Document mpnYzqknvr3Zja4rMgav94d4b

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 07/17/2024 12:45 PM (CT) 07/17/2024 3:20 PM (CT) Announced: No (tenants and related facilities) Access: Granted RCRA Focused Compliance Inspection (FCI) Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Geographic Coordinates John W. Stone Oil Distributor LLC LAD166293761 452 First Street (Noted as 87 First Street on RCRAInfo) Gretna, LA 70053 Jefferson Parish Used Oil Handler 42271 John W. Stone Oil Distributor LLC operates as a fuel distributor for barges and vessels. 29.920657, -90.062017 Additional Persons Participating in Inspection: Name Title Organization Dedriel Gardner Inspector EPA REGION 6 Joe Watson Contractor Eastern Research Group (ERG) Email Gardner.Dedriel@epa.gov Joe.Watson@erg.com Phone (281) 983-2133 (215) 891-6615 Lead Inspector: Vince Damiano ERG Vincent Damiano Digitally signed by Vincent Damiano Date: 2024.10.03 10:21:01 -04'00' Vince.Damiano@erg.com (703) 835-6281 Page 1 of 5 John W. Stone Oil Distributor LLC Inspection Date: 07/17/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port of New Orleans and surrounding facilities were selected for inspection based on an Environmental Justice and Regional initiative to evaluate facilities at ports receiving or transporting Resource Conservation and Recovery Act (RCRA)-regulated hazardous wastes, and/or have an International Convention for the Prevention of Pollution from Ships (MARPOL) Annex V Certificate of Adequacy (COA) issued by the U.S. Coast Guard (USCG) . This report is based on information supplied by the facility representatives, inspector observations, and records including photographs taken (see Appendix 1), verbal or written statements made during or after the on-site inspection, and/or materials shown, demonstrated, or submitted to the EPA during or after the on-site inspection. In addition, information gathered prior to or after the inspection from a review of EPA, State, and public records may be included in this report. Attendees Title/Organization Lead Inspector/ Contractor/ERG RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Name Vince Damiano Phone Email (703) 835-6281 Vince.Damiano@erg.com Opening Conf. Yes Closing Conf. Yes Joe Watson (215) 891-6615 Joe.Watson@erg.com Yes Yes Dedriel Gardner (281) 983-2133 Gardner.Dedriel@epa.gov Yes Yes Facility General Description Tenant/Area John W. Stone Oil Distributor LLC Inspection Date 07/17/24 Process Description John W. Stone Oil Distributor LLC (Stone Oil) operates as a fuel distributor for barges and vessels. Fuels, such as diesel or heavy bunker fuel, are bought from refineries, blended in tanks at Stone Oil, and sold to customers on the river from their barges. Stone Oil also collects used oil from vessels, barges, and other customers who generate used oil. Stone Oil maintains a MARPOL COA. Area of Concern Yes Page 2 of 5 John W. Stone Oil Distributor LLC SECTION II - OBSERVATIONS Inspection Date: 07/17/2024 Tenant: John W. Stone Oil Distributor LLC Section: 2.1 Date: 07/17/24, 12:45 PM Contains AOC: Yes Contains CBI: No Lead Inspector: Vince Damiano Attendees: Michael Hall (QSSE), Mitchell Waits (HSE), and George Forbes (Facility Manager) Stone Oil is located in Gretna, LA, and operates as a fuel distributor for barges and vessels. Fuels, such as diesel or heavy bunker fuel, are bought from refineries, blended in tanks at Stone Oil, and sold to customers on the river from their barges. The used oil is collected in one of their 42 barges, stored in a 300-gallon used oil tank on the barge, and brought back to Stone Oil once the tank is full. When the barge holding used oil docks at Stone Oil, the used oil is pumped to one of two onshore storage tanks prior to being sent off for recycling to Westside Oil Recovery Inc. in Slidell, LA. At the time of the inspection, only one onshore used oil tank was in operation (17,000-gallon holding capacity) while the other used oil storage tank (55,000-gallon storage capacity) is under repair. Stone Oil maintains a MARPOL COA, but the facility says they only accept "trash" such as food scraps, plastics, and paper from domestic vessels. Stone Oil is registered with the EPA as a used oil transporter, used oil transfer facility, and used oil processor (LAD166293761). Stone Oil representatives said they do not generate or receive RCRA-regulated hazardous waste. Stone Oil generates used oil, oily rags, oily filters, and universal waste from maintenance activities. Following the opening conference, the inspection team conducted a visual inspection of Stone Oil dock space, storage areas, used oil tanks, and maintenance shop. The inspection team first inspected Stone Oil's dock space where barges S-40, S-48, and S-46 were docked. The inspection team observed the used oil tanks on board the barges where used oil is received and stored before it is pumped to the onshore used oil storage tank. Next, the inspection team moved to a storage area where an unlabeled 350-gallon metal tote was observed. The tote was approximately one-third