GOLDMAN ANTONETTI FERRAIUOLI <fe AXTMAYER
ATTORNEYS AND COUNSELORS AT LAW
POST OFFICE BOX 13486
SAN JUAN. PUERTO RICO OO9O8-3486
VICENTEJ ANTONETTI
JOSE E ARRARAS
ALVARO C CIFUENTES-
JOSE A AXTMAYER*
JOSE A CEPEOA RODRIGUEZ
BLAS R FERRAIUOLI
ROBERTO MONTALVO
LUIS F ANTONETTI
RICARDO MUNI7"
LEONARDO ANORADE LUGO
JORGE L MARTINEZ
EUGENIC C ROMERO
LUIS D ORTIZ ABREU
GREGORY T USERA"
FRANCISCO A BESOSA"
FRANCIS TORRES
CARLOS A RODRIGUEZ VIDAL"
DANILOM EBOU
THELMA RIVERA LABOY
JORGE SEGUROLA
JUAN H SAAVEDRA CASTRO*
COUNMI.
MAX GOLDMAN*
SANTURCE OFFICE
409 INSURANCE CENTER BUILDING
7O1 PONCE DE LEON AVENUE
SANTURCE. PUERTO RICO OO9O7
TELEPHONE (8O9) 721 2424
TELECOPIER (8O9) 721 1796
TELECOPIER (UTK3ATION) (8O9) 722 6571
HATO REV OFFICE
SUITE 1420
BANCO POPULAR CENTER
HATO REY PUERTO RICO OO918
TELEPHONE (8O9) 759 8OOO
TELECOPIER (8O9) 765 8O97
RAMON L VELASCO
JORGE F FREYRE—
CARLOS F RAMIREZ OE ARELLANO
KARIN G DIAZ-TORO
FRANCISCO J GARCIA
EDGARDO COLON APRARAS
JOSE M LORIE VELASCO
BRAUUO GARCIA JIMENEZ
WILMER J CAMACHO
HOWARD PRAVDA
MARlA OE LOUROES RODRIGUEZ
ROSA M CRUZ-NIEMIEC
MIGUEL J ROORIGUEZ MARXUACH
CARLOS E COLON FRANC ESC HI
MARlA ELENA ORTIZ
IVETTE GONZALEZ BUITRAGO
p m THI mtfVMLi or COLUMW*
'"f>L$O AOMTPTtD M »
April 29, 1991 
3 
"7 V-",
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••rj 
••'
Ms. Kathleen Callahan, Director 
. : "•"•' •
Emergency and Remedial Response Division 
•-''•. o
U.S. Environmental Protection Agency 
u'
26 Federal Plaza
New York, New York 10278
RE: Request for Information under 42 U.S.C. §9604
Concerning 
Potential 
Releases 
of 
Hazardous
Substance at the ESSO Tutu Service Station in St.
Thomas, U.S.V.I.
Dear Ms. Callahan:
This constitutes ESSO Standard Oil S.A. Limited's ("Esso")
response to the Request for Information under 42 U.S.C. §9604 sent
by the U.S. Environmental Protection Agency (EPA) on April 4, 1991.
Esso was granted an extension until today, April 29, 1991, to
submit this response to EPA.
This response has been prepared pursuant to all the informa-
tion that is and has been made available to Esso until this date.
Please note that there are certain documents pertaining to
inventories of products handled at the Esso Tutu Service Station by
Mr. Daniel Bayard that have not been made available to Esso for the
preparation of these responses. Once we are provided with these
documents by Mr. Bayard, or if any other pertinent information or
document is obtained, we will immediately supplement Esso's
response to the Request for Information, if necessary.
24 SO
*64492*
64492
GOLDMAN ANTONBTTI FERRAIUOLJ <fe AXTMAYBR
-2-
REOUEST NO. 1
Here, or are, any hazardous substances ever used, stored,
generated, disposed or otherwise handled at the facility, including
but not limited to 1,1,1, trichloroethane, trichloroethylene
("TCE"), 1,2 trans-dichloroethylene ("DCE"), tetra-chloroethylene
("PCE"), and methyl-ethyl-ketone ("MEK")? Identify each hazardous
substance by providing the name, composition and source of origin
of each substance.
