this, a program called Crystal BallTM was utilized. It is an add-on program to Microsoft ExcelTM and is accessed as a custom tool bar. Variables allowed to vary, and the degree to which they were varied, are summarized below: Variable: Range of Values Considered: Percent Time at Home Mean plus or minus 5% Percent Time Smelled Gasoline Mean plus or minus 5% Gasoline Concentration For value of 375, range used was 150 to 600 For value of 225, range used was 150 to 300 For value of 150, range used was 100 to 200 Benzene percentage in gasoline for means of 2.75%, range used was 0.5% to 5%. Each range of values was considered to be distributed normally. The simulation was run 10,000 times. Output from this simulation is summarized in Figure 1 and Table 4: Energy & Environmental Solutions, Inc. 11 April 15, 2005 Figure 1: Simulated Benzene Exposure (PPM-YRS) The range of exposures calculated was from 236.9 PPM-YRS to 655.5 PPM-YRS. Energy & Environmental Solutions, Inc. 12 April 15, 2005 Statistics and percentiles from the simulation are summarized in Table 4. Statistics: Trials Mean Median Mode Standard Deviation Variance Skewness Kurtosis Coeff. of Variability Minimum Maximum Range Width Mean Std. Error 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Percentiles: Forecast values 10,000 412.8 410.0 --58.0 3,363.5 0.28 3.12 0.14 236.9 655.5 418.6 0.6 Forecast values 236.9 340.7 363.5 380.6 395.8 410.0 424.5 441.6 461.2 488.0 655.5 Table 4: Exposure Simulation Statistics and Percentiles Discussion: Several inputs to these calculations were adjusted to ensure conservatism in the results. Factors contributing to this conservatism were: No exposure was assumed from 1980 to late 2004. No exposure was assumed while at work. No enhancement factor was used. It was assumed that the concentration of benzene in vapor was equal to the concentration benzene in liquid gasoline. The percent time smelling gasoline was adjusted down in the later years below the 90% reported by Mr. Leonard Ryan and Ms. Janie Everly (his daughter). Energy & Environmental Solutions, Inc. 13 April 15, 2005 The gasoline concentrations used from Drinker in model were well below those that could have been used for a strong odor as reported by Mr. Leonard Ryan and Ms. Janie Everly. The percentage of benzene in gasoline used (2.75%) in the calculations was less than that (4%) reported in Amoco MSDS sheets. The results do not reflect other fuels that were also reportedly released, some of which have benzene concentrations as high as 15%. Closing: EES appreciates the opportunity to provide these professional services for the Walters Law Firm, LLC. If you have any questions regarding this case or require further information, please do not hesitate to call our office. Thank you, Stephen Petty, P.E., C.I.H. President Energy & Environmental Solutions, Inc. 14 APPENDIX A References April 15, 2005 Energy & Environmental Solutions, Inc. 15 April 15, 2005 American Industrial Hygiene Association. (AIHA). 1997. Odor Thresholds for Chemicals with Established Occupational Health Standards, Fairfax, VA. Defendants' First Set of Interrogatories to Plaintiff Nancy Ryan. Case 04CV-223271. 2004 Deposition of Leonard Ryan, January 26, 2005, Nancy Ryan and Leonard Ryan v. BP Corporation North America, Inc. and BP Products North America, Inc., No. 04CV223271. Deposition of Dr. Peter Infante, Vol. 1, January 10, 2005, Robert E. Scherer and Melanie Scherer v. S&S Automotive, et. al.,No. 02L435 consolidated with 02L679. Dravnieks, A. 1974. A Building-Block Model for the Characterization of Odorant Molecutles and Their Odors. Ann. N.Y. Acad. Sci. 237:144-163. May, J. 1966. Odor Thresholds of Solvents for Assessment of Solvent Odors in the Air. Staub 26: 385-389 (English translation of German article) Nicas, Mark. 2003. Using Mathematical Models to Estimate Exposure to Workplace Air Contaminants, Chemical Health & Safety, pgs. 14-21, January/February. Philip Drinker, C.P. Yaglou and Madeleine Field Warren, 1943. "The Threshold Toxicity of Gasoline Vapor", The Journal of Industrial Hygiene and Toxicology, Volume 25, pp.225-232, January 1943 December 1943 Reid, R. C., J. M. Prausnitz and T. K. Sherwood. 