full of used oil (see Appendix 1 - Photo 1) [AOC #1 - Stone Oil did not clearly label containers used to store used oil with the words "Used Oil" - 40 CFR 279.54(f)(1)]. In the same storage area, the inspection team also observed three full 55-gallon drums of used oil and oily rags which were unlabeled (see Appendix 1 - Photo 2) [see AOC #1]. While the inspection team was conducting the visual inspection, Stone Oil added a "Used Oil" label to the metal tote previously discussed (see Appendix 1 - Photo 3). Next, the inspection team observed Stone Oil's onshore used oil storage tank, which has a 17,000-gallon storage capacity, as previously mentioned (see Appendix 1 - Photos 4 to 6). The inspection team observed that the storage tank did not contain a label indicating it was storing used oil [see AOC #1]. The inspection team also noticed a hole, approximately 1-inch in diameter, at the bottom of the tank which appeared to be from corrosion; no oil was seen leaking from the hole at the time of the inspection (see Appendix 1 - Photo 7) [AOC #2 - Stone Oil stored used oil in a tank that was in poor condition - 40 CFR 279.54(b)(1)]. The inspection team noticed there was no apparent secondary containment for the tank, but Stone Oil claimed the tank farm area is in a diked area, which acts as the secondary containment. The inspection team requested their secondary containment certification, which was provided following the inspection (see Appendix 2). About 100 meters Northwest from the tank area, the inspection team observed a roll-off container used to store used oil filters (see Appendix 1 - Photos 8 to 10). The roll-off container was storing undrained used oil filters but was not labeled as "Used Oil" [see AOC #1]. Most used filters were contained in double bags inside of the roll-off container, sufficiently acting as a secondary containment; however the inspection team observed one open bag of filters with its used oil filter contents falling out of the bag inside the roll-off container (see Appendix 1 - Photo 11) [AOC #3 - Stone Oil stored used oil in containers not equipped with a Page 3 of 5 John W. Stone Oil Distributor LLC secondary containment system - 40 CFR 279.54(c)]. Inspection Date: 07/17/2024 The inspection team moved to Stone Oil's maintenance shop located at 701 Madison St., Gretna, LA 70053 (non-notifier) to continue the visual inspection. The inspection team first observed an approximately half-full 300-gallon metal tote labeled as used oil (see Appendix 1 - Photos 12 and 13). The facility stated they add their spent antifreeze into the tote of used oil. The inspection team requested a waste determination on the mix of used oil and antifreeze [AOC #4 - Stone Oil did not make a hazardous waste determination. - 40 CFR 262.11]. The inspection team also observed three unlabeled 5-gallon containers storing used oil filters that had not been drained or punctured, therefore the oil filters still contained used oil (see Appendix 1 - Photo 14) [see AOC #1]. The facility stated they recycle the used oil filters. Next, the inspection team observed eight lead-acid batteries that were not labeled as universal waste and for which Stone Oil was unable to confirm an accumulation start date on the lead-acid batteries they were managing as universal waste (see Appendix 1 - Photo 15) [AOC #5 - Stone Oil did not properly label used batteries being managed as universal waste - 40 CFR 273.14(a)] and [AOC #6 - Stone Oil could not demonstrate the length of time universal waste had been accumulating - 40 CFR 273.15 (c)]. A closing conference was conducted at approximately 3:20 PM with Stone Oil personnel. The AOCs were communicated; however, further EPA review may add to their potential AOCs. Follow-up documents were requested during the closing (see Appendices 2 - 8). SECTION III - RECORDS REVIEW Reviewed delivery confirmations for shipments of used oil. See Appendix 3 for examples requested following the inspection. SECTION IV - AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: John W. Stone Oil Distributor LLC AOC #1 - Stone Oil did not clearly label containers used to store used oil with the words "Used Oil" Citation: 40 CFR 279.54(f)(1) Section: 2.1 AOC #2 - Stone Oil stored used oil in a tank that was Citation: 40 CFR 279.54(b)(1) in poor condition Section: 2.1 AOC #3 - Stone Oil stored used oil in containers not equipped with a secondary containment system Citation: 40 CFR 279.54(c) Section: 2.1 AOC #4 - Stone Oil did not make a hazardous waste determination. Citation: 40 CFR 262.11 AOC #5 - Stone Oil did not properly label used batteries being managed as universal waste. Citation: 40 CFR 273.14(a) AOC #6 - Stone Oil could not demonstrate the length Citation: 40 CFR 273.15 (c) of time universal waste had been accumulating. Section: 2.1 Section: 2.1 Section: 2.1 Page 4 of 5 John W. Stone Oil Distributor LLC Inspection Date: 07/17/2024 SECTION V - FOLLOW UP Documents or files provided by the facility as follow-up were transmitted via email and included responses to AOCs or provision of requested documents requested. See Appendices 2-8. Communication Log During and after the inspection, additional information was emailed to EPA including: 1. 