Comments on UST Contaminated Soil Landfarm Permit Request, Lee County, KY

My name is Will Herrick. I have resided in Lee County for more than 25 years. I wish to encourage the Commonwealth of Kentucky to deny the pending application # 065-00004 LP1NW1.

I have three reasons to challenge the landfarm permit:

• It is clear that the site design fails to meet the design goals,
• The Public, Lee County and the Commonwealth of Kentucky are at risk from fugitive contaminants escaping from this site, and
• I have a compelling personal experience, that being the protracted and painful death of my mother from aplastic anemia. This disease is well associated with exposure to Benzene (and other solvents), a common component of the blended fuels being brought into Lee County under this permit. I have a deep and abiding respect for the hazards of the contamination under review here.

The long-term risk to Lee County and to the state is genuine. At a minimum the permit needs to extend the bonding requirement to cover the continuing oversight, cleanup, and closure costs that come with siting the facility, else these costs will fall to the county and state taxpayers. Failing that, the hazardous compounds will enter the air and water unabated.

Without design improvements controlling the field source emmisions of hazardous airborne chemicals, of contaminated dust, and of chemical contact, the operating staff will be at risk for chronic exposure to known hazards that their managers have already declared to be of no concern to them (Facility Impact Report P3, Sections a, b, c & d: "There will be no increased risk of accidents associated with Soil Tech activities", "Measures have been taken to prevent any water run off from soils..." {tarps}, "No adverse effects are expected to land or water...gasoline quickly evaporates into the atmosphere", "We do not expect any adverse effects on human health" and "Generally one will be exposed to more fumes from filling an automobile" {Why are those signs posted at gas stations around the nation warning that fuel fumes are carcinogenic and to be avoided?}).

The applicants frequently cite the presence of other oil wells in the region. They imply the excuse that the area is already inundated with whatever has come from these other wells and cannot be impacted by yet another contamination source. This argument is false- blended gasoline has many compounds not found in crude petroleum, to wit: lead, MTBE, etc, and the constituents common to the two are found in entirely different concentrations. Lastly, two wrongs do not make a right. Adding new burdens to the most heavily contaminated yet important stretch of waterway in the Commonwealth, the Kentucky River, cannot be construed as meaningless or below regulatory concern.

The design needs repair to control hazardous airborne contaminants. The Division of Air Quality should require a permit application for the Volatile Organic Compound emissions. The design as submitted is actually a primitive 40,000 square foot (0.9 acre) air-stripper promoting evaporation and atmospheric transport over hydrocarbon metabolism (see Treatment Process Information, P1, Section 2: "Soils transported to the site will be remidated [sic] by aeration [sic]" and Application to Process Solid Waste, P1, paragraph B, section 4, "Soils are easily remediated with exposure to open air." and Facility Impact Report P3 Section 3, Subsections c & d: "Since gasoline quickly evaporates into the atmosphere" and "Gasoline contaminated soils are quickly remediated after they have been exposed to open air").

Hydrologic protections offered by the proposed design are simply absent. The only clear language on offer is not even part of the permit application, but a non-binding ancillary document, the "Fact Sheet" where it is stated that "in the event water must be removed, the company has a permitted disposal facility available to accept liquid from the containment cells". The Facility Impact Report, Section 2b, is entirely disengenuous: "Due to the fact that we are working only with solid waste, and this waste being placed in impermeable concrete cells, there will be no impact on any groundwater reserves in the area." Please refer to the prior citation, "Soils are easily remediated with exposure to open air"- the operators intend to expose these soils to wind and sun, while expecting that none of the evaporated compounds or airborne dust will ever leave the site and re-enter the hydrologic cycle? The proposed scheme for placing tarpaulins in the event of rain is a hoax (Facility Impact Report, P2, Section 3b: "If necessary cells can be covered with covered with [sic] tarping or plastic."). Without a 24-hour monitor, no-one will rise to the 3 am downpour, much less cover the entire 0.9 acre site before some runoff leaves the site and more floods the bottom of the containments cells. The subsequent anaerobic conditions will have a major impact on the microbial populations and their ability to oxidize hydrocarbons.

The only service this site offers is a benefit to the owners of the contaminated soil. According to the application, none of the principles have any experience operating such a facility.