1977. The Properties of Gases and Liquids, Third Edition, McGraw-Hill Book Company, New York, NY. Site visit and interview of Mr. Leonard Ryan April 8, 2005. Telephone Log April 13, 2005. Telecom with Janie Everly. W.L. Nelson. 1958. Petroleum Refinery Engineering, Fourth Edition, McGraw-Hill Book Company, New York, NY. Energy & Environmental Solutions, Inc. 16 April 15, 2005 APPENDIX B Summary of Drinker (1943) Study Energy & Environmental Solutions, Inc. 17 April 15, 2005 Summary of Previous Work: According to a study involving three subjects conducted by the Bureau of Mines in 1921, it was determined that gasoline is a very innocuous substance that will cause different effects on an individual based on the concentration inhaled. The study results indicate that: 700 to 2800 ppm concentrations of gasoline vapor caused dizziness within 14 minutes. 11300 to 22200 ppm concentrations of gasoline vapor caused great dizziness in 3 minutes. 22200 to 26000 ppm concentrations of gasoline vapor made a man dizzy after 10 to 12 breaths In 1927, these experiments were repeated with results indicating: 1000 ppm concentrations of gasoline vapor caused mild symptoms of dullness, unsteadiness, and giddiness within 50 minutes. 3000 ppm concentrations of gasoline vapor caused slight irritation of the eyes and moderate symptoms of dizziness within 30 minutes. 7000 ppm concentrations of gasoline vapor caused coughing, marked irritation of the eyes and nose, numbness in the legs and unsteadiness within 10 minutes. In 1922, O. M. Spencer reported on a group of workers exposed to vapors of whole gasoline while wiping off moving belts with gasoline. According to Spencer's report, complaints in order of frequency involved: eye irritation, headaches, drowsiness, heaviness in the head and fatigue. It was concluded by investigators from all three studies that no relation exists between the possible effects of exposure and the quality of gasoline. Current Work: In 1942, an experiment was conducted using two gasolines brought out in analysis from commercial colorless lead-free gasoline. The two gasolines were: Commercial Gasoline (100F to 400F cut) and a Light Fraction of Commercial Gasoline (100F to 110F Cut). The study consisted of nine experiments. Seven experiments were carried out in a specially designed room in which the temperature, humidity and ventilation rates could be accurately controlled. Subjects within the room were exposed to different concentrations of the two gasolines to determine the health effect of exposure at different levels. The final two experiments consisted of the two gasolines being delivered steadily in specific concentrations into an air-line, where it was vaporized through a face mask held by the subject over his/her nose and face. Energy & Environmental Solutions, Inc. 18 April 15, 2005 The following two tables present a summary of each experiment that identifies the test substance used, concentration levels, experiment duration, subject information, noted observations of odor thresholds, noted health effects of exposure and complaints made by the test subjects. TABLE 1: COMMERCIAL GASOLINE CONC. LEVELS EXPOSURE DURATIONS NOTED OBSERVATIONS HEALTH EFFECTS 160 ppm 8 hours (Subjects were exposed to commercial gasoline uniformly distributed through the test areas ventilation system) 270 ppm 8 hours (Subjects were exposed to commercial gasoline uniformly distributed through the test areas ventilation system) 11,200 ppm (Commercial gasoline was delivered steadily into an air-line, where it was vaporized through a face mask held by the subject over his/her nose and face) 5 to 5.5 minutes (test was terminated voluntarily) Detectable odor upon entering area (majority of subjects experienced a loss of odor after 1, 3 and 7 hours). Subjects