08/01/24 Stone Oil email - Mitch Waits sent several photos and descriptions showing corrective actions implemented along with items requested from the inspection team at the facility based on the findings of the inspection. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Secondary Containment P.E. Certification Appendix 3. Used Oil Ticket Examples Appendix 4. MARPOL COA Appendix 5. June 2024 Used Oil Sample Results Appendix 6. Photographs of Corrected Labels Appendix 7. Sample Results from the Used Oil and Antifreeze Mixture Appendix 8. Follow-Up Response from 8/1/2024 Page 5 of 5 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6709 Date of Photo: 07/17/2024 Time of Photo: 14:05 hrs. Photographer: Vince Damiano Description: View of 1/3 full 300-gallon tote of used oil unlabeled inside storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6710 Date of Photo: 07/17/2024 Time of Photo: 14:11 hrs. Photographer: Vince Damiano Description: View of three 55-gallon drums of used oil unlabeled inside storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6711 Date of Photo: 07/17/2024 Time of Photo: 14:13 hrs. Photographer: Vince Damiano Description: View of 1/3 full 300-gallon tote of used oil seen in Photo 1 after facility put a label on. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6712 Date of Photo: 07/17/2024 Time of Photo: 14:16 hrs. Photographer: Vince Damiano Description: Overview of unlabeled used oil tank. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6713 Date of Photo: 07/17/2024 Time of Photo: 14:16 hrs. Photographer: Vince Damiano Description: Overview of unlabeled used oil tank. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6714 Date of Photo: 07/17/2024 Time of Photo: 14:17 hrs. Photographer: Vince Damiano Description: Overview of unlabeled used oil tank. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6715 Date of Photo: 07/17/2024 Time of Photo: 14:17 hrs. Photographer: Vince Damiano Description: View of rusted hole on the bottom of used oil tank. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6716 Date of Photo: 07/17/2024 Time of Photo: 14:25 hrs. Photographer: Vince Damiano Description: View of roll-off container used to store used oil filters which was unlabeled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6717 Date of Photo: 07/17/2024 Time of Photo: 14:25 hrs. Photographer: Vince Damiano Description: View inside roll-off container used to store used oil filters in double plastic bags. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6718 Date of Photo: 07/17/2024 Time of Photo: 14:26 hrs. Photographer: Vince Damiano Description: View of roll-off container used to store used oil filters which was unlabeled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6719 Date of Photo: 07/17/2024 Time of Photo: 14:26 hrs. Photographer: Vince Damiano Description: View of red used oil filter seen outside of primary containment inside unlabeled roll-off container. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6720 Date of Photo: 07/17/2024 Time of Photo: 14:47 hrs. Photographer: Vince Damiano Description: View of full used oil/antifreeze 300-gallon tote inside maintenance shop. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6721 Date of Photo: 07/17/2024 Time of Photo: 14:47 hrs. Photographer: Vince Damiano Description: View of full used oil/antifreeze 300-gallon tote and empty oil containers inside maintenance shop. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6722 Date of Photo: 07/17/2024 Time of Photo: 14:48 hrs. Photographer: Vince Damiano Description: View of three unlabeled 5-gallon containers holding undrained used oil filters inside maintenance shop. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: John W. Stone Oil Distributor LLC City: Gretna County/Parish: Jefferson State: Louisiana Photo File Name: DSCN6723 Date of Photo: 07/17/2024 Time of Photo: 14:50 hrs. Photographer: Vince Damiano Description: View of eight unlabeled and undated universal waste batteries inside maintenance shop. APPENDIX 2. SECONDARY CONTAINMENT P.E. CERTIFICATION Appendix 2 Page 1 of 2 Appendix 2 Page 2 of 2 APPENDIX 3.USED OIL TICKET EXAMPLES Appendix 3 Page 1 of 2 Appendix 3 Page 2 of 2 APPENDIX 4. MARPOL COA APPENDIX 5. JUNE 2024 USED OIL SAMPLE RESULTS Sample Summary 27-Jun-24 2:23 pm 2406270729 Batch: Project: Location: Sample Type: Customer: Cust. Sample: UMO Supplier Pre-Qual Westside 3702-24 PO: vr24-1297 Sampler: Collected: Received: Started: Completed: Invoice: KJ 6/27/2024 6/27/2024 6/27/2024 Status: Time: Time: Due: Reported: Invoiced: Normal 7:28 Description: Notes: Document: Conclusions: TK 22 1250bbls PQ PASS Analysis UMO Slate Ethylene Glycol Kinematic Viscosity@40C Polychlorinated Biphenyls Halogens Water Vol Sediment Caustic Coagulation Specific Gravity @ 60F API Gravity Density, lbs/ga @60F Flash Point, CC Sulfur Arsenic Zinc Phosphorus Lead Cadmium Iron Silicon