EPA-AA-TEB-511-81-19
EPA Evaluation of BG Supercharge Gasoline  Treatment
      Under Section 511 of the Motor Vehicle
         Information and Cost Savings Act
                        by


                  John C.  Shelton
                  September,  1981
            Test and Evaluation Branch
       Emission Control Technology Division
   Office of Mobile Source Air Pollution Control
       U.S. Environmental Protection Agency

-------
6560-26
                     ENVIRONMENTAL PROTECTION AGENCY
                            [40 CFR Part 610]
                           [FRL
                      FUEL ECONOMY RETROFIT DEVICES
        Announcement of Fuel Economy Gasoline Additive Evaluation




                 for "BG Supercharge Gasoline Treatment"
AGENCY;   Environmental Protection Agency (EPA).
ACTION;   Notice of Fuel Economy Retrofit Device Evaluation.
SUMMARY:   This document announces  the conclusions  of  the EPA  evaluation




          of  "BG  Supercharge  Gasoline  Treatment"  under  provisions   of




          Section 511  of  the Motor Vehicle  Information  and Cost  Savings.




          Act.

-------
BACKGROUND  INFORMATION:    Section  511(b)(l)  and  Section  511(c)  of  the




Motor  Vehicle  Information  and  Cost  Savings  Act  (15  U.S.C.  2011(b))




requires that:









(b)(l)   "Upon application of  any  manufacturer of  a  retrofit  device  (or




prototype  thereof),  upon  the request  of  the Federal  Trade  Commission




pursuant to subsection (a),  or upon his own motion, the  EPA  Administrator




shall evaluate, in accordance with rules  prescribed under  subsection  (d),




any  retrofit  device  to  determine  whether the  retrofit device  increases




fuel economy  and  to  determine whether  the  representations (if any)  made




with respect to such  retrofit devices are  accurate."








(c)   "The   EPA  Administrator  shall  publish  in  the  Federal  Register  a




summary  of  the  results  of all  tests  conducted  under  this  section,




together with the EPA Administrator's conclusions as to  -








          (1) the effect of any retrofit device on fuel  economy;








          (2) the  effect  of  any   such  device  on   emissions  of   air




              pollutants; and








          (3) any other  information which the Administrator determines  to




              be relevant in evaluating such device."








    EPA   published   final  regulations   establishing    procedures    for




conducting  fuel economy retrofit device evaluations  on March  23,  1979




[44 FR 17946].

-------
ORIGIN OF REQUEST FOR EVALUATION:   On  March 31, 1981,  the  EPA  received a




request  from  Glasgow Industrial  Distributing  for  evaluation  of a  fuel




saving  gasoline  additive   termed   "EG  Supercharge  Gasoline  Treatment".




This additive is claimed to save fuel and reduce emissions.









Availability of  Evaluation Report;   An evaluation  has been made  and  the




results  are described  completely in a  report entitled:   "EPA  Evaluation




of  BG Supercharge  Gasoline  Treatment  Under  Section  511  of  the  Motor




Vehicle   Information    and    Cost   Savings    Act,"    report    number




EPA-AA-TEB-511-81-19 consisting of 32 pages including all attachments.









Copies  of  this  report may   be  obtained  from  the  National  Technical




Information Service  by  using   the above  report  number.   Address  requests




to:









          National Technical Information Service




          U.S. Department of Commerce




          Springfield,  VA  22161




          Phone: Commercial  (703) 487-4650




                 FTS 737-4650









Summary of Evaluation









EPA  fully considered all of  the  information  submitted by  the  applicant.




Actual   test  data  was  not   submitted  with   this   application.    Sales




literature was  supplied which claimed improvements  from  0.8% to  11.5%




improvements in  fuel economy.   EPA  experience with similar  type  gasoline




additives does not support these claims.

-------
Based  on  this information  and  EPA's experience  with similar  additives,

there  is no  technical  basis to support any  claims  for an  improvement  in

fuel  economy or  reduction  in  exhaust  emissions due  to the  use of  "BG

Supercharge Gasoline Treatment".



FOR  FURTHER  INFORMATION  CONTACT;    Merrill  W.   Korth,  Emission  Control

Technology  Division,   Office   of  Mobile  Source  Air  Pollution  Control,

Environmental Protection Agency, 2565 Plymouth  Road, Ann Arbor,  Michigan

48105, (313) 668-4299.   .
Date                                   Kathleen Bennett
                                       Assistant Administrator
                                       for Ai\r, Noise,  and Radiation
                                             \

-------
EPA Evaluation of  BG  Supercharge Gasoline Treatment Under Section 511 of
the Motor Vehicle Information and Cost Savings Act

The following is a summary of the information  on  the additive as  supplied
by the Applicant and the resulting EPA analysis and conclusions.

1.  Marketing Identification of the  Device;

    BG Supercharge Gasoline Treatment

2.  Inventor of the Device and Patents;

    A. Inventor

       B. G. Products, Inc.
       P.O. Box 11264
       Wichita, Kansas  67211

    B. Patent
       No patent

3.  Manufacturer of the Device;

    B. G. Products, Inc.
    P.O. Box 11264
    Wichita, Kansas  67211

4.  Manufacturing Organization Principals;

    Don H. Walton - President
    Edward J. Bash - Vice President
    0. J. Connell - Vice President

5.  Marketing Organization in U.S. making Application;

    Glasgow Industrial  Distributing
    Distributor BG Products, Inc.
    Fort Peck Route
    Glasgow, Montana  59230

6.  Applying Organization Principals;

    Martin R. Connell, D.V.M
    Contact:  Dennis L. Garsjo, Sales  Manager

7.  Description of Device;

    A. Purpose of the Device (as supplied by Applicant);

       "Improve fuel economy on all motor vehicles."

-------
    B. Theory of Operation (as supplied by Applicant);

       VBG Supercharge is  a  superior gasoline treatment which cleans  the
       entire fuel system of gasoline engines.  BG  Supercharge  chemically
       removes  performance-robbing  deposits  from  engines  without  the
       expense of an overhaul."

8. Applicability of the Device (as supplied by Applicant);

    "Can be used in any gasoline engine."

9.  Costs (as supplied by Applicant);

    Not supplied.

10. Device Installation  - Tools  and Expertise Required  (as supplied  by
    Applicant);

    "BG Supercharge Gasoline Treatment is added to gasoline  at a  ratio  of
    one part BG Supercharge to four hundred parts  gasoline."

    "For quick clean-up in individual  vehicle tanks, add on  the  basis  of
    one  12  ounce  can of  BG  SUPERCHAEGEtm  for  each  10  gallons  to  20
    gallons of gasoline."

11. Device Operation (as supplied by Applicant);

    "Same as number 10."

12. Maintenance (claimed);

    "Same as number 10."

13. Effects on Vehicle Emissions (non-regulated) (claimed);

    "Use of  BG  Supercharge helps control  engine  deposits  and can  result
    in  reduced  exhaust  emissions  in  older  cars  and  can  prevent the
    formation of these deposits in new cars."