included 8 women, age 17 to 32 Detectable odor entire duration upon first entering area (one subject experienced a loss of odor after 6 hours). Subjects included 13 men, age 23 to 45 Detectable odor immediately Examination Hyperemia of the conjunctiva vessels No redness of throat was noted. Complaints Loss of appetite Sickness at stomach Headache Cough/Throat irritation Irritation/Itching of eyes Examination Slight hyperemia of the conjunctiva vessels. Distinct hyperemia of the throat. Complaints Loss of appetite Dizziness Sickness at stomach Cough/Throat irritation Irritation/Itching of eyes Examination Dizziness Incoordination and drunkenness Cough and sneezing Complaints Severe nose and throat irritation after 20 seconds to 1 minute. Subjects included 3 men and 1 woman, age 29 to 45 Energy & Environmental Solutions, Inc. 19 April 15, 2005 TABLE 2: LIGHT FRACTION OF COMMERCIAL GASOLINE CONC. LEVELS EXPOSURE DURATIONS NOTED ODOR OBSERVATIONS MADE BY SUBJECTS HEALTH EFFECTS 140 ppm 8 hours (Subjects were exposed to a light fraction of commercial gasoline uniformly distributed through the test areas ventilation system) 150 ppm 8 hours (Subjects were exposed to a light fraction of commercial gasoline uniformly distributed through the test areas ventilation system) 500 ppm 1 hour (Subjects were exposed to a light fraction of commercial gasoline uniformly distributed through the test areas ventilation system) Detectable odor upon entering area. Described as gasoline by 8 of 10 subjects. Described as some sort of disinfectant by 2 of 10 subjects. Examination N/A Complaints Slight sickness at stomach Slight headache Slight cough/throat irritation Slight drowsiness Slight irritation/itching of eyes Subjects included 10 college girls, age 17 to 22 Detectable odor entire duration upon first entering area. Described as weak by 5 of 8 subjects. Described as strong by 3 of 8 subjects. Examination N/A Complaints Loss of appetite Sickness at stomach Headache Cough/Throat irritation Very slight irritation/itching of eyes (Four subjects experienced a loss of odor. Three after 2 hours and one late in the afternoon). Subjects included 8 women, age 17 to 32 Detectable odor entire duration upon first entering area. Described as weak by 3 of 9 subjects. Described as strong by 2 of 9 subjects. 4 of 9 subjects made no Examination N/A Complaints Headache Cough/Throat irritation Irritation/itching of eyes Energy & Environmental Solutions, Inc. 20 April 15, 2005 TABLE 2: LIGHT FRACTION OF COMMERCIAL GASOLINE CONC. LEVELS EXPOSURE DURATIONS NOTED ODOR OBSERVATIONS MADE BY SUBJECTS comments. HEALTH EFFECTS 900 ppm 1 hour (Subjects were exposed to a light fraction of commercial gasoline uniformly distributed through the test areas ventilation system) Subjects included 9 men, age 23 to 45 Detectable odor within area (one subject indicated that the odor was stronger than previous day but other five subjects could not detect same). Described as strong by 4 of 6 subjects. 2 of 6 subjects made no comments. Subjects included 6 men, age 23 to 45 Examination Dizziness and unsteadiness Complaints Dizziness was not experienced, however, two subjects the following morning experienced unsteadiness of gait and uncertainty in driving. Slight nose/throat irritation Slight irritation/itching of eyes 2600 ppm 1 hour (Subjects were exposed to a light fraction of commercial gasoline uniformly distributed through the test areas ventilation system) "Very Strong" Detectable gasoline odor upon first entering area but strength could not be estimated (one subject experienced a loss of odor after 6 hours). Subjects included 5 men and 1 women, age 23 to 45 Examination Mild intoxication Small amount of muscle incoordination Difficulty accurately reading gauges Light-headedness with no headaches or disagreeable sensations No unpleasant after-effects Complaints Dizziness without mark incoordination Sickness at stomach (one subject left room due to nausea after 13 minutes). Cough/Throat