Chromium Vanadium Calcium Sodium Result Units Spec. Method Date Time N/A* vol% 26.9 cSt@40C < 2 mg/kg 97 ppm 0.47 vol% .100 vol% Pass N/A 0.86440 degF 32.2 API 7.2067 lbs/gal > 150 degF 0.1737 wt% 1.8 ppm 426.9 ppm 386.9 ppm 3.2 ppm ND ppm 77.3 ppm 99.4 ppm 0.4 ppm ND ppm 335.0 ppm 3.6 ppm VELM702 E 32-120 D7279 <2 SW846-808 <300 SW846-907 <5.0 D1744 (KF) <1.5 D1796mod pass OHLI-0708 0.8654-0.89 D4052 55 D4052 (API report D4052 (lbs/ >150 D3828 <0.300 D5185mod <5 D5185mod <1100 D5185mod <1100 D5185mod <100 D5185mod <2 D5185mod <150 D5185mod <150 D5185mod <10 D5185mod <10 D5185mod <3500 D5185mod <250 D5185mod 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 6/27/2024 Tech/Lab kj kj kj kj kj kj kj kj kj kj kj kj kj kj kj kj kj kj kj kj kj kj kj Vertex Energy Laboratory- LA Appendix 5 Page 1 of 1 Page 1 of 1 APPENDIX 6. PHOTOGRAPHS OF CORRECTED LABELS Appendix 6 Page 1 of 4 Appendix 6 Page 2 of 4 Appendix 6 Page 3 of 4 Appendix 6 Page 4 of 4 APPENDIX 7. SAMPLE RESULTS FROM THE USED OIL AND ANTIFREEZE MIXTURE Certificate of Analysis John W. Stone Oil Dist. Inc. (JW Stone Oil) George Forbes P.O. Box 2010 Gretna United States of America Our Reference Number: Lab Reference Number: Customer Reference Number: US210-0027376 2024-GRET-000901 1180452 Customer Product Description: UMO Location: Gretna, LA, USA, Harvey, Louisiana, United States Sample Representing: 27376-1 REF#1180452 Composite Drawn By: Client Sample ID: 2024-GRET-000901-001 Date Sampled: 19-Jul-2024 Date Submitted: 19-Jul-2024 Date Tested: 19-Jul-2024 Method ASTM D7359 SW-846 9056A Property Chloride. Fluoride. SW846-907 Halogens Result 42.7 5.4 66 Units mg/kg mg/kg ppm Results are only representative of the sample tested. All tests have been performed using the latest version unless otherwise indicated. This report shall not be reproduced except in full without written approval of Intertek. Report is subject to our standard Terms and Conditions which can be obtained at our website : http://www.intertek.com/terms The sample was submitted for testing purposes. Intertek cannot accept liability for the representativeness of the sample. Signed By: Javier Mairena, Supervisor Date: 2604 Moss Lane, Harvey, Louisiana 70058 USA Tel.: +1 504 362 9898 Fax.: +1 504 362 2521 Report Generated: 20-Jul-2024 19:44 Page 1 of 1 Safety Data Sheet SECTION 1 PRODUCT AND COMPANY IDENTIFICATION Delo ELC Antifreeze/Coolant - Premixed 50/50 Product Use: Heavy Duty Coolant Product Number(s): 227811 Company Identification Chevron Products Company a division of Chevron U.S.A. Inc. 6001 Bollinger Canyon Rd. San Ramon, CA 94583 United States of America www.chevronlubricants.com Transportation Emergency Response CHEMTREC: (800) 424-9300 or (703) 527-3887 Health Emergency Chevron Emergency & Information Center: Located in the USA. International collect calls accepted. (800) 231-0623 or (510) 231-0623 Product Information email : lubemsds@chevron.com Product Information: 1 (800) 582-3835, LUBETEK@chevron.com SECTION 2 HAZARDS IDENTIFICATION CLASSIFICATION: Reproductive toxicant (developmental): Category 1B. Target organ toxicant (repeated exposure): Category 2. Signal Word: Danger Health Hazards: May damage the unborn child. May cause damage to organs (Kidney) through prolonged or repeated exposure. PRECAUTIONARY STATEMENTS: Prevention: Obtain special instructions before use. _____________________________________________________________________ Revision Number: 16 Revision Date: March 04, 2024 1 of 9 Delo ELC Antifreeze/Coolant Premixed 50/50 SDS : 10673  Do not handle until all safety precautions have been read and understood. Do not breathe dust/fume/gas/mist/vapours/spray. Use personal protective equipment as required. Response: IF exposed or concerned: Get medical advice/attention. Get medical advice/attention if you feel unwell. Storage: Store locked up. Disposal: Dispose of contents/container in accordance with applicable local/regional/national/international regulations. HAZARDS NOT OTHERWISE CLASSIFIED: Not Applicable SECTION 3 COMPOSITION/ INFORMATION ON INGREDIENTS COMPONENTS Ethylene glycol Sodium 2-ethylhexanoate Tolyltriazole CAS NUMBER 107-21-1 19766-89-3 29385-43-1 AMOUNT 34 - < 80 %weight 1 - 5 %weight 0.1 - < 1 %weight SECTION 4 FIRST AID MEASURES Description of first aid measures Eye: No specific first aid measures are required. As a precaution, remove contact lenses, if worn, and flush eyes with water. Skin: No specific first aid measures are required. As a precaution, remove clothing and shoes if contaminated. To remove the material from skin, use soap and water. Discard contaminated clothing and shoes or thoroughly clean before reuse. Ingestion: If swallowed, get immediate medical attention. Do not induce vomiting. Never give anything by mouth to an unconscious person. Inhalation: No specific first aid measures are required. If exposed to excessive levels of material in the air, move the exposed person to fresh air. Get medical attention if coughing or respiratory discomfort occurs. Most important symptoms and effects, both acute and delayed IMMEDIATE