14. Effects on Vehicle Safety (claimed);

    "Does not alter vehicle safety."

15. Test Results (Regulated  Emissions  and  Fuel  Economy)  (submitted  by
    Applicant);

    The applicant  stated  "A Fuel Economy  Improvement  Test  was conducted
    with nine cars each  of four different U.S. models.  These thirty-six
    were  driven  for  20,000  miles  with  a  commercial gasoline   which
    contained a carburetor detergent.  These automobiles were then  driven
    an  additional  10,000  miles  with  the  additive   contained   in   BG
    SUPEKCHARGEtm  mixed  with   the   gasoline.    The  miles  per   gallon
    improvement  varied  from  0.8%  to  11.5%,  with  the  dirtiest  engines
    showing  the greatest  improvement.   The  average  miles per  gallon

-------
    improvement for all  thirty-six cars was  3.6%;  further proof that  BG
    SUPERCHARGEtm helps  improve engine  performance and  removes mileage
    reducing deposits."   The applicant  did  not  submit  the  actual  test
    data to support the above claims.

16. Analysis

    A. Description of  the Additive;

       This product appears to be a detergent  type  gasoline additive.

    B. Applicability of the Additive;

       It can be used  in all gasoline  engines.

    C. Costs:

       Not supplied.

    D. Additive Installation - Tools and Expertise  Required;

       The additive is added  to gasoline at a ratio of  one part in  four
       hundred  parts  of   gasoline.    The  method  of   installation   in
       individual vehicle tanks is  reasonable.

    E. Effects on Vehicle Emissions (non-regulated);

       The effects  on vehicle  emissions  is unknown.   The applicant did
       not supply any test data.

    F. Effects on Vehicle Safety;

       The addition of  this additive  to  the  vehicles  fuel supply  should
       not affect the  vehicle's safety.

    G. Test Results Supplied by Applicant;

       The applicant did not  submit any test  data  in accordance with the
       Federal  Test Procedure  or  the  Highway Fuel  Economy  Test.  The
       requirement for test data following  these procedures is stated  in
       the application test policy documents  that  EPA  sends to  potential

-------
       applicants*.  The  applicant  stated in  his  original application
       that he would complete the testing upon request.  He  later decided
       riot to conduct this testing.

17. Conclusions

    EPA  fully  considered  all  of  the  information  submitted  by  the
    applicant in his application.  Based on the available information and
    EPA's previous  experience  with similar fuel  additives,  there  is no
    technical  basis  to support  any  claims  for  an improvement  in  fuel
    economy.
 *  From EPA 511 Application test  policy documents:

    Test Results (Regulated Emissions  and Fuel  Economy);
    Provide all test information which is available on the effects of the
    device on vehicle emissions and  fuel economy.

    The Federal Test Procedure (40 CFR Part 86) is the only test which is
    recognized  by  the  U.S.  Environmental Protection  Agency  for  the
    evaluation of vehicle  emissions.  The  Federal Test Procedure and the
    Highway Fuel Economy Test  (40 CFR Part  600) are  the  only tests which
    are normally  recognized  by the U.S. EPA for  evaluating vehicle fuel
    economy.  Data  which  have  been  collected  in accordance  with other
    standardized  fuel  economy measuring  procedures  (e.g.  Society  of
    Automotive  Engineers)  are  acceptable  as  supplemental  data  to  the
    Federal Test Procedure and Highway Fuel Economy Test Data and will be
    used, if provided, in  the preliminary evaluation of the device.  Data
    are  required   from  the  test  vehicle(s) in  both  baseline  (all
    parameters  set  to manufacturer's  specifications)  and  modified forms
    (with device installed).

-------
                           List of Attachments



Attachment A       Letter, EPA to Mr.  Garsjo,  of Glasgow,  March  9,  1981.




Attachemnt B       511 application from Mr.  Garsjo to EPA, March 31,  1981.




Attachment C       Letter, EPA to Mr.  Garsjo,  June 30, 1981.




Attachment D       Letter, EPA to Mr.  Garsjo,  August 19,  1981.




Attachment E       Letter, Mr. Garsjo  to EPA,  August 24,  1981.




Attachment F       Letter, EPA to Mr.  Garsjo,  September 3,  1981.

-------
                                                           Attachment A
March 9, 1931
Mr. Deimis Cars jo
Claspo
Fort t'eck Route
Glosrrow, >?T  59230

Dear I'r. Gars jo:

This  letter  is  in  response  to,  your inquiry  of  3/6/31,  rejrarc'itir*  an I?A
evaluation  of  EG Products.   The Environmental Protection Agency Is charged  hy
Concessional  mandate  to evaluate  fuel economy  and emission control devices.
While  the  EPA  does  not  actually "approve"  such  devices,  it does  conduct
evaluations  for the purpose  of increasing  the  corrnon knowledge  in  the  area.
For this reason, the outcome of any testing  by EPA becomes public information.
It  is  this information  which may be cltc-d although no claims can be  made that
any EPA findings constitute "approval" of the device or systen.

Enclosed  with this  letter  is a packet  of  materials  which  you will need  to
npply  for an  EPA  evaluation of your  device.   This packet  consists  of  1)  i;rx
application  forrat,  2)  a  document' entitled  "E?A Retrofit and Emission Control
Device  Evaluation   Test Policy"   and  3)  a  copy  of   the applicable  Federal
Regulations.

In  order  for the EPA  to conduct an evaluation of  your device, ve rust  have  an
application.   Cnce  you have reviewed  all  the  documents  in the  packet, you
should  prepare  an  application in  accordance  with   the ruiclullnes  of t!-e-
application  format.   A  critical part of the application is the substantiating
test data.   The  required test results vrill have  to be  obtained at a laboratory
of  your  choice.   Such  tee tin?,- would be  conducted  at  your expense.   A  lir.t  of
laboratories w.ich  are  known  to  have the equipment and  personnel  to  perron-
acceptable  tests has  been  included in the enclosed packet.  If you desire,  vo
can assist  in  the  cicvolor-rent of a satisfactory  test plan.

Once '.•;« receive  your application,  rt will be reviewed  to determine if it  r.-e.et;-.
the  requircr.crts  Hi? toe! in  the fornat.   If r-o,  you xd.ll be  ad vised  of ov:r
decision  x.-i.-^ther or not  TT'-\ x;ill  p«rforn any  conf innntory  tontin;;.   Any L?,\
tu^tir.:.;,  \rlll  be \ urfoiT or   at  no  cot t  to  you,  and  ycu rill be  j-.ivon t-K-
op,-:t t':' i'.~

-------
Tinteun  Test  Pequirerents  -  Although different  typos  of  devices  ray
require a  r..orc- conplex  teat  plan,  the rinirun  tre  require  involves  rv-o
vehicles and tvo tcsjt Sii'nier.ccs run  in duplicate.  The vehicles ehouiu '^
selected fron  those  listed in  Table 1; if  possible.  Fach vehicle IE to
be  set  to  tunuf actur^r's  tune-up  specifications  for the baseline tiii>cs.