RESPONSE NO. 1
ESSO has no specific knowledge regarding the use, storage,
generation, disposal or handling of hazardous substances at the
ESSO Tutu Service Station (hereinafter referred to as "ETSS11). The
ETSS, although now owned and operated by ESSO Virgin Islands, Inc.,
was operated under a lease from 1970 until 1971 by Mr. Robert Dunn,
from 1971 until 1978 by Mr. Daniel Bayard, Sr., and from 1978 until
1990 by Mr. Daniel Bayard, Jr. The whereabouts of Mr. Dunn are un-
known and Mr. Bayard, Sr., was deceased in 1978, therefore ESSO has
been unable to obtain any information and/or documents from the two
(2) first operators of the ETSS to prepare this response.
As such, Esso has never used, stored, generated, disposed or
otherwise handled hazardous substances at the ETSS. We know of no
ESSO product that had been marketed at the ETSS which contained the
materials specifically listed in the Request No. l. Notwithstand-
ing the above, and in attention to a request by EPA dated May 18,
1988, to provide Material Safety Data Sheets (MSDS) of all the
cleaning products and solvents used at the ETSS from 1987 on, EPA
was provided on August 17, 1988 a copy of the MSDS of the engine
cleaner used at the ETSS by Mr. Daniel Bayard in his auto mechanic
shop. Copy of the pertinent MSDS, as well as corresponding cover
letter, is attached herewith as part of this response.
As operator and lessee of the service station from 1978 until
1990, Mr. Bayard is the person with specific knowledge of the
materials, including hazardous substances, that may have been used,
stored, generated, or handled at the ETSS.
According to Mr. Bayard, engine cleaning or degreasing was not
a service provided at the ETSS mechanic shop. During the very few
occasions in which he recalls that an engine cleaner was used, the
particular car was driven to a facility having a steam or pressure
cleaning system where the cleaner and the engine grease was
removed.
i"f 
OO3 
248.1
GOLDMAN ANTONETTI FKRRAIUOLI <fe AXTMAYBR
-3-
Analytical results of samples obtained by EPA on August 17,
1987 from the oil and water separator at the ETSS showed the
presence of certain chlorinated compounds which are listed as
hazardous substances. 
However, ESSO has no specific knowledge
regarding the origin, composition or nature of these hazardous
substances which were included in EPA's sampling results.
Inventory records of Mr. Bayard's operations at the ETSS have
not been made available to Esso yet. 
Once these records are
provided and analyzed, ESSO will supplement these responses
accordingly.
REQUEST MO. 2
For each hazardous substance identified above, please provide
an annual summary describing how each such substance was treated,
handled, transported, stored and/or disposed of by the facility.
Please attach any manifests, invoices and other documentation which
relate to the treatment, handling, transportation, storage and/or
disposal of each such substance. If you are unable to provide a
copy of any such document, please describe the document and explain
why it cannot be provided.
RESPONSE MO. 2
Esso has no document in its possession which relates to the
treatment, handling, transportation, storage and/or disposal of
such substances. Please refer to Response No. 1.
REQUEST NO. 3
Are, or were, auto mechanic repairs, including oil changes,
performed at the ESSO facility? 
Please describe what type of
repairs were performed, if any, and the frequency of such repairs.
RESPONSE NO. 3
To the best of our knowledge and belief, Mr. Daniel Bayard,
Jr., as lessee of the ETSS conducted auto mechanic repairs and oil
changes at the facility. However, ESSO has no specific information
with respect to the type of repairs that were performed at the ETSS
or the frequency of oil changes performed by Mr. Daniel Bayard.
Mr. Bayard has informed ESSO that oil changes were performed at a
frequency of 2 to 4 per day. Light mechanical repairs were also
performed at the ETSS such as general tune-ups, brakes repairs, and
other miscellaneous small repairs, at a frequency of 4 to 6 per
day.
248:.
GOLDMAN ANTONBTTI FERRAIUOLJ <fe AXTMAYBR
-4-
REOUEST NO. 4
If the answer to Question 3 above is yes, were any hazardous
substances or hazardous wastes generated, treated, stored, disposed
of or otherwise handled in the process? Please attach any mani-
fests, invoices, and other documentation which relates to this
question. 
If you are unable to provide a copy of any such
document, please describe the document and explain why it cannot be
provided.
RESPONSE MO. 4
ESSO has no specific knowledge of, nor documents which relate
to, any hazardous substances or hazardous waste being generated,
treated, stored, disposed of or otherwise handled at the ETSS.