HEALTH EFFECTS Eye: Not expected to cause prolonged or significant eye irritation. Skin: Contact with the skin is not expected to cause prolonged or significant irritation. Contact with the skin is not expected to cause an allergic skin response. Not expected to be harmful to internal organs if absorbed through the skin. Ingestion: May be harmful if swallowed. Inhalation: Not expected to be harmful if inhaled. Breathing this material at concentrations above the recommended exposure limits may cause central nervous system effects. Central nervous system effects may include headache, dizziness, nausea, vomiting, weakness, loss of coordination, blurred vision, drowsiness, confusion, or disorientation. At extreme exposures, central nervous system effects may include respiratory depression, tremors or convulsions, loss of consciousness, coma or death. DELAYED OR OTHER HEALTH EFFECTS: Reproduction and Birth Defects: Contains material that may cause harm to the unborn child if swallowed based on animal data. Target Organs: Contains material that may cause damage to the following organ(s) following repeated _____________________________________________________________________ Revision Number: 16 Revision Date: March 04, 2024 2 of 9 Delo ELC Antifreeze/Coolant Premixed 50/50 SDS : 10673 inhalation at concentrations above the recommended exposure limit: Kidney See Section 11 for additional information. Risk depends on duration and level of exposure. Indication of any immediate medical attention and special treatment needed Not Applicable SECTION 5 FIRE FIGHTING MEASURES EXTINGUISHING MEDIA: Dry Chemical, CO2, Aqueous Film Forming Foam (AFFF) or alcohol resistant foam. PROTECTION OF FIRE FIGHTERS: Fire Fighting Instructions: This material will burn although it is not easily ignited. See Section 7 for proper handling and storage. For fires involving this material, do not enter any enclosed or confined fire space without proper protective equipment, including self-contained breathing apparatus. Combustion Products: Highly dependent on combustion conditions. A complex mixture of airborne solids, liquids, and gases including carbon monoxide, carbon dioxide, and unidentified organic compounds will be evolved when this material undergoes combustion. Combustion may form oxides of: Sodium. SECTION 6 ACCIDENTAL RELEASE MEASURES Protective Measures: Eliminate all sources of ignition in vicinity of spilled material. Spill Management: Stop the source of the release if you can do it without risk. Contain release to prevent further contamination of soil, surface water or groundwater. Clean up spill as soon as possible, observing precautions in Exposure Controls/Personal Protection. Use appropriate techniques such as applying non-combustible absorbent materials or pumping. Where feasible and appropriate, remove contaminated soil. Place contaminated materials in disposable containers and dispose of in a manner consistent with applicable regulations. Reporting: Report spills to local authorities and/or the U.S. Coast Guard's National Response Center at (800) 424-8802 as appropriate or required. SECTION 7 HANDLING AND STORAGE General Handling Information: Do not taste or swallow antifreeze or solution. Keep out of the reach of children and animals. Precautionary Measures: Do not get in eyes, on skin, or on clothing. Do not taste or swallow. Do not breathe vapor or fumes. Wash thoroughly after handling. Keep out of the reach of children. Static Hazard: Electrostatic charge may accumulate and create a hazardous condition when handling this material. To minimize this hazard, bonding and grounding may be necessary but may not, by themselves, be sufficient. Review all operations which have the potential of generating and accumulating an electrostatic charge and/or a flammable atmosphere (including tank and container filling, splash filling, tank cleaning, sampling, gauging, switch loading, filtering, mixing, agitation, and vacuum truck operations) and use appropriate mitigating procedures. Container Warnings: Container is not designed to contain pressure. Do not use pressure to empty container or it may rupture with explosive force. Empty containers retain product residue (solid, liquid, and/or vapor) and can be dangerous. Do not pressurize, cut, weld, braze, solder, drill, grind, or expose such containers to heat, flame, sparks, static electricity, or other sources of ignition. They may explode and cause injury or death. Empty containers should be completely drained, properly closed, and promptly returned to a drum reconditioner or disposed of properly. General Storage Information: Do not store in open or unlabeled containers. _____________________________________________________________________ Revision Number: 16 Revision Date: March 04, 2024 3 of 9 Delo ELC Antifreeze/Coolant Premixed 50/50 SDS : 10673 SECTION 8 EXPOSURE CONTROLS/PERSONAL PROTECTION GENERAL CONSIDERATIONS: Consider the potential hazards of this material (see Section 2), applicable exposure limits, job activities, and other substances in the workplace when