There are adequate facilities in the Commonwealth that have better engineering, oversight, and bonding to provide the service being offered by the applicants. It is in everyone's interest to not lower is standards for contaminated soil remediation and invite the proliferation of undercapitalized, ill managed, understaffed facilities.

I have included below a very brief survey of the available literature to document my arguments. Neither inclusive nor detailed, these tip-of-the-iceberg citations give authoritative published support to my position:

• that the design submitted in the permit application is a recipe for air and water contamination;
• that a significant fraction of the contaminants ostensibly intended for bio-remediation by metabolic processes within bacteria will in fact escape untreated into the air and waters of the Commonwealth,
• that the air and water born effluents from this site are a public health risk; and
• that the operations staff are immersed in a field source of hazardous dust, vapor, and fluid.

The Permit by Rule historically given to landfarms by DNREP has been based on remediation of organic waste as a fertilizer amendment to deep healthy soils. The permit being sought here in fact seeks to evaporate significant fractions of the volatile contaminants, has no impact on soil fertility, and fails to show the required technical expertise to effectively manage bio-remediation. The husbanding of soil microbia is not trivial. The estimates and timeframes listed in the permit application demonstrate an optimistic ignorance of microbial growth kinetics, rates of remediation, and the likelyhood of metal toxicity impacting microbial populations.

---

The below are sample references on the hazards of blended fuels with an emphasis on Aplastic Anemias and Benzene. I have narrowed the focus for examples only- I could offer similar documentation on Lead, MTBE, Toluene and expect the Commonwealth to consider all known hazardous compounds found in the waste stream under permit.

• Report to the Occupational Disease Panel (Industrial Disease Standards Panel) on Occupational Exposure to Benzene and Leukaemia: Jennifer Penney,September 1995 [https://www.canoshweb.org/odp/html/rp7.htm]

Selected quotes on Benzene Exposures:

"Because of its anti-knock properties, benzene-containing substances are added to gasoline as a replacement for alkyl lead compounds. Gasoline contains from less than one to five percent

of benzene by volume." (International Agency for Research on Cancer. Benzene. IARC Monographs on the Evaluation of Carcinogenic Risk of Chemicals to Humans Vol. 29,Lyon France 1982)

IARC identifies the following major contributors to benzene emissions into air: (1) gasoline production, storage, transport, vending and combustion...(International Agency for Research on Cancer. Benzene. IARC Monographs on the Evaluation of Carcinogenic Risk of Chemicals to Humans Vol. 29, Lyon France 1982)

...

Because of the high volatility of benzene, inhalation is the most important route of exposure. Almost 50 percent of inhaled benzene is absorbed. (Landrigan and Nicholson, 1992) NIOSH estimates that

approximately 1% of benzene is absorbed from skin contact. However dermal absorption is enhanced and may approach 5% when skin is cracked, blistered or abraded as in rubber workers engaged in tire building. (Occupational Safety and Health Administration (OSHA). Final Rule on Occupational Exposure to Benzene. Fed Regist 1987;52:34460-34578)

...

Benzene is sometimes found in drinking water, primarily as a result of gasoline spills, or seepage from underground gasoline tanks. (Akland GG. Exposure of the general population to gasoline. Environ Health Persp Suppl 1993;101:27-32)

• National Emission Standards for Hazardous Air Pollutants: Off-Site Waste and Recovery Operations; Final Rule

[Federal Register: July 1, 1996 (Volume 61, Number 127)] [Rules and Regulations] [Page 34139-34200]

SUMMARY: This action promulgates National Emission Standards for Hazardous Air Pollutants (NESHAP) under the authority of Section 112 of the Clean Air Act for off-site waste and recovery operations that emit hazardous air pollutants (HAP). The NESHAP applies to specific types of facilities that are determined to be major sources of HAP emissions and receive certain wastes, used oil, and used solvents from off-site locations for storage, treatment, recovery, or disposal at the facility. The rule requires use of maximum achievable control technology (MACT) to reduce HAP emissions from tanks, surface impoundments, containers, oil-water separators, individual drain systems and other material conveyance systems, process vents, and equipment leaks.

...

From the section II. Basis and Purpose, subcategory A. Purpose of Regulation:

Following is a summary of the potential health and environmental effects associated with exposures, at some level, to the emitted pollutants that would be reduced by this NESHAP. The range of potential human health effects associated with exposure to organic HAP include cancer, aplastic anemia, pulmonary (lung) structural changes, dyspnea (difficulty in breathing), upper respiratory tract irritation with cough, conjunctivitis, and neurotoxic effects (e.g., visual blurring, tremors,delirium, unconsciousness, coma, convulsions).