REQUEST HO. 5
If the answer to Question 3 above is yes, please list and/or
describe what kinds of solvents were used. In addition, please
describe where and how these solvents were stored at the facility
prior to their use, and all disposal practices regarding these
solvents. Please attach any manifests, invoices and other docu-
mentation which relate to this question. 
If you are unable to
provide a copy of any such document, please describe the document
and explain why it cannot be provided.
RESPONSE MO. 5
According to the information provided by Mr. Daniel Bayard,
engine cleaners and brake cleaners in spray cans were sold at the
ETSS. The engine cleaner used at the station's mechanics shop is
described in the MSDS attached hereto. The use of these products
at the station's mechanics shop did not generate any waste. The
spray cans, once empty, were disposed of in the waste basket.
We know of no ESSO solvent products that have been marketed at
the ETSS. Besides, from the MSDS attached hereto, Esso has no
other document which relates to this question.
REQUEST NO. 6
If oil changes were conducted at the facility, please give an
annual summary explaining how the used oil was disposed of, the
quantity disposed of per month and any and all analysis of this
used oil. Please provide all appropriate documentation. If any
such document is not available, please describe the document and
explain why it cannot be provided.
GOLDMAN ANTONETTI FBRRAIUOLJ <fe AXTMAYKR
-5-
RE8PON8B NO. 6
Used oil handling, management and storage practices were con-
ducted at the ETSS by Mr. Daniel Bayard who is the person with
specific knowledge of those practices. ESSO has knowledge of the
common practice of service station operation in the U.S. Virgin
Islands to provide the used oil generated at the stations' mechan-
ics shops for energy recovery to the Water and Power Authority of
the Virgin Islands until such time that the regulations applicable
to such operation became effective. ESSO is also aware of off-site
disposal by Safety Kleen Envirosystems Company, Inc., of the used
oil generated at the service station in the U.S. Virgin Islands,
which may include the ETS"
According to Mr. Bayard, approximately 75 gallons of used oil
were generated at the service station as a result of oil changes.
The used oil was removed by gravity into a 5 gallon storage cart
with a capture funnel on top. The used oil was then stored at a
2,000 gallon storage tank located at the ETSS. Subsequently, the
used oil was removed by the local government (V.I. Department of
Energy) for usage at the WAPA power plant. The used oil was also
removed and transported off-site for disposal by Safety Kleen
Envirosystems, Inc.
Mr. Bayard maintains that he has no records of the instances
in which the used oil was removed and transported off-site. Nor
are there records of analysis, if any, of the used oils.
REQUEST NO. 7
Please describe the structure and location of each oil and
water separator at the facility, as well as explain the use of each
such unit. Include separators which have been removed and/or shut
down. Please attach a diagram or drawing of these units, the dates
of their use and their location.
RESPONSE NO. 7
The only oil and water separator ever operated at the ETSS was
constructed in 1986 by EDACO (Eugenio de Arce), an independent
contractor. The separator is made of reinforced concrete with a
steel cover, and has three (3) compartments designed to separate
oils, greases and sludges from the water. A diagram illustrating
the location of the separator at the ETSS is attached herewith.
The separator is presently out of use since all mechanic shop
activities were discontinued in 1990.
O03 2484
GOLDMAN ANTONBTTI F*ERRAIUOLI <fe AXTMAYER
-6-
REQUEST NO. 8
Is there, or has there ever been, any means by which fluids or
sludge can escape or be discharged from any oil and water separator
(i.e., an open overflow valve or pipe) that presently exists or
existed at the facility?
RESPONSE NO. 8
In 1986 a pipe was constructed by EDACO to connect the water
phase of the separator into a sewer line located in the parking lot
of the Four Winds Shopping Center behind the ETSS. Pursuant to the
information provided by Mr. Eugenio de Arce of EDACO and Mr. Daniel
Bayard, liquids from the oil/water separator were not discharged
through this connection as the pipe was immediately eliminated and
capped by EDACO.
The oil and water separator is designed, constructed and
operated to prevent the escape or release of the substances which
are stored therein. 
According to information provided by Mr.
Daniel Bayard, there has never been an overflow of liquids at the
oil/water separator. The oil from the separator was transferred
manually into a used oil storage tank located at the premises and
the water was also transferred manually and discharged into the
sanitary line.
