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STAT! OF VIRGINIA 1 \l· ~ · ~-

AFFIDAVIT

COUNT'i OP FAIRFAX

AFfiQAVIT Of PAUL M SULLIVAN

I, Paul M. Sullivan, beinq duly aworn, atata the following under oath:

1. I have worked for Mobil Oil Corporation ainca .June 1974 with tha exception of the period from June 1976 to September 1977 when I vorkad for Baa Chemical Company in California. I am currently Corporate PurchaainC) Coordinator tor Additivaa at Mobil '• corporate headquarter• in Fairfax, Virginia.

2. Fro• 1974 to 1976, I vorkad aa a chamht at Mobil' • Eaat Beaton Lube Plant (EBLP) in Eaat Beaton , Maaaachuaatta. Froa Saptaaber 1977 to 1979 I waa a Technical Service Rapraaantatlva for Mobil'• Northeast Raqion, and had raaponsibility for providing technical aarvica to tha EBLP during this period . rro• 1979 through 1985, I returned to EBLP, where I waa Chief Chaaiat froa 1979 throuqh 1982, and Plant Manager froa 1982 through 1985 . As auch, I •• thoroughly taailiar with the producta produced at the EBLP, their contanta and ••thod of production, which have changed relatively little fro• the 1970'• to the pre..nt.

l. The EBLP h one of tan lube oil planta operated by Mobil across the country. Soaa of theae lube planta are at and are part of Mobil retinari... Othera auch a a EBLP are not phyaically at the refinery due to loqiatical conaidarationa involving the efficient diatribution of product•, but perform the aame proc••••• and operation• that are parforaed by a lube plant that ia part of a ratinary . Other oil companiea abo hava lube planta that are part of their retinariea, aa wall aa aoma othara that are physically located alaevhera.

4 . The EBLP produce• a variety of lubricatinq oila by blanding baaa atock oila delivered from the refinery by tanker, barge or rail tank car, with varioua low volume additivea. The baae atock and additive• are blended by heating the product and aixing it in a kettle blender . Other than reactions which involve foraulation of aoapa in a taw products, no chemical reactions taka place which chemically change tha contenta of the lube oil. EBLP's baae atock oils vera paraffinic oila shipped from Mobil'• Paulaboro, New Jersey refinery .

5. The EBLP's products included three categories: automotive oils (about 60 percent by volume), industrial oils (about 25 percent by volume), and apecialty oils (10 to 15 percent by

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volume) . All or th••• product• qanarally contain at leaat ao parcant baaa atock patrolaua with tha aajority containing in axcau ot 90 parcant baaa atocka and the balance ia additivaa .

6 . EBLP'a automotive oila generally contain at haat 10 parcant baaa atock and about 10 parcant of a "'DDI packaCJa" of additivaa conahting of datarqanta, dbpananta and i nhibiton, all of which ara atandard, non-haa:ardoua chamicala uaed. in all angina o Ua. Mobil'• industrial oila aada at EBLP con.htad prbarily of hydraulic oila and cutting tlulda, which ware typically 95 parcant or aor a baaa atock and about 5 parcant additivaa, conabtinq of anti-oxidanta and anti-foamanta including zinc and aulfur com­pounda. Specialty oila conabted of 9ear lubea, 9r••••• and a amall quantity of aynthetic oila ma nufactured elaewhere ,

7 . None of the additiv.. that the EBLP uaed in t he 1970 1 •

were conddered hazardoua or toxic che•icala that required apecial handling , precaution• of labeling . None of the lube oil•, baae atocka or additive• uaed or produced at the EBLP contained benzene , toluene, xylene or other volatile hydrocarbon co•pounda, which we re contained in the light fnctiona reaoved fro• the crude oil by diatillation at the refinery, leaving the heavier petroleu• fraction• that were uaed in lube oil. To the beat of •Y knowledge, none of the baae atocka, additive• or product• uaed or produced at EBLP contained PCBa, chlorinated aolventa or toxic heavy metab .

Subacribed and aworn to before •• thh {,ft._ day of October 1992.

Notary Public

My co11l!Dhaion expirea : ----­