• Environmental Health Perspectives, Volume 104, Supplement 6, December 1996

Clinical Features of Hematopoietic Malignancies and Related Disorders among Benzene-exposed Workers in China

Martha S. Linet,1 Song-Nian Yin,2 Lois B. Travis,1Chin-Yang Li,3 Zhi-Nan Zhang,4 De-Gao Li,4 Nathaniel Rothman,1 Gui-Lan Li,2 Wong-Ho Chow,1 Jennifer Donaldson,1 Mustafa

Dosemeci,1 Sholom Wacholder,1 William J. Blot,1 Richard B. Hayes,1 and The Benzene Study Group*

From the Discussion section of this article:

Fatal aplastic anemia was first reported among benzene-exposed workers nearly 100 years ago (72), while leukemia was initially linked with benzene exposure in 1928 (73)... Case-control studies have also linked benzene exposure (primarily occupational) with leukemia (10,78,79). These clinical series, case-control studies, and two important cohort investigations (18,19,80) were considered to provide sufficient evidence to link benzene with leukemia, particularly AML, in humans (2). Subsequent cohort investigations of benzene-exposed workers within chemical manufacturing, petroleum refinery, or other industries in the United States, the United Kingdom, Italy, and China have confirmed the benzene-leukemia association (Table 3) (81,82). Although acute myeloid leukemia, not otherwise characterized, has been the type of malignancy most consistently associated with benzene exposure, other unusual variants of acute myeloid leukemia, particularly erythroleukemia and to a lesser extent acute myelomonocytic leukemia, appear to occur disproportionately in some studies of benzene-related leukemia (15,83-85). While chronic myeloid leukemia has been mentioned in clinical reports (86,87), the only previous cohort investigation in which this

leukemia type was noted was the first cohort study by Yin et al. in China (6).

• Aplastic Anemia in a Petrochemical Factory Worker

Young Mann Baak, Byoung Yong Ahn, Hwang Shin Chang, Ji Hong Kim, Kyoung Ah Kim, and Young Lim. Environ Health Perspect 107:851-853 (1999). Department of Industrial Medicine, St. Mary's Hospital, The Catholic University of Korea, Seoul, Korea

Abstract

A petrochemical worker with aplastic anemia was referred to our hospital. He worked in a petroleum resin-producing factory and had been exposed to low-level benzene while packaging the powder resin and pouring lime into a deactivation tank. According to the yearly environmental survey of the working area, the airborne benzene level was approximately 0.28 ppm. Exposure to benzene, a common chemical used widely in industry, may progressively lead to pancytopenia, aplastic anemia, and leukemia. The hematotoxicity of benzene is related to the amount and duration of exposure. Most risk predictions for benzene exposures have been based on rubber workers who were exposed to high concentrations. In the petroleum industry, the concentration of benzene is relatively low, and there are disputes over the toxicity of low-level benzene because of a lack of evidence. In this paper we report the case of aplastic anemia induced by low-level benzene exposure.

---

EPA might tighten regulations on gas additive that fouls water

Published Friday, February 25, 2000, in the Lexington Herald-Leader

ASSOCIATED PRESS, LOUISVILLE

The Environmental Protection Agency might tighten controls over an additive that produces cleaner gasoline but is fouling water in many states, including Kentucky.

Four state legislators already have expressed their concern by pressing for a General Assembly resolution supporting an MTBE ban in Kentucky. The lawmakers acted as the EPA notified the federal Office of Management and Budget that it wants public comment on a proposal to regulate MTBE under the Toxic Substances Control Act. Tighter regulation could lead to phasing out the additive, which has been turning up in groundwater, lakes and rivers from California to Maine.

The resolution by state Sen. Dan Seum, R-Louisville, and his colleagues urges the state Natural Resources and Environmental Protection Cabinet to develop drinking-water standards for MTBE and to increase testing for the chemical. Kentucky environmental officials have found no current or imminent threat to water supplies.