Tlie  tests are conducted in a  ''back-to-back" rvinner, or.cc with the vehicle
in bast-line condition arui  arr.ia with the device installed with no vehicle
adjustrent's  h^Ci-cart  tctitc.  If  installation of  ths device alrro  involves
sore adjustments,  «?.£.  tteinj1. »  fuel-air mixture,  choke  or   Idle  speed,
another  test sequence  with  only these  adjutitr.;cots should   be  in^t.-rr.::::.
bun. ecu tnt  fir^t  and !:ir;t.   Also  as a pinirr.n,  tbu test  Gfcrucnco .<-.: all
.consist of  a hot-start T.A-4  portion  (bnao  1 and 2)  of the  Federal Ie2t
Procedure (IT?) and  a highway  Fuel  Econor-y  Test  (I:F!;T).  The cletailr of
these  tests are   contained   in  the  enclosed  packet.   Although only  a
hot-r.tart  FTP  is  required   to uininize  th.e  costs  to  you,  you  ari ether ci >:.
 test 'results  \rLtn your device  si^ould be  cousidcfeil enccurorin.^.   T/.cre.
 valtujs have  been  cliu£k?n  to  asr.ura  both  of us that  a rtnl  dif ferer.ct- ir.
 fuel ccoucr.y  f.:;ii'.ti.;  and  that V'"1  are  v.ot sec in;;;  only  tt'-o variiihiliiy i;.
 the results.   TJ'u r-il:lc  below  r-resents  the li-iniv.^;-^  r.u-bcr of  cnn-  t!..:t.
 neinl  to   bo   tcstiri   for   vnryi- ;  dt^-rees   of  fuol  ccovic>.:'V  iv provi :;••.• tit.
 asfMiriu';   n typical  r.r ount of  varlcbLlity  in fuel  i>co:uw.;y  re a sure; o:>c .

-------
     For  a rr.iiiirM:n  test plan *r> ich t.-us conducted on  a fleet of  tvo  car;-:,  the
     aver a re  improver-eat  shculO. be at  least j';:.'.   If  at leu:;t an  fiTi difference
     in  average  fu«l  ecor:or.;y  c:.n  be   shovu,   then we viould  bo  able  to  :-;ay
     stastic.illy  at the 80". confidence  level that  there is a real  irprovercnt.

     Similarly,  wu would  e;-rect a  r.inLpun of  5% improvement for  a fleet of 5
     vehicles.   Test  results  t.hich display a significant increase, in •emission
     levels should >:e reason,  for cancvrn.

           !iinir.un Fuel Economy  Ir.iprove-ents verrus  Size .of Test Fleet

           rieet  n~e                    Average  Tt^rnvepent Fe-miroci
                2                                     3/i
                3                                     17,
                4                                     6Z
                5                                     5%
               10                                     4%
               25                                     2%

Cncc we receive your application,  it  will be reviewed to dete.rrd.ne if. it r.cetr?
the requirerrents listed  in the  format.  If  your application is  not  couplets,
we  will ask  you  to  submit  further  infornation  or  data.   After any  r.rissin.?.
infoiTiation has been eubnittjx'. ,  your  application will be reconsidered ard once
it meets  our  racjuirer.ents, you  will  be acSvised of  our decision whether or. not
EPA vill  perform any confirmatory  testing.  Any I?A  testing will  be  perfonr.ed
at no  coat  to you  and you  will be  &lven the  opportunity  to  concur  with  our
test  plan.   Once  this  testing  is  complete,  an  evaluation  report will  be
written.   If  no further testing  is  required, the report will be written solely
on the basis  of the test data eubr.itted and our en^ineeriT:.^ analysis.
Despite  the current  backlog and  increasing nuaber  of inquiries rcrardin^. fuel
economy  device evaluations, the  UFA  intends to process your application in n.s
expeditious a winner  as possible.   Ue have established a poal of  twelve weak:;
fron  the receipt  of  a complete application to the  announcement of  our report.
The attainment of  this objective requires very  precise  scheduling and  we one
depending  on the  applicant to  respond promptly  to any  questions  or  to roihr-.it
any requested data.   Failure to  respond in a  tir.ely  manner will  unduly delay
the  process.   In  the  extreme care,  ve nay  consider  lack  of response, .-as  s.
withdrawal  of the application.
I hope  the  ii;f on.>atian /ibova  and that contained  In  the enclosed tlo citric at s '.-/ill
aid  you in the  preparation of  an acceptable application ''or an I.PA  t:V^1uati:>r.
of  your iit.>.v i c i.-.   I  •;ill br.  yoi-.r ci>r.t:jct  '.ri th '".:-'t\  liuriiv. t M.R procoss  -ii-.d c:-y
sub.sctiutnt   *.TA   c-valuation.    J'y  n.'lurciss*  ir.   r.?.\,   ?'otor  Vehicle  ;."i.:ir;...i;'.in
I.obor;'. tory,  2 .".•'/:'  T:ly: :>uta  l.or'.4,  Aon Arhot,  "ichiran,  ••'»'.-10 5.   T!.t:  tcl c ; I'.^i.c
nia:her  is  (°.13)   (-•(• .j-A?'/'.   llcciie  contact  1:0 if  you i-avo  any quc.Pt:ri::'. or
require, any  fisrtl.oi- i^Jr'ur atior-.

nine i'rely.
:Vrrlll \r.  \i:rtl.
':.-.:vi^-i" ;.'.•.••.]»:•=: ioi; Ci>'.>ri-'.i.i:.-tor
Vt-...U .M'ui  1 v.;. 1 :i.. t Ji-a "r.Tiit:!;

-------
    March 31,  1981
    EPA
    Motor Vehicle Emission  Laboratory
    2565 Plymouth Road
    Ann Arbor,  Michigan   48105
    Attn;  Merrill W.  Korth
            Device Evaluation Coordinator
            Test & Evaluation Branch
    Dear Mr.  Korth,

    Enclosed  is my number  one Preliminary Application.

    Please let me know what the  next step is.

    Thank you

    .Sincerely,
    Dennis L.  Garsjo,  Sales Manager
    Glasgow  Industrial Distributing
    Distributor, BG  Products, Inc.
    Fort Peck  Route
    Glasgow, MT  59230
    DLG/dra

    Encl
Fort Peck Route
Glasgow. Montana 5923O
(406)228-9313
BRANCHES  Glasgow Veterinary Supply
          P.O. Box 2366  Hwy. 87 North
          Great Fob Montana S94O3
          (4O6) 727O6U
Qosgo of Miles Oty
Industrial Park
P.O. Box 67
Mle* City. Montana 593O1
(406)232-6868
Gtasgo of Belgrade
Route 2. Box 469A
JackraDQit lane
Belgrade. Montana 59714
(4O6) 38M742
Gtosgo or Kalispofl
Box 1499
3239 Hwy. 93 S
KaBspel Montana 5f9Ol
(4O6) 755-8555

-------
 1.  Application for Evaluation of a Fuel  Economy  Retrofit Device
     Under Section 511  of the Motor Vehicle Information and Cost
     Savings Act

