p.1 

CBIC Control Number 

RECEIVED 

OPPT CBiC 

201UAH15 AH 10:29 

357802 

Baule USA LLC 

3100 McClaren Woods Drive 

Coraopolis, PA 15108 

January 14,2014 

By FedEx 

Document Control Office (DCO) (7407M) 

Office of Pollution Control and Toxics (OPPT) 

U.S. Environmental Protection Agency (EPA) 

EPA East Building, Room E6428 (202-564-8930) 

1201 Constitution Avenue, NW 

Washington, D.C. 20460 

Attention: TSCA Section 4 

40 C.F.R. § 799.5087 (Docket No. EPA-HQ-OPPT-2007-0531) 

Re: Application for Exemption from Testing 

Test Rule: 40 C.F.R. § 799.5087 (Docket No. EPA-HQ-OPPT-2007-0531) 

Test Substance: Benzenediamine, ar,ar-diethyl-ar-m ethyl-, Chemical Abstracts 

Service Registry Number 68479-98-1 

Dear Sir or Madam: 

Baule USA LLC ("Baule") hereby requests an exemption from all testing of benzenediamine, 

ar,ar-diethyl-ar-methyl-, Chemical Abstracts Service Registry Number 68479-98-1 ("DETDA"), 

under the TSCA § 4 test rule for DETDA codified at 40 C.F.R. § 799.5087. The basis for 

Baule's exemption request is as follows. 

Baule imports DETDA in small quantities and solely as an ingredient in mixtures processed by a 

foreign affiliate. Baule's imports of DETDA were less than 1,500 kg in 2013, and Baule expects 

to import only 3,000 kg in 2014, which is less than two percent (< 2%) of the 2011 import 

volume reported for DETDA by Lonza, Inc. under the 2012 Chemical Data Reporting ("CDR") 

Rule.1 

In addition, Albemarle reported its 2011 manufacturing volume for DETDA under the 2012 CDR Rule but 

claimed this information as confidential. 
p. 2 

*EPA/OPPT/DCO, Attention: TSCA Section 4 

January 14, 2014 

Page 2 of2 

Albemarle Corporation has provided EPA with a letter of intent to conduct all of the testing from 

which Baule seeks an exemption.2 Therefore, Baule's submission of the required test data for 

DETDA would duplicate the data that Albemarle already is submitting to EPA under 40 C.F.R. 

§ 799.5087. In addition, EPA does not require Baule to demonstrate that its imported DETDA is 

equivalent to the DETDA being tested by Albemarle.3 For these reasons, Baule's exemption 

application satisfies the requirements for conditional approval by EPA.4 

Lastly, Baule understands that if this application is granted before the reimbursement period 

described in section 4(c)(3)(B) of TSCA expires, Baule 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 Baule's application was 

based. 

Please address any questions about this exemption application to the undersigned. Baule 

appreciates EPA's consideration of this application. 

Sincerely, 

General Manager 

Baule USA LLC 

3100 McClaren Woods Drive 

Coraopolis, PA 15108 

Tel. (724)213-6088 

Email: rich.rogers@bauleusa.com 

RR:mb 

2

 Baute understands that Albemarle also has submitted studies of DETDA to EPA under 40 C.F.R. § 799.5087. 

3

 76 Fed. Reg. 1067, 1079 (Jan. 7, 2011) ("In this final rule, EPA will not require the submission of equivalence 

data (i.e., data demonstrating that your substance is equivalent to the substance actually being tested) as a condition 

for approval of your exemption."). 

4

 See 40 C.F.R. § 790.87(a).