---

BP OIL -- GASOLINE BP REGULAR UNLEADED (RFG W-MTBE)

MATERIAL SAFETY DATA SHEET

NSN: 9130013884080

Manufacturer's CAGE: 0NDT1

Part No. Indicator: A

Part Number/Trade Name: GASOLINE BP REGULAR UNLEADED (RFG W/MTBE)

===========================================================================

General Information

===========================================================================

Item Name: GASOLINE/BLENDED; MOTOR FUEL

Company's Name: BP OIL CO

Company's Street: 200 PUBLIC SQ

Company's City: CLEVELAND

Company's State: OH

Company's Country: US

Company's Zip Code: 44114-2375

Company's Emerg Ph #: 216-586-4219/800-321-8642

Company's Info Ph #: 216-586-4219/800-321-8642

Record No. For Safety Entry: 001

Tot Safety Entries This Stk#: 001

Status: SE

Date MSDS Prepared: 08JUN94

Safety Data Review Date: 01MAR96

Preparer's Company: BP OIL CO

Preparer's St Or P. O. Box: 200 PUBLIC SQ

Preparer's City: CLEVELAND

Preparer's State: OH

Preparer's Zip Code: 44114-2375

MSDS Serial Number: BYPGP

===========================================================================

Ingredients/Identity Information

===========================================================================

Proprietary: NO

Ingredient: METHYL TERT BUTYL ETHER (MTBE), 2-METHOXY-2-METHYL PROPANE,

T-BUTYLMETHYL ETHER *96-1*

Ingredient Sequence Number: 01

Percent: 15

NIOSH (RTECS) Number: KN5250000

CAS Number: 1634-04-4

-------------------------------------

Proprietary: NO

Ingredient: XYLENE, DIMETHYLBENZENE, XYLOL (IARC - GROUP 3) *95-4*

Ingredient Sequence Number: 02

Percent: 9

NIOSH (RTECS) Number: ZE2100000

CAS Number: 1330-20-7

OSHA PEL: 100 PPM

ACGIH TLV: 100 PPM, SKIN

Other Recommended Limit: 100 PPM

-------------------------------------

Proprietary: NO

Ingredient: TOLUENE (IARC CARC- GROUP 3) *95-4*

Ingredient Sequence Number: 03

Percent: 6

NIOSH (RTECS) Number: XS5250000

CAS Number: 108-88-3

OSHA PEL: 100 PPM

ACGIH TLV: 100 PPM

Other Recommended Limit: 375 MG/CUM

-------------------------------------

Proprietary: NO

Ingredient: 1,2,4-TRIMETHYLBENZENE *95-4*

Ingredient Sequence Number: 04

Percent: 3

NIOSH (RTECS) Number: DC3325000

CAS Number: 95-63-6

ACGIH TLV: 25 PPM

-------------------------------------

Proprietary: NO

Ingredient: BENZENE (SUSPECTED HUMAN CARC BY ACGIH, IARC, ANIMAL

CARCINOGEN BY IARC, CARCINOGEN BY NTP - IARC GROUP 1) *95-4*

Ingredient Sequence Number: 05

Percent: 2

NIOSH (RTECS) Number: CY1400000

CAS Number: 71-43-2

ACGIH TLV: 0.3 MG/CUM (A2) IC

Other Recommended Limit: 16 MG/CUM

-------------------------------------

Proprietary: NO

Ingredient: ETHYL BENZENE *95-4*

Ingredient Sequence Number: 06

Percent: 2

NIOSH (RTECS) Number: DA0700000

CAS Number: 100-41-4

OSHA PEL: 435 MG/CUM

ACGIH TLV: 434 MG/CUM

Other Recommended Limit: 100 PPM

-------------------------------------

Proprietary: NO

Ingredient: CYCLOHEXANE

Ingredient Sequence Number: 07

Percent: 1

NIOSH (RTECS) Number: GU6300000

CAS Number: 110-82-7

OSHA PEL: 1050 MG/CUM

ACGIH TLV: 1030 MG/CUM

Other Recommended Limit: 300 PPM

-------------------------------------

Proprietary: NO

Ingredient: GASOLINE

Ingredient Sequence Number: 08

Percent: 85-86

NIOSH (RTECS) Number: LX3300000

CAS Number: 8006-61-9

ACGIH TLV: 890 MG/CUM

Other Recommended Limit: 300 PPM

===========================================================================

Physical/Chemical Characteristics

===========================================================================

Appearance And Odor: CLEAR LIQUID W/A STRONG HYDROCARBON ODOR

Boiling Point: 80-440F

Vapor Pressure (MM Hg/70 F): 760

Vapor Density (Air=1): 1.2

Specific Gravity: 0.72-0.74

Evaporation Rate And Ref: (WATER = 1): >1

Solubility In Water: NEGLIGIBLE

Percent Volatiles By Volume: 100

===========================================================================

Fire and Explosion Hazard Data

===========================================================================

Flash Point: -35F

Flash Point Method: TCC

Lower Explosive Limit: 1.4

Upper Explosive Limit: 7.6

Extinguishing Media: DRY CHEMICAL, ALCOHOL FOAM, CLASS B EXTINGUISHERS,

CO2.