irritation Irritation/Itching of eyes (was experienced at beginning of experiment but rapidly disappeared) Two subject reported tasting and smelling gasoline the following morning Energy & Environmental Solutions, Inc. 21 April 15, 2005 TABLE 2: LIGHT FRACTION OF COMMERCIAL GASOLINE CONC. LEVELS EXPOSURE DURATIONS NOTED ODOR OBSERVATIONS MADE BY SUBJECTS 10,700 ppm (A light fraction of commercial gasoline was delivered steadily into an air-line, where it was vaporized through a face mask held by the subject over his/her nose and face) 2 to 7.1 minutes Detectable odor immediately Subjects included 4 men, age 37 to 45 HEALTH EFFECTS Examination Dizziness and visible unsteadiness was observed within 4 minutes In-coordination and drunkenness Two subjects were distinctly hilarious and very active. Acute effects appeared to wear off in a short time with no objectionable afterexperiences. Complaints Severe nose and throat irritation after 2 minutes. Incoordination and drunkenness occurred in three subjects within 4 to 5 minutes and one subject within 7 minutes 10 seconds. (Philip Drinker, C.P. Yaglou and Madeleine Field Warren, 1943. "The Threshold Toxicity of Gasoline Vapor", The Journal of Industrial Hygiene and Toxicology, Volume 25, pp.225-232, January 1943 December 1943.) Energy & Environmental Solutions, Inc. 22 April 15, 2005 APPENDIX C Benzene Content of Gasoline and Naphtha Literature Values Energy & Environmental Solutions, Inc. 23 April 15, 2005 BENZENE CONCENTRATIONS IN GASOLINE BY YEAR YEAR 1974 1975 1976 1977 1977 1977 1978 1988 1988 1988 1988 1988 1988 1988 % BENZENE <1 <2 .54 2.39 >1 1.1 - 4 0.86 0.2 4.8 4 2.7 1.30 3.0 1.21 2.8 1.10 1.58 REFERENCE (Runion, Howard E.; "Benzene in Gasoline", American Industrial Hygiene Association Journal, Vol. 36, p.338, 1975.) (Runion, Howard E.; "Benzene in Gasoline", American Industrial Hygiene Association Journal, Vol. 36, p.338, 1975.) (Runion, Howard E.; "Benzene in Gasoline", American Industrial Hygiene Association Journal, Vol. 36, p.338, 1975.) (Testimony of R.J. Comeaux, July 11, 1977, Vice President of Gulf Oil Company) (Testimony of R.S. Proctor Chevron - before the OSHA committee reviewing the proposed revised permanent standard for occupational exposure to benzene on July 11, 1977 OSHA Docket H-059) Mobile Premium Gasoline - (Memo from W. F. Hergrueter to P.R. Carl dated October 4, 1977. Source Monitoring of Marine Emissions of Benzene, Technical Service Laboratories, Mobil Technical Center, Princeton, N.J.) (McDermott, H.J. and S.E. Killiany, Jr.; "Quest for a Gasoline TLV", American Industrial Hygiene Association Journal, Vol. 39, pp. 110117, Feb. 1978.) AMOCO Oil Co.- AMOCO Regular Leaded Gasoline Material Safety Data Sheet, 9130-00-264-6218, http://hazard.com/msds/f2/bgw/bgwpv.html Regular Leaded Gasoline, (Letter from R.E. Green to C.F. Grimmer, Shell Oil Company Interoffice Memorandum, February 29, 1988, Table III, p. 6) Regular Leaded Gasoline, (Letter from R. K. Jones to D. E. Eitel, Shell Oil Company Interoffice Memorandum, March 28, 1988, p. 1-2) RU-2000, (Letter from R.E. Green to C.F. Grimmer, Shell Oil Company Interoffice Memorandum, February 29, 1988, Table III, p. 6) RU-2000, (Letter from R. K. Jones to D. E. Eitel, Shell Oil Company Interoffice Memorandum, March 28, 1988, p. 2) SU-2000, (Letter from R.E. Green to C.F. Grimmer, Shell Oil Company Interoffice Memorandum, February 29, 1988, Table III, p. 6) SU-2000, (Letter from R. K. Jones to D. E. Eitel, Shell Oil Company Interoffice Memorandum, March 28, 1988, p. 1-2) Energy & Environmental Solutions, Inc. 24 April 15, 2005 YEAR 1988 1988 1988 1988 1988 1988 1988 1988 1988 1988 1988 1988 1988 1988 1989 1989 1990 1991 % BENZENE 2.55 5.29 4.91 4.25 5.42 4.84 2.96 4.65 2.96 4.64 4.86 4.63 4.90 4.64 2.1 3.2 0.95 1.35 1.70 REFERENCE SU2000, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) RU2000, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) Shell