REQUEST NO. 9
If the answer to Question 8 above is yes, has there ever been
such a discharge or release? If so, please explain all the details
surrounding such a release and submit any related documentation,
including analysis. 
If a document is not available, please
describe the document and explain why it cannot be provided.
RESPONSE NO. 9
To the best of our knowledge and pursuant to the information
provided by Mr. Daniel Bayard and Mr. Eugenio de Arce from EDACO,
none.
RESPONSE NO. 10
By what means could hazardous substances such as PCE and TCE
enter an oil and water separator at the ESSO facility? Please be
specific, and explain all possible means.
TUT 
OO:3 2485
GOLDMAN ANTONETTI FERRAIUOLI <fe AXTMAYBR
-7-
RE8PON8E HO. 10
ESSO has no specific knowledge on the means by which PCE and
TCE could have entered the oil and water separator at the ETSS.
REQUEST MO. 11
Does, or did, the facility conduct periodic sampling to deter-
mine whether hazardous substances have entered the oil and water
separators? 
If so, how often, and on what occasions. 
Please
attach any such analysis.
RESPONSE NO. 11
ESSO has not sampled periodically the oil and water separator
to determine whether hazardous substances have entered such unit.
REQUEST NO. 12
Have the oil and water separators been periodically cleaned
out or emptied, either completely or partially? If so, how often
and on what occasions.
RESPONSE MO. 12
The oil and water separator was cleaned and emptied by Mr.
Daniel Bayard almost on a daily basis, pursuant to the procedure
referred to in Response No. 8.
REQUEST MO. 13
If the answer to Question 12, above is yes, please explain how
the removed liquids and/or sludges are handled and disposed of?
Please include any sampling procedures and relevant documentation
such as analysis, and manifests. If a document is not available,
please describe the document and explain why it cannot be provided.
RESPONSE NO. 13
Refer to Responses Nos. 6 and 8. Esso has no document in its
possession which relates to this question.
REQUEST NO. 14
Were, or are, any products (including solvents containing 1,
1,1, trichloroethane, TCE, DCE, PCE and MEK) ever used, stored,
generated, disposed or otherwise handled at the facility? If so,
identify these products, and explain how were they used, stored
2486
GOLDMAN ANTONBTTI FERRAIUOLJ <fe AXTMAYER
-8-
and/or disposed of? Please provide any related documents, if a
document is not available, please describe the document and explain
why it cannot be provided.
RESPONSE MO. 14
Not to our knowledge. Refer to Response No. 1.
Pursuant to the instructions included in EPA's Request for
Information, nor have attached to these responses a "Certification
of Answers to Request for Information" duly signed by Ms. Ana
Gloria Ramos, Esso's Safety, Industrial Hygiene and Environmental
Protection Advisor. Should you have any further question or need
any information regarding the matters referred to in these
responses, do not hesitate to contact us.
Cordially yours,
Francis Torres
Enclosures
cc 
Amy Chester, Esq.
Jose L. Blanco
Ana Gloria Ramos
Otto Bustelo, Esq.
Jose Cepeda-Rodrlguez, Esq.
OO3 2487
CENTER 
PARKIN6
I1
-- —— ___i_:
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CERTIFICATION OF ANSWERS TO REQUEST FOR INFORMATION
Commonwealth of Puerto Rico
City of San Juan_________
I certify under penalty of law that I have personally examined
and am familiar with the information submitted in this document
(response to EPA Request for Information) and all documents
submitted herewith, and that based on my inquiry of those
individuals immediately responsible for obtaining the
information, I believe that the submitted information is true,
accurate, and complete, and that all documents submitted herewith
are complete and authentic unless otherwise indicated. I am
aware that there are significant penalties for submitting false
information, including the possibility of fine and imprisonment.
SIGNATURE
Ana Gloria Ramos
NAME (Print or Type)
Safety, Industrial Hygiene and
Environmental Protection Advisor
JOB TITLE
NOTARY PUBLIC
Sworn to before me this 29th
' 
of April 
.