designing engineering controls and selecting personal protective equipment (PPE). If engineering controls or work practices are not adequate to prevent exposure to harmful levels of this material, refer to PPE information below. Factors that affect PPE include, but are not limited to: properties of the chemical, other chemicals which may contact the same PPE, physical requirements (fit & sizing, cut/puncture protection, dexterity, thermal protection, etc.), and potential allergic reactions to the PPE material. It is the responsibility of the user to read and understand all instructions and limitations supplied with the equipment since protection is usually provided for a limited time or under certain circumstances. Refer to appropriate CEN standards. ENGINEERING CONTROLS: Use general ventilation, local exhaust ventilation, or a combination of both. PERSONAL PROTECTIVE EQUIPMENT Eye/Face Protection: Wear protective equipment to prevent eye contact. Selection of protective equipment may include safety glasses, chemical goggles, face shields, or a combination depending on the work operations conducted. Skin Protection: Wear chemical personal protective equipment (PPE) to prevent skin contact. Selection of chemical protective clothing should be performed by an Occupational Hygienist or Safety Professional and be based upon applicable standards (ASTM F739 or EN 374). Using chemical PPE depends upon operations conducted and may include chemical gloves, boots, chemical apron, chemical suit, and complete facial protection. Refer to PPE manufacturers to obtain breakthrough time information to determine how long PPE can be used before it needs to be replaced. Unless specific glove manufacturer data indicates otherwise, the below table is based upon available industry data to assist in the glove selection process and is intended to be used as reference only. Chemical Glove Material Butyl Neoprene Nitrile Polyvinyl Chloride (PVC) Viton Butyl Thickness (mm) 0.7 0.61 0.8 1.1 0.3 Typical Breakthrough Time (minutes) 120 120 120 120 120 Respiratory Protection: Determine if airborne concentrations are below the recommended occupational exposure limits for jurisdiction of use. If airborne concentrations are above the acceptable limits, wear an approved respirator that provides adequate protection from this material, such as: Air-Purifying Respirator for Organic Vapors, Dusts and Mists. Use a positive pressure air-supplying respirator in circumstances where air-purifying respirators may not provide adequate protection. Occupational Exposure Limits: Component Agency Ethylene glycol ACGIH Ethylene glycol ACGIH Ethylene glycol ACGIH Form -Inhalable aerosol Vapor TWA 0.01 ppm -- 25 ppm STEL -10 mg/m3 50 ppm Ceiling --- -- Notation Skin -- -- _____________________________________________________________________ Revision Number: 16 Revision Date: March 04, 2024 4 of 9 Delo ELC Antifreeze/Coolant Premixed 50/50 SDS : 10673 fraction Consult local authorities for appropriate values. SECTION 9 PHYSICAL AND CHEMICAL PROPERTIES Attention: the data below are typical values and do not constitute a specification. Color: Red Physical State: Liquid Odor: Faint or Mild Odor Threshold: No data available pH: 8.0 - 8.6; 67%volume @ 20C (solution in water) Vapor Pressure: No data available Relative Vapor Density: 2.1 Initial Boiling Point: 109C (228.2F) Solubility: Soluble in water. Freezing Point: -37C (-34.6F) (Max) Melting Point: Not Applicable Specific Gravity: 1.06 - 1.09 Particle Characteristics: Not applicable Density: 1.071 kg/l @ 15C (59F) (Min) Kinematic Viscosity: No data available Coefficient of Therm. Expansion / F: No data available Evaporation Rate: No data available Decomposition temperature: No data available Partition coefficient n-octanol/water (logarithmic value): No data available FLAMMABLE PROPERTIES: Flammability (solid, gas): Not Applicable Flashpoint: Not Applicable Autoignition: No data available Flammability (Explosive) Limits (% by volume in air): Lower: Not Applicable Upper: Not Applicable SECTION 10 STABILITY AND REACTIVITY Reactivity: May react with strong acids or strong oxidizing agents, such as chlorates, nitrates, peroxides, etc. Chemical Stability: This material is considered stable under normal ambient and anticipated storage and handling conditions of temperature and pressure. Incompatibility With Other Materials: Not applicable Hazardous Decomposition Products: Aldehydes (Elevated temperatures), Ketones (Elevated temperatures) Hazardous Polymerization: Hazardous polymerization will not occur. SECTION 11 TOXICOLOGICAL INFORMATION Information on toxicological effects Serious Eye Damage/Irritation: The material is not considered an eye irritant. The product has not been tested. The statement is based on evaluation of data for similar materials or product components. Skin Corrosion/Irritation: The material is not considered a skin irritant. The product has not been tested. _____________________________________________________________________ Revision Number: 16 Revision Date: March 04, 2024 5 of 9 