Special Fire Fighting Proc: WATER MAY BE INEFFECTIVE, USE TO COOL FIRE

EXPOSED CONTAINERS. FIREFIGHTERS MUST WEAR MSHA/NIOSH APPROVED POSITIVE

PRESSURE SCBA W/FULL FACE MASK/CLOTHING.

Unusual Fire And Expl Hazrds: VAPORS MAY FORM FLAMMABLE/EXPLOSIVE

MIXTURES

W/AIR. VAPOR/GAS MAY SPREAD TO DISTANT IGNITION SOURCES & FLASHBACK.

CONTAINERS MAY EXPLODE IN HEAT OF FIRE.

===========================================================================

Reactivity Data

===========================================================================

Stability: YES

Cond To Avoid (Stability): HEAT, SOURCES OF IGNITION

Materials To Avoid: STRONG OXIDIZERS & ALKALI METALS, STRONG

ACIDS/BASES.

Hazardous Decomp Products: CO, CO2, HYDROCARBONS

Hazardous Poly Occur: NO

===========================================================================

Health Hazard Data

===========================================================================

Route Of Entry - Inhalation: YES

Route Of Entry - Skin: NO

Route Of Entry - Ingestion: YES

Health Haz Acute And Chronic: INGESTION: HARMFUL/FATAL. ASPIRATION

HAZARD,

CAN ENTER LUNGS & CAUSE PNEUMONITIS/DAMAGE. IRRITATION, HARMFUL CNS

EFFECTS, RESPIRATORY ARREST, DEATH. INHALATION: RESPIRATORY TRACT

IRRITATION, CNS EFFECTS, IRREGULAR HEAT RHYTHMS. SKIN: IRRITATION,

BURNS.

EYES: IRRITATION, CONJUNCTIVITIS.

Carcinogenicity - NTP: YES

Carcinogenicity - IARC: YES

Carcinogenicity - OSHA: NO

Explanation Carcinogenicity: SEE INGREDIENTS.

Signs/Symptoms Of Overexp: IRRITATION, GI DISTURBANCES, NAUSEA,

VOMITING,

DIARRHEA, EXCITATION, EUPHORIA, HEADACHE, DIZZINESS, DROWSINESS, BLURRED

VISION, FATIGUE, TREMORS, CONVULSIONS, LOSS OF CONSCIOUSNESS, COMA,

DEFATTING, REDNESS, ITCHING, CRACKING OF SKIN, BURNS, SWOLLEN &

DISCOLORED

TISSUE, PAIN, LACRIMATION, INFLAMMATION.

Med Cond Aggravated By Exp: PRE-EXISTING EYE, SKIN & RESPIRATORY

DISORDERS.

Emergency/First Aid Proc: INGESTION: DON'T INDUCE VOMITING. ASPIRATION

HAZARD. SKIN: WASH W/SOAP & WATER. INJECTIONS NEED SERIOUS MEDICAL

ATTENTION. EYES: FLUSH W/WATER FOR 15 MINS. INHALATION: REMOVE TO FRESH

AIR. GIVE OXYGEN/CPR AS NEEDED. NOTE TO PHYSICIAN: ACUTE CHEMICAL

PNEUMONITIS CAN RAPIDLY PROGRESS TO RESPIRATORY FAILURE. FOR SKIN

INJECTION

CONSIDER DEBRIDEMENT TO MINIMIZE NECROSIS & TISSUE LOSS. (SEE SUPP)

===========================================================================

Precautions for Safe Handling and Use

===========================================================================

Steps If Matl Released/Spill: SHUT OFF IGNITION SOURCES. STOP LEAK

SAFELY.