 2.  Marketing Identification of the Device:
        BG Extreme Pressure Concentrate
        BG Motor Oil Additive
        BG Supercharge  Gasoline Treatment

 3.  Identification of  Inventor and/or Patent Protection:
      a-BG Products, Inc.
        P.O. Box 11264
        Witchita, Kansas  67211

      b-No Patent - Product information attachment
        1, 2, & 3 enclosed

 4.  Identification of  Device Manufacturers:
        BG Products, Inc.
        P.O. Box 11264
        Witchita, Kansas  67211

 5.  Identification of  Manufacturing Organization's  Principals:
        Don H. Walton,  President
        Edward J. Bash, Vice President
        0. J. Connell,  Vice President

 6.  Identification of  Organization Making Application:
        Glasgow Industrial Distributing
        Distributor BG  Products, Inc.
        Fort Peck Route
        Glasgow, Montana 59230

 7.  Identification of  Applying Organization's  Principals:
        Martin R. Connell, D.V.M.
        Contact:  Dennis L. Garsjo, Sales  Manager

 8.  Description of Device:
      a-Improve fuel economy on all motor  vehicles
      b-Exhibit 1, 2, & 3
      c-Exhibit 1, 2, & 3

 9.  Applicability of the Device:
        Can be used in  any gasoline engine and  is  compatible
        with all petroleum based oils  and  gear  lubricants.
        Products are marketed in guantities from six ounces
        to fifty three  gallon containers.

10.  Device Installation:
        BG Extreme Pressure Concentrate is added at  regular
        service intervals  at a ratio of one part BG  E.P.C.
        to eight parts  gear lubricant.
        BG Motor Oil Additive is added at  each  oil change  at
        a ratio of one  part BG M.O.A.  to fifteen parts  motor
        oil.

-------
10.   Device Installation:  (continued)
        BG Supercharge Gasoline Treatment is added to
        gasoline at a ratio of one part BG Supercharge
        to four hundred parts gasoline.

11.   Device Operation:
        Same as number 10

12.   Device Maintenance:
        Same as number 10

13.   Effects on Vehicle Emissions (non-regulated):
        Exhibits 4, 5, 6,  & 7

14.   Effects on Vehicle Safety:
        Does not alter vehicle safety

15.   Test Results (Regulated Emissions and Fuel  Economy):
        To be completed upon request

-------
                                             GASOLINE  TREATC3EHT
                                        BG SUPERCHARGE™ is a superior gasoline treatment which cleans
                                        the entire fuel system  of gasoline engines.  Use of  BG SUPER-
                                        CHARGE- helps control engine deposits and can result in reduced
                                        exhaust emissions in older cars and can prevent the formation of
                                        these deposits in new cars.
                                        Harmful engine deposits of carbon, gum, varnish,  and acids are
                                        problems inherent to internal combustion engines. Because these
                                        deposit formations  affect the carburetor, intake manifold, plugs,
                                        valves, pistons, and PCV valve, the engine is unable to reach peak
                                        performance.
                                        Most of the areas affected by these deposits are inaccessible to a
                                        mechanic  without dismantling the engine. BG SUPERCHARGE®
                                        chemically removes these performance robbing deposits from your
                                        engine without the  expense of an overhaul.
                                        BG SUPERCHARGED working in the fuel system and throughout the
                                        entire engine has proven superiority in carburetor clean-up and in
                                        reduced engine deposits. Engine manufacturer's severe sequence
                                        test results  show BG SUPERCHARGE® improves engine perfor-
                                        mance even when the engine is lubricated with high quality oil.
                                        A Fuel Economy Improvement Test was conducted with nine cars
                                        each of four different U.S. models. These thirty-six cars were driven
                                        for 20,000 miles with a commercial gasoline which  contained a
                                        carburetor detergent. These automobiles were then driven an addi-
                                        tional  10\000 miles  with the additive contained in  BG SUPER-
                                        CHARGED mixed with the gasoline. The miles per gallon improve-
                                        ment varied  from 0.8% to 11.5%, with the dirtiest engines showing
                                        the greatest improvement. The average miles per gallon improve-
                                        ment for all  thirty-six cars was 3.6%; further proof that BG SUPER-
                                        CHARGED helps improve engine performance and removes mileage
                                        reducing deposits.
                                        BG SUPERCHARGED cleans fuel injectors and nozzles and restores
                                        injector spray pattern, assuring proper combustion  and fuel
                                        economy.
                                        BG SUPERCHARGED—
                                        • Cleans emission control devices and keeps  them  clean.
                                        • Cleans carburetor,  intake valves, and valve stems.
                                        • Keeps fuel tank and carburetor free of gums and  resins.
                                        • Controls deposits on spark plugs,  pistons,  valves, lifters,  oil
                                          screens, and other engine parts.
                                        • Is satisfactory for use in engines requiring Non-Leaded Fuel.
                                        • Is recommended  for any type of fuel injection system.
                                        • Non-Corrosive to  all types of metals.
                                        • Non-Injurious to all types of materials used in carburetors and fuel
                                          systems.
                                              NON-HARMFUL TO CATALYTIC  EXHAUST SYSTEMS
                                                         WHEN USED AS DIRECTED
                                                           DIRECTIONS FOR USE
                                        For quick clean-up in individual vehicle tanks, add on the basis of
                                        one 12 ounce can (.355 liter) of BG SUPERCHARGE'" for each 10
                                        gallons (38.85 liters) to 20 gallons (75.71  liters) of gasoline. Con-
                                        tinued use provides best results.
5962
                                                             © 1978 BG Products, Inc. P.O. Box 11264 Wichita, Kansas 67211

-------
                                         PRODUCT
                                                                                                    T.M.
                                          BG EXTREME PRESSURE CONCENTRATE FOR FARM AND INDUSTRY is an
                                          oil soluble, heat stable formula which increases delivered power, in-
                                          creases equipment life and ease of operation, and decreases wear. Even
                                          the smoothest metal finish is pitted and rough looking when viewed under a
                                          microscope. This surface roughness can result in rapid wear and eventual
                                          parts failure. BG EXTREME PRESSURE CONCENTRATE FOR FARM  AND
                                          INDUSTRY contains agents which have the effect of smoothing and sealing
                                          metals under frictional conditions while reducing noise in gears and bear-
                                          ings, smoothing and quieting noisy hydraulic systems and improving shift-
                                          ing and power steering.  BG EXTREME PRESSURE CONCENTRATE  FOR
                                          FARM AND INDUSTRY will aid in reducing frictional heat, conditions seals,
                                          aids in stopping seal leaks, aids in prevention of corrosion and  acid
                                          damage on bearing surfaces, reduces  fuel consumption by increasing
                                          delivered power, and helps lubrication during cold starting conditions.