Delo ELC Antifreeze/Coolant Premixed 50/50 SDS : 10673 The statement is based on evaluation of data for similar materials or product components. Skin Sensitization: The material is not considered a skin sensitizer. The product has not been tested. The statement is based on evaluation of data for similar materials or product components. Acute Dermal Toxicity: The material is not considered a dermal toxicant. The product has not been tested. The statement is based on evaluation of data for similar materials or product components. Acute Oral Toxicity: The material is not considered an oral toxicant. The product has not been tested. The statement is based on evaluation of data for similar materials or product components. Acute Inhalation Toxicity: The material is not considered an inhalation toxicant. The product has not been tested. The statement is based on evaluation of data for similar materials or product components. Acute Toxicity Estimate: Not Determined Germ Cell Mutagenicity: The material is not considered a mutagen. The product has not been tested. The statement is based on evaluation of data for similar materials or product components. Carcinogenicity: The material is not considered a carcinogen. The product has not been tested. The statement is based on evaluation of data for similar materials or product components. Reproductive Toxicity: This material may damage the unborn child. The product has not been tested. The statement is based on evaluation of data for similar materials or product components. Specific Target Organ Toxicity - Single Exposure: The material is not considered a target organ toxicant (single exposure). The product has not been tested. The statement is based on evaluation of data for similar materials or product components. Specific Target Organ Toxicity - Repeated Exposure: This material may cause damage to organs through prolonged or repeated exposure. The product has not been tested. The statement is based on evaluation of data for similar materials or product components. Aspiration Hazard: The material is not considered an aspiration hazard. ADDITIONAL TOXICOLOGY INFORMATION: This product contains ethylene glycol (EG). The toxicity of EG via inhalation or skin contact is expected to be slight at room temperature. The estimated oral lethal dose is about 100 cc (3.3 oz.) for an adult human. Ethylene glycol is oxidized to oxalic acid which results in the deposition of calcium oxalate crystals mainly in the brain and kidneys. Early signs and symptoms of EG poisoning may resemble those of alcohol intoxication. Later, the victim may experience nausea, vomiting, weakness, abdominal and muscle pain, difficulty in breathing and decreased urine output. When EG was heated above the boiling point of water, vapors formed which reportedly caused unconsciousness, increased lymphocyte count, and a rapid, jerky movement of the eyes in persons chronically exposed. When EG was administered orally to pregnant rats and mice, there was an increase in fetal deaths and birth defects. Some of these effects occurred at doses that had no toxic effects on the mothers. We are not aware of any reports that EG causes reproductive toxicity in human beings. 2-Ethylhexanoic acid (2-EXA) caused an increase in liver size and enzyme levels when repeatedly administered to rats via the diet. When administered to pregnant rats by gavage or in drinking water, 2EXA caused teratogenicity (birth defects) and delayed postnatal development of the pups. Additionally, 2EXA impaired female fertility in rats. Birth defects were seen in the offspring of mice who were administered sodium 2-ethylhexanoate via intraperitoneal injection during pregnancy. SECTION 12 ECOLOGICAL INFORMATION _____________________________________________________________________ Revision Number: 16 Revision Date: March 04, 2024 6 of 9 Delo ELC Antifreeze/Coolant Premixed 50/50 SDS : 10673 ECOTOXICITY This material is not expected to be harmful to aquatic organisms. The product has not been tested. The statement has been derived from the properties of the individual components. MOBILITY No data available. PERSISTENCE AND DEGRADABILITY This material is expected to be readily biodegradable. The product has not been tested. The statement has been derived from the properties of the individual components. POTENTIAL TO BIOACCUMULATE Bioconcentration Factor: No data available. Partition coefficient n-octanol/water (logarithmic value): No data available SECTION 13 DISPOSAL CONSIDERATIONS Use material for its intended purpose or recycle if possible. This material, if it must be discarded, may meet the criteria of a hazardous waste as defined by international, country, or local laws and regulations. SECTION 14 TRANSPORT INFORMATION The description shown may not apply to all shipping situations. Consult 49CFR, or appropriate Dangerous Goods Regulations, for additional description requirements (e.g., technical name) and modespecific or quantity-specific shipping requirements. DOT Shipping Description: PROPRIETARY ANTIFREEZE PREPARATION IN NON-BULK