GREENwicH CHEMICAL CoNsuLTING, INc. RECEIVED 

OPPT CBIC 

3300 PGA BouLEVARD • SuiTE 635 

PALM BEACH GARDENS, FL 33410 2012 OCT 23 AM 10: 39 

October 22, 2012 

TELEPHONE 561.578.8110 

fACSIMILE 561.578.8!20 

OCT 3 1 2012 

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By UPS 

OPPT Document Control Office 

U.S. Environmental Protection Agency 

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Room E6428 1111111111111111111111111111111111111111111111111111111111111111 

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1201 Constitution Ave., NW 

Washington, DC 20004 

Attn.: 40 CFR 799.5089 

Docket ID Number: EPA-HQ-OPPT-2009-0112 

Re: Request for Modification of Test Schedule for Testing Conducted by the 

PCBTF Testing Consortium under the TSCA Section 4 Test Rule on the 

Testing of Certain High Production Volume Chemicals; Third Group 

Benzene, 1-chloro-4-( trifluoromethyl)-

CAS RN 98-56-6 

(para-Chlorobenzotrifluoride (PCBTF)) 

Docket ID Number: EPA-HQ-OPPT-2009-0112 

40 CFR 799.5089 

Dear Sir/Madam: 

On behalf of the PCBTF Testing Consortium (the Consortium), Greenwich Chemical 

Consulting, Inc. submits to the U.S. Environmental Protection Agency (EPA or the Agency) 

a request for the modification of the test schedule for studies c<?nducted on the chemical 

c 

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U.S. Environmental Protection i\gency 

October 22, 2012 

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substance, benzene, 1-chloro-4-(trifluoromethyl)- [CAS RN 98-56-6] which is currently 

subject to a Toxic Substances Control Act (TSCA) Section 4 test rule. 1 For purposes of this 

letter, the chemical substance, benzene, 1-chloro-4-(trifluoromethyl)-, is herein referred to as, 

PCBIF. The Consortium ftles this request in accordance with this test rule and the 

regulations set forth at 40 CFR 790.55 and 799.5089. 

I. General Background 

Greenwich Chemical Consulting, Inc. (Greenwich Chemical Consulting) functions and 

operates as the panel manager for and authorized representative of the Consortium. 

Therefore, Greenwich Chemical Consulting submits this letter on behalf of the 

Consortium's 10 member companies identified below:2 

• Brenn tag North America, Inc. 

• Chemsynergy, Inc. 

• EMCO Chemical Distributors, Inc. 

• Greenchem Industries LLC 

• Kowa American Corporation 

• Makhteshim Agan of North America, Inc. 

• MC International, LLC3 

• Silver Fern Chemical, Inc. 

• Special Materials Company 

• Univar USA, Inc. 

This final test rule addresses 15 high production volume (HPV) chemicals that went 

unsponsored under the Agency's voluntary HPV Chemical Challenge Program. One of the 

15 chemicals identified in the rule is PCBTF. The final rule identifies the following two 

studies on PCBTF: 

• Aquatic Toxicity Testing: toxicity to plants (algae)) 

• Ready Biodegradation 

II. Request for Test Schedule Modification 

The deadline set forth in the TSCA Section 4 test rule requires that the test data on PCBTF 

be submitted to EPA by December 21, 2012 unless the Agency grants a test schedule 

modification. The Consortium understands that EPA will accept a schedule modification 

request if such a request is made in accordance with 40 CFR 790.55. Concurrent with this, 

the Agency stated the following in the final rule: 

1 76 Fed. Reg. 65385; October 21,2011. 2 See Attachment A for the addresses of member companies. 3 It is noted that MC International, LLC operates the entity, Miami Chemical, Inc., as a DK-\. For purposes of 

U.S. Customs and TSC-\, MC International, LLC is the importer. 
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U.S. Environmental Protection :\gency 

October 22, 2012 

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A company that submits a letter of intent to test under the final rule and that 

subsequently anticipates difficulties in completing the testing by the deadline set 

forth in the final rule may submit a modification request to the Agency, pursuant 

to 40 CFR 790.55. EPA will determine whether modification of the test schedule 

is appropriate ... 4 

In accordance with the requirements under 40 CFR 790.55 and EPA's comments in the final 

rule. the Consortium respectfully requests a four-month extension of the December 21. 2012 

deadline to April 21. 2013 for the two required studies on PCBTF: (1) algae aquatic toxicity 

and (2) biodegradation. The basis of this request is set forth below. 