0
rCENTC J. ANTONETTI
x._x<OBERTO MONTALVO
JORGE L. MARTI'NEZ
ALVARO C.CIFUENTES
LUIS r. ANTONETTI
RICARDO MUfilZ
LEONARDO ANORAOE
JOSE A.CEPEDA-ROORI'GUEZ
EUGENIO C. ROMERO
LUIS D. ORTIZ ABREU
COUNSEL
MAX GOLDMAN
LAW OFFICES
GOLDMAN & ANTONETTI
INSURANCE CENTER
7OI PONCE DE LEON AVENUE
POST OFFICE BOX 13486
SANTUHCE, PUEHTO Rico OO0O8-3486
TELEPHONE: (8O9) 721-3424
CABLE: RIGOSA
TELEX: RCA-azszaao*
TELECOPIER: 000-721-1706
FANNY AUZ-PATINO
CARLOS A. ROORI'GUEZ-VIOAL
CORALINA RIVERA
THELMA RIVERA-LABOY
JORGE SEGUROLA
RAM6N L.VELASCO
FRANCIS TORRES-FERN/JNDEZ
KARIN G. OIAZ-TORO
FRANCISCO J. CARCIA
EOGAROO COL6N-ARRARAS
josf. M. LORIE'-VELASCO
MANUEL A. SILVA-ROSAS
Ref. 092.007
September 22, 1988
Caroline Kwan
Site Compliance Branch
U.S. Environmental Protection Agency
Region II - Room 737
Federal Plaza
New York, N.Y. 10278
Re: Request for Information Under 42 USC
9604, 42 USC 6927, 42, USC 6991(d)
Tutu Esso Car Care Center, US Virgin Islands
Dear Ms. Kwan:
This confirms our telephone conversation of September 22,
1988 regarding the Material Safety Data Sheet (MSDS) of an engine
degreaser which was recently provided to us by Mr. Thomas
Gutshall, Operation Manager for the Esso Tutu Car Care Center.
The enclosed MSDS was provided to us in response to our
request to Mr. Daniel Bayard, the service station operator, to
ascertain whether other degreasers, having different constituents
than the one already reported to EPA in response to the above
referred Request for Information, have been used over the years
in the Esso Tutu Service Station.
The attached MSDS is provided the supplement the response
provided by Esso to the Request for Information of reference.
Should you have any questions
document do' not hesitate to contact us.
regarding the attached
Cordially yours,
Attachment
cc: Eng. Ana G.
Jose Font
Greg Rhymer
r
,
'
* 
' *
Francis Torres-Fernandez
Ramos
TUT 003 249O
SENT BYiEZCH MEMPHIS TRAFFIC 
- 9-19-88 
11:4CWM ;
, ' •' ••'-* " »
i UMIM &IGCI rim
9017578443-
CCITT Q3;«
SECTION I — PRODUCT IDENTIFICATION
MASTER CHEMICAL CORPORATION
1900 EXETER ROAD
GERMANTOWN, TM - 38138
901-755-5555 • • • ' • • ' "
PRODUCT TRADE NAME Oft BRAND NAME EHm.MASTBt EMCMI MCREASER
^^k 
. MM <• * * 
* 
. 
. ^ _ * 
. t
OTHER PRODUCT DESCRIPTION OR IDENTIFICATION ' 
__ 
PETimLHJX HYDROCARBOH FTUKIION
SECTION II 
— IAZAROOyi INORgQIgNTS
INGREDIENT CHEMICAL NAME
TYPE OP
HAZARD*®
APPROXMATc
WEIGHT %
-TLV
VALUE
Omen iOAK/J * T
INFORMATION
NO. 1 FUEL OIL ( KEROSENE )
yHBOSTIOl
N/A
EYE/SKIH IRRIT
NOW-IOMIC SURFACTANT
KYE/SRIK
2.93
K/A
SECTION III 
— PHYSICAL DATA
BOtUNQ POINT
A 101.3 kPa fTAOmtn Hat
U Not
176
Ns.
U Not Appfc«W»
WPOR
MAXIMUM
VOLATU8
Yvs. AIR • 1
130 orirt
2 Hetvfar
An
9
1.0
EVAPORATION RATE
ilnth
i7 %
(Wtbht
MOOONJZED WATER
»10*C/50*PV
- 1-10%
B 
> 10%
w
%byWt.