Regular, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) SU2000, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) RU2000, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) Shell Regular, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) SU2000, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) Shell Regular, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) SU2000, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) Shell Regular, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) SU2000, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) Shell Regular, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) SU2000, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) Shell Regular, (Letter from T. A. Colangelo to C. F. Grimmer, Shell Oil Company Interoffice Memorandum, April 4, 1988, p. 14) (Page, Norbert P. and Myron Mehlman; "Health Effects of Gasoline Refueling Vapors and Measured Exposures at Service Stations", Toxicology and Industrial Health, Vol. 5, No. 5, pp. 869-890, 1989.) (Air Force, Chemical and Physical Information, Table 3-3 Major Components of Gasoline, 1989) http://www.chevron.com/prodserv/fuels/bulletin/fed-refm/rfgchar.shtml Premium Gasoline - (Tironi, Gene and D. G. Hodgkins. 1991. Compliance with the OSHA Benzene Permissible Exposure Limit (PEL) at the Gasoline Vapor PEL, Appl. Occup. Environ. Hyg., Vol. Energy & Environmental Solutions, Inc. 25 April 15, 2005 YEAR 1991 1991 1991 1993 1993 1994 % BENZENE 1.38 1.73 0-5 <5 1-5 4 1.6 REFERENCE 6, No. 10., pp. 881-884, October) Regular Gasoline - (Tironi, Gene and D. G. Hodgkins. 1991. Compliance with the OSHA Benzene Permissible Exposure Limit (PEL) at the Gasoline Vapor PEL, Appl. Occup. Environ. Hyg., Vol. 6, No. 10., pp. 881-884, October) (Shell Products Containing Benzene or Benzene Compounds, November 13, 1991, pgs. 3-8). Recovered Gasoline, Shell Products Containing Benzene or Benzene Compounds, November 13, 1991, pg. 4 (Employee Benzene Exposure Assessment Summary Report Barge Operations, Bruce B. Crowell, Ashland Petroleum Company, April 1, 1993) AMOCO Oil Regular Lead- Free Gasoline Gasoline, Automotive Material Safety Data Sheet, http://home.att.net/~weltanco/msds/gasoline.htm http://www.ec.gc.ca/energ/fuels/reports/benz_99/benz_1999_e.pdf 1994 1995 3.5 http://www.dmu.dk/1_viden/2_Publikationer/3_fagrapporter/rapporter /fr309.pdf 1.4 http://www.ec.gc.ca/energ/fuels/reports/benz_99/benz_1999_e.pdf 1995 1996 2 http://www.dmu.dk/1_viden/2_Publikationer/3_fagrapporter/rapporter /fr309.pdf 1.6 http://www.ec.gc.ca/energ/fuels/reports/benz_99/benz_1999_e.pdf 1997 1.5 http://www.ec.gc.ca/energ/fuels/reports/benz_99/benz_1999_e.pdf 1998 1.6 http://www.ec.gc.ca/energ/fuels/reports/benz_99/benz_1999_e.pdf 1998 2005 ? 1 0.1 - 4 1.2 to 4.9 http://www.dmu.dk/1_viden/2_Publikationer/3_fagrapporter/rapporter /fr309.pdf http://www.kemi.se/kemamne_eng/benzen_eng.htm http://www.prod.exxon.com/exxon_gas/conv-exxon.html Energy & Environmental Solutions, Inc. 26 April 15, 2005 OUTLINE OF BENZENE CONCENTRATIONS IN NAPHTHA BY YEAR YEAR 1961 1963 1977 1977 1991 1991 1991 % BENZENE REFERENCE 9.3 1.6 2.8 >1 0.1 1 - 18 1-5 <5 (Pagnotto, Leonard, D., et. al., 1961. "Industrial Benzene Exposure from Petroleum Naphtha: I. Rubber Coating Industry", American Industrial Hygiene Journal, Vol. 22, pp. 417-421, Dec.) (Elkins, Hervey, B., et. al., 1963. "Industrial Benzene Exposure from Petroleum Naphtha", American Industrial Hygiene Journal, pp. 99-102, Mar-Apr.) Naphtha solvents and Naphtha-based (type B) jet fuels, (Testimony of R.J. Comeaux, July 11, 1977, Vice President of Gulf Oil Company) Kerosene and light fuel oils, (Testimony of R.J. Comeaux, July 11, 1977, Vice President of Gulf Oil Company) Naphtha Algerian, (Shell Products Containing Benzene or Benzene Compounds, November 13, 1991, pg. 1) Naphtha Cutback Diluent, (Shell Products Containing Benzene or Benzene Compounds, November 13, 1991, pg. 3) Naphtha Distilling Light, (Shell Products Containing Benzene or Benzene Compounds, November 13, 1991, pg. 1)