p. 1



### GREENWICH CHEMICAL CONSULTING, OPPT



### 3300 PGA BOULEVARD • SUITE 

### 635 CBIC
PALM BEACH GARDENS, FL 3 3 4 1 0 

## 2014 AUG 28 

## 11 : 30 TELEPHONE 561.578.8110 FACSIMILE 561.578.8120

August 27, 2014 CBIC Control Number 

# 361585
CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION
By Federal Express Scanned & Processed in CIS by: SHARON
OPPT Document Control Office EPA East Building Room E6428 U.S. Environmental Protection Agency 1201 Constitution Ave., NW Washington, DC 20004
Attention: Docket ID Number: EPA-HQ-OPPT-2009-0112

40 CFR 799.5089

Re: Exemption Application Submitted by Superior Oil Company, Inc. as Part of the PCBTF Testing Consortium under the TSCA Section 4(a)(1)(B) Test Rule 

### 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: Through this letter, Superior Oil Company, Inc. (Superior Oil Company or the Company). submits to the U.S. Environmental Protection Agency (EPA or the Agency) this application for an exemption from testing under Section 4 of the Toxic Substances Control Act (TSCA). This exemption application is submitted for the chemical substance, benzene, 1-chloro-4-p. 2 CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION U.S. Environmental Protection Agency August 27, 2014 Page 2
(trifluoromethyl)- [CAS RN 98-56-6], under the Agency's Toxic Substances Control Act (TSCA) Section 4(a)(1)(B) test rule published on October 21, 2011. 1 For purposes of this letter, the chemical substance, benzene, 1-chloro-4-(trifluoromethyl)-, is herein referred to as, 

### PCBTF. Superior Oil Company files this request in accordance with this final rule and the regulations set forth at 40 CFR 790.80 - 790.99 and 799.5089.
I. General Background Greenwich Chemical Consulting, Inc. (Greenwich Chemical Consulting) functions and operates as the panel manager for and representative of the PCBTF Testing Consortium. Therefore, Greenwich Chemical Consulting submits this letter on behalf of Superior Oil Company as a new member of the PCBTF Testing Consortium. 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 Agency has issued this test rule under its TSCA Section 4(a)(1)(B) authority based on its belief that HPV compounds, including PCBTF, are "produced in substantial quantities; there is or may be substantial human exposure to them; existing data are insufficient to determine or predict their health and environmental effects; and testing is necessary to develop such data." In general, the final rule identifies the following two studies on PCBTF:

• Ready Biodegradation

• Aquatic Toxicity Testing (toxicity to plants (algae)) Required Information for this Exemption Application
A. 790.82(a) 

### IdentiO of the test rule, the chemical identiO, and the CAS Registg Number of the test substance on which the application is based. Testing of Certain High Production Volume Chemicals; Third Group [76 Fed. Reg. 65385; October 21, 2011] Benzene, 1-chloro-4-(trifluoromethyl)- [CAS RN 98-56-6]
B. 790.82(6)

1 76 Fed. Reg. 65385. 2 76 ask Reg. 65387.P. 3 CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION U.S. Environmental Protection Agency August 27, 2014 Page 3
The specific testing requirement(s) from which an exemption is sought and the basis for the exemption request. This exemption application is being submitted for the ready biodegradation test and aquatic toxicity testing (toxicity to plants (algae)) on PCBTF as required under this test rule at 40 CFR 799.5089 and as subsequently approved by EPA during the study plan review process. The primary basis for this exemption application is that these two studies have already been completed through testing already sponsored by the PCBTF Testing Consortium. 3 In addition, Superior Oil Company understands that EPA is not interested in receiving duplicative testing. The Company, as part of its membership in the PCBTF Testing Consortium, will be reimbursing the original members for its share of the group's original testing and administrative costs incurred under the test rule. C. 790.82(c) Name, address, and telephone number of applicant.' Superior Oil Company, Inc. 1402 North Capitol Avenue Suite 100 Indianapolis, IN 46202 Telephone: (317) 781-4400
D. 790.82(d) Name, address, and telephone number of appropriate individual to contact for further information. 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@grcci.com

3 The final reports for the algae and biodegradation studies were completed and issued on March 19, 2013 and April 4, 2013, respectively. In April 2013, the PCBTF Testing Consortium timely submitted these fmal test reports to EPA. The Agency subsequently determined that the algae study was inadequate and required that the study be re-conducted for purposes of the TSCA Section 4 test rule. This second algae study is in the development stage in conjunction with Harlan Laboratories Ltd. and EPA. 4 Company contact person: Mr. Steve Mahoney (Manager of Regulatory Affairs).Sincerely,

John V. Massingale Panel Manager p. 4 CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION U.S. Environmental Protection Agency August 27, 2014 Page 4

E. 790.99 Certification I understand that if this application is granted before the reimbursement period described in section 4(c)(3)(B) of TSCA expires, I must pay fair and equitable reimbursement to the person or persons who incurred or shared in the costs of complying with the requirement to submit data and upon whose data the granting of my application was based.

Superior Oil Company, as a member of the PCBTF Testing Consortium, therefore, submits this exemption application in accordance with the final TSCA Section 4(a)(1)(B) test rule described herein and the regulations set forth at 40 CFR 790.80 - 790.99 and 799.5089. For all questions and comments concerning this matter, please contact the PCBTF Testing Consortium's panel manager: 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@graicomP. 5 CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION U.S. Environmental Protection Agency August 27, 2014 Page 5

cc: Brenntag North America, Inc. Chemsynergy, Inc. China Specialty Chemical Company, Ltd. EMCO Chemical Distributors, Inc. Greenchem Industries, LLC Kowa American Corporation Makhteshim Agan of North America, Inc. MC International, LLC (Miami Chemical) Nexeo Solutions LLC Superior Oil Company, Inc. Silver Fern Chemical, Inc. Special Materials Company Univar USA, Inc. Valspar Corporation Mr. John Schaeffer — U.S. Environmental Protection Agency