                                                              DIRECTIONS FOR USE
                                          ALL TYPES OFTRANSMISSIONS, TORQUE CONVERTERS, AND HYDRAULIC
                                          SYSTEMS: Add to lubricant  in the following proportions — Initial Treat-
                                          ment: 2 oz. (0.59 liters) per pint (.473  liters) or pound (453.6 g).  Sub-
                                          sequent Treatment: 1 oz. (.0296 liters) per pint (.473 liters) or pound (453.6
                                          g) every 500 hours and/or when changing lubricant.
                                          DIFFERENTIAL AND FINAL DRIVE: 2 oz. (.059 liters) per pint (.473 liters) or
                                          pound (453.6 g)  every 500 hours and/or when changing lubricant.
                                          CHASSIS: Grease fittings and wheel bearings — mix thoroughly  with
                                          lubricant as follows — 2 oz. (.059 liters) to the pint (.473 liters) or pound
                                          (453.6 g).
                                          BG EXTREME PRESSURE CONCENTRATE  FOR  FARM AND INDUSTRY
                                          SHOWS EXCELLENT COMPATIBILITY WITH PETROLEUM BASE OILS  AND
                                          WILL NOT SETTLE OUT  OF OILS OR  GREASES WHEN THOROUGHLY
                                          BLENDED.
                                          CAUTION: MAY CAUSE EYE IRRITATION. AVOID EYE CONTACT. IF PROD-
                                          UCT GETS IN EYES, FLUSH EYES WITH WATER FOR AT LEAST 15 MINUTES
                                          AND GET MEDICAL ATTENTION AT ONCE.
                                                         KEEP OUT OF REACH OF  CHILDREN
                                                                SPECIFICATIONS
                                          Viscosity  @210  F., SUS                              120-130
                                          Viscosity  @100  F., SUS                              800-1100
                                          Density                                           0.929
                                          Pounds Per Gallon (U.S. Liquid)                       7.735
                                          Color                                             Dark Amber
                                          Flash Point, F.,  Minimum                             350
                                          Pour Point, F., Maximum                             0
                                          Copper Corrosion, Maximum, (ASTM D-130)             1
                                          Shell Four-Ball E.P.
                                            Load Wear Index                                 68
                                            Weld Point, Kg.                                   400
                                          Timken O.K.  Test Load, #                            60
4824
                                                                M977 Hfi Products. Inc.  P fl  Rn» 117R4  Wir.hita Kansas Pf>r

-------
            SPECIFICATIONS
  Viscosity @ 210°F. SUS
  Viscosity @ 100°C. cs
  Viscosity @ 100°F. SUS
  Viscosity @ 40°C. cs
  Viscosity Index,
    Minimum
  Flash Point, °F.
  Flash Point,  C.
60-70
10.0-12.6
300-500
58.9-97.7

130
350 Minimum
177 Minimum

                                            Lib
                                       UU
                                                         i   n
                                                            1  i
BG  MOTOR OIL ADDITIVE  is an oil-soluble, heat-stable for-
mula which provides improved engine performance, less en-
gine parts wear, easier operation, and longer equipment life.
Most modern, high quality motor oils contain additives that are
designed to protect against the formation of engine deposits,
rust and corrosion,  and engine parts wear. These additives
gradually deplete themselves through normal engine opera-
tion which can result in oil oxidation or thickening. BG MOTOR
OIL ADDITIVE improves a quality motor oil's ability to provide
the desired protection and performance characteristics.
A Sequence IIIC Test (a standard industry accepted measure-
ment of a motor  oil's performance under severe operating
conditions) was conducted at the facilities  of a leading inde-
pendent testing laboratory to determine any advantages which
might result from using BG MOTOR OIL ADDITIVE in an  API
Service Classification "SE" motor oil.
The results of the tests show that use of BG MOTOR  OIL
ADDITIVE affords greater engine protection against the forma-
tion of sludge and varnish deposits than the protection pro-
vided by a high quality "SE"  motor oil without the benefits of
BG  MOTOR OIL ADDITIVE. The tests also concluded that the
viscosity increase data indicated use of BG  MOTOR OIL ADDI-
TIVE offered improved high temperature oxidation inhibition.
BG MOTOR OIL ADDITIVE can help reduce oil consumption and
engine parts wear, smooth and seal metals under frictionai
conditions, and reduce friction between internal parts.
                 DIRECTIONS FOR  USE:
For continued engine protection use as follows: Use at the ratio
of 1 gallon (3.792 liters) Motor Oil Additive to each 15 gallons
(56.88 liters) (or  11 ozs. to  5 qts.) of Motor  Oil at each oil
change or every 150 hours of operation.
 Motor Oil Additive can be  added to crankcase anytime the oil
 level is low to fortify the motor oil and to improve lubrication.
 DO NOT OVERFILL  CRANKCASE!
5964
                                  © 1978 BG Products, Inc. P.O. Box 11264 Wichita, Kansas 67211

-------
  April 27, 1978
                                      Cocie 766
                             US. DEPARTMENT OF LABOR
                       Occupational Safety and Health Administration

                  MATERIAL  SAFETY  DATA  SHEET
                                     Form Aoorovcd
                                     OMB No. 44.R1J87
                 Required under USOL Safety and Health Regulations for Ship Repairing,
                      Shipbuilding, and Shipbreaking (29 CFR 1915, 1916. 1917)
                                     SECTION I
  MANUFACTURER'S NAME
                        EMERGENCY TELEPHONE NO.

                                   fc
  ADDRESS (Number, Street. City. State, and ZIP Code)
  424  S. Greenwood (P.O.  Box  11264)  Wichita. Kansas  67211
  CHEMICAL NAME AND SYNONYMS
  N. A.
                 TRADE NAME AND SYNONYMS
                 BG EPC 1320.  Code 766
  CHEMICATT FAMILY
  Hydrocarbon
                                          FORMULA
                 N.A.
SECTION II • HAZARDOUS INGREDIENTS
PAINTS. PRESERVATIVES. & SOLVENTS
PIGMENTS
CATALYST
VEHICLE
SOLVENTS
ADDITIVES
OTHERS
%






TLV
(Units)






ALLOYS AND METALLIC COATINGS
BASE METAL
ALLOYS
METALLIC COATINGS
FILLER METAL
PLUS COATING OR CORE FLUX
OTHERS
'
HAZARDOUS MIXTURES OF OTHER LIQUIDS. SOLIDS, OR GASES
This material is essentially lubricating oils with extreme pressure and
antiwear agents, 'it is not believed to be a hazardous material by U. S.
Department of Labor definition, * and would not require a warning label
as specified in the Hazardous Substance Act.**
%






X




TLV
(Units)






TLV
(Units)




                            SECTION III - PHYSICAL DATA
 BOILING POINT (°F.)
                                Unknown
          SPECIFIC GRAVITY (HjO-1)
                                             0.9
 VAPOR PRESSURE (mm H9.)
                                Unknown
          PERCENT. VOLATILE
          BY VOLUME (%)
  Slight
 VAPOR DENSITY (AIR-1)
Unknown
                                          EVAPORATION RATE
Unknown
 SOLUBILITY IN WATER
                                  Slight
 APPEARANCE AND ODOR  Dark amber lube oil
                   SECTION IV - FIRE AND EXPLOSION HAZARD DATA
 FLASH POINT (M«thod u»«d)
                    300° F.  C.O.C.
            FLAMMABLE LIMITS
             Unknown	
 EXTINGUISHING MEDIA
                    CO?, foam, dry chemical
 SPECIAL FIRE FIGHTING PROCEDURES
                            Do not direct water directly into fire,
 UNUSUAL FIRE AND EXPLOSION HAZARDS
                               None
        *C. F. K. January  I,  l(.>70  ISO!.?.
PAGE (1)                        (Continund on rovervi sidn)
            C. K. U.  Par I I'.'I
                                       Form OSHA-20
                                       *•». M»y It