PACKAGING; NOT REGULATED FOR TRANSPORT UNDER 49 CFR Additional Information: Bulk shipments containing a reportable quantity (RQ, 5000 pounds or more) of ethylene glycol in a single packaging are transported as hazardous material. The shipping description is: UN3082, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S. (ETHYLENE GLYCOL CONTAINS BITTERANT), 9, III, RQ (ETHYLENE GLYCOL) IMO/IMDG Shipping Description: NOT REGULATED AS DANGEROUS GOODS FOR TRANSPORTATION UNDER THE IMDG CODE ICAO/IATA Shipping Description: NOT REGULATED AS DANGEROUS GOODS FOR TRANSPORTATION UNDER ICAO TI OR IATA DGR Transport in bulk according to Annex II of MARPOL 73/78 and the IBC code: Not applicable SECTION 15 REGULATORY INFORMATION EPCRA 311/312 CATEGORIES: Reproductive toxicity Specific target organ toxicity (single or repeated exposure) REGULATORY LISTS SEARCHED: 01-1=IARC Group 1 05=MA RTK _____________________________________________________________________ Revision Number: 16 Revision Date: March 04, 2024 7 of 9 Delo ELC Antifreeze/Coolant Premixed 50/50 SDS : 10673 01-2A=IARC Group 2A 01-2B=IARC Group 2B 02=NTP Carcinogen 03=EPCRA 313 04=CA Proposition 65 06=NJ RTK 07=PA RTK 08-1=TSCA 5(e) 08-2=TSCA 12(b) The following components of this material are found on the regulatory lists indicated. Ethylene glycol 03, 04, 05, 07 CHEMICAL INVENTORIES: All components comply with the following chemical inventory requirements: AIIC (Australia), DSL (Canada), EINECS (European Union), ENCS (Japan), IECSC (China), KECI (Korea), NZIoC (New Zealand), PICCS (Philippines), TCSI (Taiwan), TSCA (United States). NEW JERSEY RTK CLASSIFICATION: Under the New Jersey Right-to-Know Act L. 1983 Chapter 315 N.J.S.A. 34:5A-1 et. seq., the product is to be identified as follows: Refer to components listed in Section 3. SECTION 16 OTHER INFORMATION NFPA RATINGS: Health: 1 Flammability: 1 Reactivity: 0 HMIS RATINGS: Health: 1* Flammability: 1 Reactivity: 0 (0-Least, 1-Slight, 2-Moderate, 3-High, 4-Extreme, PPE:- Personal Protection Equipment Index recommendation, *- Chronic Effect Indicator). These values are obtained using the guidelines or published evaluations prepared by the National Fire Protection Association (NFPA) or the National Paint and Coating Association (for HMIS ratings). REVISION STATEMENT: SECTION 02 - Hazard Statements information was modified. SECTION 02 - Health Classification information was modified. SECTION 02 - Signal Word information was modified. SECTION 03 - Composition information was modified. SECTION 05 - Fire Fighters Protection Measures information was modified. SECTION 08 - Occupational Exposure Limit Table information was modified. SECTION 08 - Skin Protection information was modified. SECTION 09 - Physical/Chemical Properties information was modified. SECTION 10 - Hazardous Decomposition Products information was modified. SECTION 11 - Reproductive Toxicity information was modified. SECTION 11 - Toxicological Information information was modified. SECTION 12 - Ecological Information information was added. SECTION 12 - Ecological Information information was deleted. Revision Date: March 04, 2024 ABBREVIATIONS THAT MAY HAVE BEEN USED IN THIS DOCUMENT: TLV - Threshold Limit Value TWA - Time Weighted Average STEL - Short-term Exposure Limit PEL - Permissible Exposure Limit GHS - Globally Harmonized System CAS - Chemical Abstract Service Number ACGIH - American Conference of Governmental IMO/IMDG - International Maritime Dangerous Goods _____________________________________________________________________ Revision Number: 16 Revision Date: March 04, 2024 8 of 9 Delo ELC Antifreeze/Coolant Premixed 50/50 SDS : 10673 Industrial Hygienists API - American Petroleum Institute HMIS - Hazardous Materials Information System DOT - Department of Transportation (USA) IARC - International Agency for Research on Cancer NCEL - New Chemical Exposure Limit SCBA - Self-Contained Breathing Apparatus Code SDS - Safety Data Sheet NFPA - National Fire Protection Association (USA) NTP - National Toxicology Program (USA) OSHA - Occupational Safety and Health Administration EPA - Environmental Protection Agency PNOS - Particles Not Otherwise Specified Prepared according to the 29 CFR 1910.1200 (2012) by Chevron. The above information is based on the data of which we are aware and is believed to be correct as of the date hereof. Since this information may be applied under conditions beyond our control and with which we may be unfamiliar and since data made available subsequent to the date hereof may suggest modifications of the information, we do not assume any responsibility for the results of its use. This information is furnished upon condition that the person receiving it shall make his own determination of the suitability of the material for his particular purpose. _____________________________________________________________________ Revision Number: 16 Revision Date: March 04, 2024 9 of 9 Delo ELC Antifreeze/Coolant Premixed 50/50 SDS : 10673 APPENDIX 8. FOLLOW-UP RESPONSE FROM 8/1/2024 Appendix 8 Page 1 of 2 Appendix 8 Page 2 of 2