WATER SPRAY MAY REDUCE VAPOR IN CLOSED SPACES. SMALL: TAKE UP

W/SAND/OTHER

NONCOMBUSTIBLE ABSORBENT MATERIAL & PLACE INTO CONTAINERS FOR LATER

DISPOSAL. LARGE: DIKE FAR AHEAD OF LIQUID FOR LATER DISPOSAL.

Waste Disposal Method: THE TRANSPORTATION, STORAGE, TREATMENT & DISPOSAL

OF THIS WASTE IAW/FEDERAL, STATE & LOCAL REGULATIONS. FLAMMABLE LIQUID

UN1203.

Precautions-Handling/Storing: STORE GASOLINE ONLY IN APPROVED, CLEARLY

LABELED CONTAINERS. NEVER STORE IN GLASS/UNAPPROVED PLASTIC CONTAINERS.

STORE IN TIGHTLY CLOSED CONTAINERS.

Other Precautions: STORE IN A COOL, DRY ISOLATED, WELL VENTILATED AREA

AWAY FROM HEAT. GROUND LINES & EQUIPMENT USED DURING TRANSFER TO REDUCE

STATIC SPARK, FIRE/EXPLOSION. KEEP OUT OF REACH OF CHILDREN. DON'T

SIPHON

PRODUCT BY MOUTH. (SEE SUPP)

===========================================================================

Control Measures

===========================================================================

Respiratory Protection: USE NIOSH APPROVED RESPIRATORY PROTECTION SHOULD

BE WORN. RESPIRATORY PROTECTION MAY BE NEEDED FOR NON-ROUTINE/EMERGENCY

SITUATIONS.

Ventilation: VENTILATION & OTHER FORMS OF CONTROLS ARE PREFERRED FOR

CONTROLLING CHEMICAL EXPOSURES.

Protective Gloves: IMPERVIOUS

Eye Protection: SAFETY GLASSES/CHEMICAL GOGGLES

Other Protective Equipment: PROTECTIVE CLOTHING.

Work Hygienic Practices: REMOVE/LAUNDER CONTAMINATED CLOTHING BEFORE

REUSE. WASH HANDS BEFORE EATING, DRINKING, SMOKING/USING TOILET

FACILITIES.

Suppl. Safety & Health Data: USE GOOD PERSONAL HYGIENE PRACTICES. SHOWER

AFTER WORK USING SOAP & WATER. FIRST AID: OBTAIN MEDICAL ATTENTION IN

ALL

CASES. PREC: DON'T USE FOR CLEANING, PRESSURE APPLIANCE FUEL. EMPTY

CONTAINERS MAY CONTAIN TOXIC, FLAMMABLE/COMBUSTIBLE/EXPLOSIVE RESIDUE/

VAPORS. DON'T CUT/GRIND/DRILL/WELD, REUSE/DISPOSE CONTAINERS.

===========================================================================

Transportation Data

===========================================================================

===========================================================================

Disposal Data

===========================================================================

===========================================================================

Label Data

===========================================================================

Label Required: YES

Label Status: G

Common Name: GASOLINE BP REGULAR UNLEADED (RFG W/MTBE)

Special Hazard Precautions: INGESTION: HARMFUL/FATAL. ASPIRATION HAZARD,

CAN ENTER LUNGS & CAUSE PNEUMONITIS/DAMAGE. IRRITATION, HARMFUL CNS

EFFECTS, RESPIRATORY ARREST, DEATH. INHALATION: RESPIRATORY TRACT

IRRITATION, CNS EFFECTS, IRREGULAR HEAT RHYTHMS. SKIN: IRRITATION,

BURNS.

EYES: IRRITATION, CONJUNCTIVITIS. IRRITATION, GI DISTURBANCES, NAUSEA,

VOMITING, DIARRHEA, EXCITATION, EUPHORIA, HEADACHE, DIZZINESS,

DROWSINESS,

BLURRED VISION, FATIGUE, TREMORS, CONVULSIONS, LOSS OF CONSCIOUSNESS,

COMA,

DEFATTING, REDNESS, ITCHING, CRACKING OF SKIN, BURNS, SWOLLEN &

DISCOLORED

TISSUE, PAIN, LACRIMATION, INFLAMMATION.

Label Name: BP OIL CO

Label Street: 200 PUBLIC SQ

Label City: CLEVELAND

Label State: OH

Label Zip Code: 44114-2375

Label Country: US

Label Emergency Number: 216-586-4219/800-321-8642




---