EPA - Inipol EAP 22 Tech 10 Bulletin Needs Correcting

February 12, 2003

Dear EPA -

I encourage you to correct the Tech 10 Bulletin on Inipol EAP 22 *

as either there needs to be a major update as of 7-28-89...

the New Inipol EAP 22 originates as of 7-28-89

It is most misleading

to state Inipol EAP 22 is a micro emulsion of nitrogen & phosphorus...

It has only minimal nitrogen and phosphorus...

allowing it to 'technically' be called a fertilizer...

it is more correctly labeled a Surfactant. *

To not disclose in your literature...

what the MSDS even said in 7-28-89...

that it has 10-12% by weight of 2-butoxyethanol

... makes you look bad.

Margaret - Valdez, Alaska

Note: The French Inipol patent was purchased by Exxon;

then experimented with by adding other chemicals: Inipol EAP 13 was experimental;

so was Inipol EAP 22: In essence this French Inipol (now Exxon-owned) had 22 chemicals added, creating a never before used

... until 7-28-89

What was the original patent?

What were the 22 chemicals?

Art Veteri's comments on August 3, 1989

Make it clear

he thought the French Inipol was what was being used for 'bioremediation'

on the beaches of Prince William Sound

(Art Veteri was head of DEC Research & Development in Alaska then)

It's not much of a fertilizer considering it has a C:N:P ratio of 62:5:1 *