APPEARANCE AND OOOR
NAZI » TKAM
WIT
•nd
of tpriy
y rMltfiM)
tV »- 
FIRE AND EXPLOSION -HAZARD DATA
NotAopiotblt 
FlAMMABLEUMfTS IN AIR
(IW «R ___ 
(Vol. % A iO«C/68 *n
Not A
L6L-UEL *
E2$T1NGUISHING MEDIA: U Not Appfieibl* (w« Mttium tMk>w B15*C/1,600*F)
Water Fog 
Jp stmdtrd FOMI 
D SpwW AtoohoVStaM* Fo«n
DrvChMnleal 
L
SPECIAL RRERGHTINQ PROCEDURES: KMP conttfnm oool. UM «qulpfMnt or ahWolna rtquirtd to protect
p«nonn«i •oain«t ourMtng. njpturtng, or venting oontaton.
UNUSUAL RRE AND EXPLOSION HAZARDS: At •(•vttod'twnptnAjrM (ovw S4*O/130"P). oonMncni may v«nt,
ruptura, or burst. Alto M« Stctton VI.
*• AdcfftKxwl Note* or Ccmmtnfc from Motion* *bov*:
(->03 
2491
5!, T E' r : ET 01 l MEfiPh IS TRnFF 1C 
; 9- i 9-88 
11: 41PM ;
9317578441^
63; 8 3
^fev'-.si^-:.-:->'^S^:::.-1
SECTIONWfrU.>H
VALUE fTU/1:
HAZARD DATA •••*
_ TOVERlXPOSURE: ETJET IERITATIOH SXUfsDRYZNd, DCFATTIHC, IRRITATION, DEKXATITIS~
INHALATION! AKCSTKESIA, HEADACHE,' DIZZINESS, NAUSEA, UPPER RESPIRATORY IRRITATION.
ANO RRST AIO PROCEDURES: M unconscious, ramow vtatim to (nth «* «na c»fl • physician, it
oott«n in ayM, fiuah knmatfatofy with largo amounts of water.
JJ contains eartfial Mmifagf'—if unconsctou* from InhalaUon, do not gtv« aoV«oalo-typ« drugs. Q_ _____
SECTION VI — REACTIVITY DATA
CHEMICAL STABUJTY; B STABLE 
U UNSTABLE • OONOmONS TOAVOtt):
tNCOMPATlBIUTY (Materials to avoid!: LJ Nont wfth oommon matarte
HA2AROOOS OeopMPOSinON PROOyCTS (FRXR t^rrtr^.
13 Cart>on Morwdd« 
Q PfK»Q«nt 
D HyoYxjfluortg AoW
D Hydrochloric Acid
HAZARDOUS POLYMERIZATION: B Wl not occur
May Occur • OondWona to avoM:
ON VIII .- 
LEAK AND OISPOSAL PROCEDURES
STEPS TO 86.TAKEN IF
Ramova tenrtten sourcas
AINERS ARE LEAKING OR LARGE AMOUNTSAR8 RCtfiASEO: td AvoW DT««th-
Q Avoid sWn ooniact with li«iid. 0 
_______. ______
WASTE DISPOSAL METHOD: Do not punotura or Indnwata contain**. Givs •mpty. laaldng. or fwfl gontaln«rs to
a dtsposst service «omppod to aafsly handto and dtePOM of prsssurttad oontalrKfi.
SECTION Wit — SPECIAL PROTECTION INFORMATION
RESPIRATORY PROTECTION (SpMtfy typo): U Not AppCc»W«.
VENTILATION
LOCAL EXHAUST (Hoods, Fan*, oto.}: O Not
vJno*a funny tw-~ ^ 
—
U*Not ftoqulrad
Should ba on white scravtnp. (o ramoy» aolvant vapor,
Not AppRcabte
PROTECTIVE GLOVES: (2 Not
'
U Vinyl 
D Pdyatnylana
wMssoravtvi.
PROTECTJON: G Not App**cmWo
Waar QoQQlM whte apraylng.
PROTECTIVE EQUH
Oo not waar dotnino toskad by spray.
i •
S TO B6 TAKEN
O
IN HANDLING AND ST
— SPECIAL PRECAUTIONS
ORAQE:
D
DO not atom
Mfnpwaturas oouU
cotrrwr$ riAKKABLt. corrms DMDIR PUSSORE. DO HOT
OKLY
AREAS. AVOID STRAYINC X«0 EYES OR OK
KEEP OUT 0? REACH OP CHILDREN 1 1
> or Commarua (ram sacttons abova:
ZNTCMTZOKAL MISUSE OR USE OP PRODUCT IN A KAMKER OTHER THAN THAT CONSISTENT WITH
LABELING IS A VIOLATION OP FEDERAL LAW.
O03 
2492