-------
SECTION V - HEALTH HAZARD DATA
THRESHOLD
EFFECTS OF
LIMIT VALUE
Unknown
OVEREXPOSURE
Irritation and redness to eves

EMERGENCY
AND FIRST AID PROCEDURES ... . ... • .
Wash eyes with water or eyewash

.
                             SECTION VI . REACTIVITY DATA
STABILITY
                UNSTABLE
                STABLE
 INCOMPATABILITY (Materials to avoid)
                               X
                                     CONDITIONS TO AVOID
                              None
 HAZARDOUS DECOMPOSITION PRODUCTS
                                 Dense black smoke,  CO.  CO?.
 HAZARDOUS
 POLYMERIZATION
                    MAV OCCUR
                    WILL NOT OCCUR
                                              CONDITIONS TO AVOID
SECTION VIJ - SPILL OR LEAK PROCEDURES
STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED
Rerpove all sources of icrnition. Absorb with floor sweep and shovel up excess
and scrape and sweep remainder.

WASTE DISPOSAL METHOD
Controlled burning if allowed bv Federal, State, and local laws. Used lube
oils
are recycleablc through rerefining processes.

SECTION VIII - SPECIAL PROTECTION INFORMATION
RESPIRATORY PROTECTION (Specify type)
None
VENTILATION
LOCAL EXHAUST
MECHANICAL (General)
PROTECTIVE GLOVES
None

SPECIAL
OTHER None
eve PROTECTION
Sufficient to avoid direct contact.
OTHER PROTECTIVE EQUIPMENT _. ,
None
SECTION IX • SPECIAL PRECAUTIONS
PRECAUTIONS TO BE TAKEN IN HANDLING AND STORING
Store awav from HicrH hpat anrl or»pn f1am*>s ... ,

OTHER PRECAUTIONS
Product should

be used

onlv for the purpose for which it was intended.

PAGE (2)
C"0 f JC.5W
Form OSHA-20
R«*. M»y 72

-------
           Si;*?--  MATERIAL SAFETY'DATA. SHEET
 SECTION  I
                              PRODUCT  MOTOR OT1  ADnTTTVg
• MANUFACTURING DIVISION
_ -BG -PRODUCTS, » INCV."
ADDRESS (NUMBER. STREET. CiTY.
P.' 0.-BOX~1126*f.-
CHEMICAL NAME OR FAMILY
Hydrocarbon
dR SUBSIDIARY •'
STATE. ZIP CODE)
WICHITA, KANSAS 6721l'
.

• ' ' * ' .
: • . • '
FORMULA
.. N. A. ' ' ' .
EMERGENCY TELEPHONE
MANUFACTURER • '
,31fr .265-2686..
CHEM TREC l-(800) 424-9300


SECTION II -CHEMICAL AND PHYSICAL. PROPERTIES '•.-•' .', .
BOILING PT. 	 •£( 	 _•?=)
MELTING PT 	 »C ( 	 f)
EVAPORATION HATE 1 	 __.- 1)
VAPOR PRESSURE- . (mmHg.at 20 «C)
SOLUBILITY IN. H,0 AT . > *^ , . •
VAPOR DENSITY (AIR - 1) , ...
PERCENT VOLATILE (BY WT. %) .
PHYSICAL FORM AND ODOR • ' • .' • . ' ' '*".•'
Red Lubricating Oil . . .-...-.>'. ' ' '.•'.'•
HAZARDOUS DECOMPOSITION PRODUCTS '. , _ ' ' '. ,.
t) ens e Black Smoke,- CO, CO7 . "....>
SPECIFIED GRAVITY (H.O -1)
STRONG ACiq D
STRONG BASE' D
STABLE CS..--
UNSTABLE < D
'^^^:^:^':'^:/-\'.
INCOMPATIBILITY (KEEP AWAY FROM) -........,._..''.' .. •
None •• •" •• •- • • '• • .:•'. ••'. ..' •-..- • '. • ... .-•..•'..' •;:"''•••'•'••:'•••
LIST ALL TOXIC AND HAZARDOUS INGREDIENTS • ..• ' i% •• •:•;..«•• .:•'.'•• . .'•... '' ' • ' • • ; '• '' •'••.-.,.
• . . ; • ;'/.'• .'• ." . "•.•: '/'''•'..;•';.'•;. '• '..'.:'' \ , '. ' _..• • . .' '''. f •'•''•..'
•' • ' ' ' . ' ' •••*.'
SECTION III - FIRE AND EXPLOSION DATA
 FLASH POINT (METHOD USED)
                         350.
                                            Unknown
                          FLAMMABLE LIMITS % LOWER	UPPER .
EXTINGUISHING AGENTS
DRYCHEMICAL ' &' CO,  ' D  WATERSPRAY  .Foam
SPECIAL FIRE FIGHTING PROCEDURES •   .    ....
   Do not direct water directly.into fire.
UNUSUAL FIRE AND EXPLOSION HAZARDS
.   Noae         .   '-.-:.
                                        -.1.
SECTION IV - HEALTH HAZARD DATA
PERMISSIBLE CONCENTRATIONS (AIR)
  •Unknown       •   ' '
•EFFECTS OF OVEREXPOSURE
 Irritation and
                                                  fen
TOXICOLOGlCAL PROPERTIES
  •Unknown
EMERGENCY FIRST AID PROCEDURES .  '% '\
  EYES       Wash eyes with water or eyewash.
  SKIN CONTACT   .    .         '
  INHALATION
  IF SWALLOWED           .               .  .    .'