The principal reason for this extension request pertains to a significant delay in the initiation 

of biodegradation testing on PCBTF because of technical testing issues. As previously 

approved by the Agency, PCBTF is to be tested for biodegradability under OECD Test 

Guideline 301D. In late April, the laboratory advised the Consortium that because of the 

compound's highly stable nature- owing largely to its carbon-fluorine bonding- a Chemical 

Oxygen Demand (COD) value could not be calculated using the standard dichromatic 

method set forth in the test guideline. 5 After several discussions between the Consortium 

and the laboratory in May and June, EPA was subsequently advised of this COD testing 

issue in early July. 6 In September, the Agency responded with guidance on how to possibly 

address the COD issue. This guidance was immediately provided to the laboratory which, 

after reviewing this guidance, continued to believe that testing under OECD 301D could 

likely not be accomplished. In a conference call earlier this month with the Agency to 

address this issue with the Dr. Paul Campanella and Dr. Robert Boethling and Greenwich 

Chemical Consulting, EPA recommended the use of Theoretical Oxygen Demand (ThO D) 

in lieu of COD. Dr. Boethling subsequently provided additional and indeed helpful 

comments on ThOD which were provided to the laboratory. At this time, the laboratory is 

reviewing EPA's ThOD comments, but is also signaling that OECD 301F may be a better 

alternative. In sum, the technical issues associated with biodegradation testing have 

significantly protracted the laboratory testing process. 

Another reason, albeit minor, for this extension request pertains to the high volatility of the 

test material. In its preliminary analytical work, the laboratory has had to take additional 

measures to ensure that PCBTF is not volatilized during testing. These same measures are to 

be applied to the algae and biodegradation testing. The laboratory has just completed its 

analytical method test work and will soon initiate the algae testing. Overall, the high volatility 

of PCBTF has slowed the laboratory's work. 

The Consortium is requesting a four-month extension (rather than a somewhat shorter one) 

to address the possibi!iry that OECD 301D may not be feasible and that OECD 301F (or 

4 76 Fed. Reg. 65397. 5 During this time, the Consortium was still awaiting EP.\'s review of the study plans submitted to the Agency 

on February 17, 2012. 

6 Electronic mail to Dr. Paul Campanella (EPA) from ;o.rr. John V . .'\Iassingale (Greenwich Chemical 

Consulting) on July 3, 2012. 
U.S. Environmental Protection Agency 

October 22, 2012 

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another protocol) may be required. If so, this would require the submission of a new study 

plan on OECD 301F to the Agency for approval - it would likely take several weeks for 

EPA to review and approve such a plan. 

With respect to the requirements set forth at 40 CFR 790.55, The Consortium does not 

believe that the requested modification to the test schedule requested herein would 

"significandy alter the scope of the test[s] or significandy change the schedule for completing 

the test[s]" because it does not meet any of the conditions set forth at 790.55(b)(4)(i)-(iv) and 

further because it does not rise to the level of "significant" in terms of time. 7 Moreover, this 

alleviates EPA from having to seek public comment before approving these modifications. 

In compliance with the timing requirements set forth at 790.55(d)(1), this test schedule 

modification application is being made prior to the 60-day deadline for such requests. In 

addition, this requested four-month extension is only about one month longer than that 

described at 790.55(d)(3) which provides that EPA "will normally limit extensions to a 

period of time equal to the in-life portion of the test plus 60 days." 

The Consortium believes that a four-month extension to the test schedule to April 21, 2013 

is a minor schedule modification and would not prevent the Agency from meeting its 

statutory obligations under TSCA Section 4 or its voluntary commitments under either the 

HPV Chemical Challenge Program or the OECD HPV SIDS Program. In addition, this 

schedule modification request does not significandy change the schedule for completing the 

tests as described in 790.55. 

* * * 

The Consortium thanks the Agency for its consideration in this matter. For all questions, 

comments, and determinations concerning this matter, please use the contact information 

given below. 

Mr. John V. Massingale 

Greenwich Chemical Consulting, Inc. 

3300 PGA Boulevard, Suite 635 

Palm Beach Gardens, FL 33410 

Telephone: (561) 578-8110 

Facsimile: (561) 578-8120 

E-mail: john(ci!grcci.com 

7 40 CFR 790.55(b)(3). 
U.S. Environmental Protection Agency 

October 22, 2012 

Page 5 

Sincerely, 

John V. Massingale 

Principal 

cc: Dr. Paul Campanella- U.S. EPA 

PCBTF Testing Consortium 

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