-------
                     MATERIAL SAFETY DATA SHEET
                                       Pago 2 of 2
                                                                '  PHQPUCT toTOR OIL ADDITIVE
  SECTION  V - SPECIAL PROTECTION INFORMATION        .'                     .                      7"~
  VENTILATION TYPE REQUIRED (LOCAL. MECHANICAL. SPuCiAL)
 	    None          .-           '     .
  flESPIRAJORY PROTECTION (SPECIF,/ TYPE)          :^             '  '   :      . '               ~~	~

       None     ••'''••..-:...•••....,
  PROTECTIVE GLOVES
       None
EYE PROTECTION
  Sufficient to avoid direct contact.
 OTHER PROTECTIVE EQUIPMENT
       None
 SECTION VI - HANDLING OF SPILLS OR LEAKS
 PROCEDURES FOR CLEAN-UP    •'              ;                    •        •~.
    Reoaove all Sources of ignition.  Absorb with floor sweep and shovel up. excess and
    scrape  and sweep remainder.'         '        .      •   	<•
 WASTE DISPOSAL                :                            ~   '     :      .
    Controlled burning if allowed by S^ederalj  State,  and local laws.  Used lube oils are
    recyclable through re-refining processes.   •
 SECTION Vll - SPECIAL PRECAUTIONS
 PRECAUTIONS TO BE TAKEN IN HANDLING AND STORAGE         .,

   Store away from high heat and open flames.
 SECTION  VIII - TRANSPORTATION DATA
 U.S. DEPARTMENT Of TRANSPORTATION HAZARD CLASS
                                                                         D  UNREGULATED BY D.O.T.
 LABEL REQUIHED
 U.S. O.O.T. PROPER SHIPPING NAME
   Petroleum Oil N.O.S,  173,  118
 TRANSPORTATION EMERGENCY INFORMATION
        CHEM TREC l-(800) 424-9300
 SECTION  IX - COMMENTS
   Product should be used only for the purpose for which it was intended..!
                                                'TITLE     Manager. Total Quality Assui'ance •
              TERRY H.  SMITH          "•:'^ '
 REVISION DATE  	;	   •         DATE SENT  	
The information contained herein is based on data considered accurate. Howovor, no warranty, expressed or implied, is s'tvon re-
garding tho accuracy of those data or the results to bo obtained from the use thereof.

-------
                    MATERIAL SAFETY DATA SHEET
                                       Pag« 2 of 2
 SECTION  V - SPECIAL PROTECTION INFORMATION
                pRQDUtrrBG Supercharge No. 20
                              Code 785
 VENTILATION TYPE REQUIRED (LOCAL, MECHANICAL. SPECIAL)
                                        None
 RESPIRATORY PROTECTION (SPECIFY TYPEI
                                        None
 PROTECTIVE GLOVES
                  None
EYE PROTECTION
Sufficient to avoid direct contact
 OTHER PROTECTIVE EQUIPMENT
                      None
 SECTION  VI - HANDLING OF SPILLS OR LEAKS
 PROCEDURES FOR CLEAN-UP
  Remove all sources of ignition.  Absorb with floor sweep and shovel up excess and
  scrape and  sweep remainder.
 WASTE DISPOSAL
  Controlled burning if allowed by Federal, State, and local laws,
  recycleable through  re-refining processes.
                       Used lube oils are
 SECTION  VII - SPECIAL PRECAUTIONS
 PRECAUTIONS TO BE TAKEN IN HANDLING AND STORAGE

  • Store away from high heat and open flames.!
 SECTION  VIII - TRANSPORTATION DATA
 U.S. DEPARTMENT OF TRANSPORTATION HAZARD CLASS
  Non-hazardous
                        •D UNREGULATED BY D.O.T.
 LABEL REQUIRED
            None
 U.S. D.O.T. PROPER SHIPPING NAME
                        Petroleum  Oil N.O.S. 173, 118
 TRANSPORTATION EMERGENCY INFORMATION
        CHEM TREC 1-1800) 424-9300
           t
 SECTION  IX - COMMENTS
  Product .should be  used only for the purpose for which it was intended.
 SIGNATURE
                              i.'//
          (/ Jon W. Smith
 REVISION DATE  	
TITLE Quality Control Supervisor,
             Plants I & II
DATE SENT 	
The information contained herein is based on data considered accurate. However, no warranty, expressed or implied, is given re-
garding the accuracy of these data or the results to be obtained from the use thereof.

-------
SECTION I
                                                    RECEIVtD MAY*
                   MATERIAL SAFETY DATA SHEET

                             PRODUCT BG Supercharge No.  200, Code 785
WITCO MANUFACTURING DIVISION OR SUBSIDIARY
Southwest Petro-Chem, Inc. (Wichita)
ADDRESS INUMBER. STREET, CITY. STATE. ZIP CODE)
220 West Waterman - Wichita, Kansas, 67202
CHEMICAL NAME OR FAMILY
Hydrocarbon
EMERGENCY TELEPHONE
MANUFACTURER
I 316 1261-311 1
CHEMTREC l-{800) 424-9300
FORMULA
• N.A.
SECTION II - CHEMICAL AND PHYSICAL PROPERTIES
Unknown
BOILING PT. 	 °C( 	 °F)
MELTING PT. 	 'C ( 	 °F)
EVAPORATION RATE ( 	 - 11
Unknown
VAPOR PRESSURE ImmHg at 20 *C)
Unknown
SOLUBILITY IN H,0 AT 	 "C
Slight , ..
VAPOR DENSITY (AIR - 1)
Unknown
PERCENT VOLATILE tBY WT. %l
Slight '.-••.'.
PHYSICAL FORM AND ODOR .
Amber lube oil with solvent odor
HAZARDOUS DECOMPOSITION PRODUCTS
Dense black smoke, CO, CC>2 !
INCOMPATIBILITY (KEEP AWAY FROM)
None
SPECIFIED GRAVITY 
-------
                        RICHARD .T. FAY AND ASSOCIATES, INC.
                               CONSULTING ENGINEERS
                                 516 ACOMA STREET
                               DENVER. COLORADO 8O2O4



                                   REPORT                            003) 823.1309
RICHARD J. FAY                           —————
REX E. PAULSEN
JOHN M. FREEMAN. JR.
JACK N. GROWER
ROOCR H. MAGUIRC
BRUCE E. BIRIA
Boa O. SCHLIEM
MARK J. FEU.INO
GBEO W. MCILVAIN
   Mr.  Dennis  Garsjo
   Glasgo-BG
   Fort Peck Route
   Glasgow,  Montana 59230
    SUBJECT:        Oil Analysis  for  PCB  or Contaminates

    REFERENCE:      Our File No:   81-94

    DATED:          March 25, 1981

    PREPARED  BY:    Bruce E. Birza, Senior Lab Technician
    INTRODUCTION ;    A natural gas  transmission system is concerned about
    their transmission gas lines becoming contaminated by compressor cylinder
    oil.   We were  engaged to analyze  a  "BG Motor Oil Additive"  for PCB or
    other known contaminates.

    CHEMICAL ANALYSIS RESULT;

            The "BG Motor Oil Additive"  sample was tested for Polychlorinated
    Biphenyls (PCB) and other chlorinated hydrocarbons using "Gas  Chroma-
    tographic"  techniques..  This Gas  Chromotograph instrument will detect
    PCB  above 5 parts per million  (ppm) .

            EPA consider oils which have  less than 50 ppm not harmful and
    may  be used for any function.  5  ppm  is 1/10 of the permissible limit.
    In the sample  oil tested, no PCB  or other chlorinated hydrocarbons were
    detected.


                       Respectfully submitted,
                       Bruce E. Birza      (j
                       Senior Technician
    BEB/C

-------
                                                             Attachment C.'•
June 30, 1981
Hr. Pennis L. Carsjc, Sales Manager
Glasgow Industrial Distributing
Distributor, I-G Products, Inc.
Fort Peck Haute
       , in  5?230
Dear llr. Gars Jo:

We have  reviewed your application  for  an EPA  evaluation of BG  Products,
which  include,  ;;:G Extreme  Pressure Concentrate,  BG I'otcr  Oil  Additive,
and  "G  fuperchargt; Casoline Treatment.   This  letter Is  intended to  pro-
vjx'e direction in proceeding though  the evaluation process.

Your gasoline additive vill be evaluated  according to Section  311  process
as  described  in the  documents  enclosed with ny  letter  to  you  dated
March 9, 1981.   I an  enclosing the  latest list of FPA recogrinecl indepen-
dent  laboratories  so  t^at  you cay  cake   arrangement 3  to  obtain  the
required data  on this  product.  Ue  would like  to  cotment  on ycur  test
plan before testing begins.

EPA has  b«en involved  ever  the past two years  in the development of  test
procedures  for  lav friction  engine lubricants including serving  on  the
technical cotnr.ittcc  that is developing  the  ASTM procedure.   Since  there
arc  several  conpnnies  vrith   product  11 nee  aiirilar  to  yours, IT? A  ban
r«cciv&d  numerous suggestions as  to the  Eanner in which  low friction
lubricants should be evaluated* - Our policy is  finning up as  follows:

    1.  Motor vehicle oils ami  lubricants do  not  fall  under the  provi-
         sions  of Section 511  of the l-'otor  Vehicle  Information and  Cost
        Eavirgs  Act.   Howevex, T.PA  io  prepared to vork  with ?G Products
        and  to  evaluate your products  using  the  same procedures  and
        protocols dafir.Cf!  in  the documents  I  mailed  to   you  on MarcL  'J,
        15H1.  The  results  will be  published  in the form of a  technical
        report and  uo Section 511 report  or  Federal Register notice  uiJ.l
       •be prepared as done in norcal Section 511 evaluations.

    2.  The 
-------
«   »  »
                                                                                               4.
                                                                                                   o
                                                                                                   1
                                                                                                   t
                                                                                                  6.
                                                                                                cles
                                                                                                you!
                                                                                                taot<

                                                                                                 Pie
                                                                                                  yn
                                                                                                  yo

-------
                           ANN AR80R" M'CH'GAN  48105           Attachment D


                                                                 OFFICE OF
                                                         AIR AND WASTE MANAGEMENT
August 19, 1981
Mr. Dennis Garsjo
Glasgow Industrial Distributing
Fort Peck Route
Glasgow, MT  59230

Dear Mr. Garsjo:

In my letter to you of June 30, I described the procedure  for  pursuing an
EPA evaluation  of  BG  Supercharge  Gasoline Treatment under Section  511 of
the Motor Vehicle. Information and Cost Savings Act.  I  also  explained how
we could  evaluate  BG  Motor Oil Additive,  even though  it  is outside  the
scope  of  the  Act.  In  that   letter,  I  offered  to assist  you  in  your
efforts to conduct preliminary testing at an independent laboratory which
is "recognized" by EPA.

Since  that  time,  we have  not heard from  you.   In order  to conduct  our
evaluations on  a  timely  basis,  we  must establish  a   schedule  for  each
one.  Please contact me by August 31 if you wish to pursue evaluations of
BG Supercharge  Gasoline Treatment and/or BG  Motor Oil Additive.  In this
case, we will expect your draft test plan by September  14  and  the results
of testing at an recognized laboratory  by October  26.

If we do not hear  from you by August 31, we  will prepare  our  Section 511
evaluation of BG Supercharge  Gasoline  Treatment  based  on  the  information
we have.   We will take  no  further action  on  the other BG additives.
Please  contact  me immediately  if  you have  any  questions  or require
further information.  My telephone number is  (313)  668-4299.

Sincerely,
Merrill U. Korth,  Device Evaluation Coordinator
Test and Evaluation Branch

-------
          August 24,  1981
          Merrill W.  Korth
          Device Evaluation  Co-Ordinator
          United States Enviromental  Protection Agency
          Ann Arbor,  MI  48105
          Dear Mr.  Korth,

          In answer to your  letter of August  19, 1981,  Glasgow  Industrial
          Distributing hereby requests that you withdraw our application
          to test BG Supercharge Gasoline Treatment and BG Motor Oil
          Additive  until we  are able  to submit the proper information
               such an evaluation.
          Do to economic conditions we have not retained one of  the approved
          laboratories to conduct the  preliminary test.   We will  submit
          a new application when we are ready  to have one of them proceed.

          Thank you  for your  time and  consideration.

          Sincere!
          Dennis L.  G,
          Glasgo BG
             jo, President
          DLG/dra
HOME OFFICE
For I Peck Route
Glasgow. Montana 5923O
(406)238-9313
BRANCHES   Glasgow Veterinary Stjpcty
          P.O. Box 2346 Hwy. 87 North
          Gteat Fail, Montana S94O3
          (4O6) 727-0613
Oasgo of Mriei City
Industrial Park
P.O. Box 67
Mle» Otv. Montana 593OJ
(406)232-6868
Glasgo ol Belgrade
Route Z Box 469A
JocluaDbit Lane
Bolata** Montana 59714
(406)388-4742
GtajQO of Kcliipol
BO(V)99
3239Hwy.93S
Katspol Montana SW
(4O6) 755-aiW

-------
                                                                Attachment F
Soptcabec  3,  1981
Mr. Eamls I..  Carsjo
C 1.1 PEU  ill?
Fort Peck  ?.oute
         rfT  39230
thsar Mr.  Oars jo:

'*?i  h^v.:  rucsiJvad  your letter-t:£ ^u^-jst  2b in  vh.lc»« you  eeck  to «1chilr«v
your   application  for   nn  r?A  «evalt.sation  of  5C  3uporclK-*r^«  Oa«ollr.i:
Tr^.-'Swonc  -r.c  iiti  irotor  f/ii  jwiiitiv:-.   As  I  r.uatioaad   to  you  its our
tul-jphonii ccnvirsoticr.  of August  24,  Section  511  of ttia I'otor Vehicle
IniorrntJon .'.rd  Cost Savi.n?*3  Act  requires us  Co  puhllcli  era  r«t>:lcs  yT
our  ?v,)!uation  of yotir'fual sdditlva.  I's will cor.sir-jr  all iaff^-natior.
a:v!  .-;ntc «'i?  have  ot thin tine*   Sir,r.»»  oil  scdittvcs ara rot  a::Jr•?.•?•:-•-•'
itttcisr  tri-j provisions of  this  act,  you ray uithuraw  your  o^plic^tJcn for
 C*- * •»  .>*•• '(•»•»
 :i*0 ,•*>-. Uw ».«

li  ycu visJi  to pursue  an i'FA  evaluation of either of  thasa  prtcucts  in
this  iuC'jro, vhu ara prepar-id  to work,  with you again.  Pleas a  contact re  if
you 'uivu  jny  r^iestloos or require further  inforraticjn.

Sincorcly,
Merrill  '.f.  ;-;orc!:, iv:vic-2  revaluation Coordinator
Test  ar.d Cvalu.itinn Pra

bcc:  H.  Korch

-------