CBIC Control Number 

356879 

GREENWICH CHEMICAL CONSULTING, ID~f'~B~g 

3300 PGA BOULEVARD • SUITE 635 

PALM BEACH GARDENs, FL 3341o 20J3t;ov -7 AM ro: s2 

November 6, 2013 

TELEPHONE 561.578.8110 

FACSIMILE 561.578.8120 

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By UPS 

OPPT Document Control Office 

U.S. Environmental Protection Agency 

EPA East Building 

Room E6428 

1201 Constitution Ave., NW 

Washington, DC 20004 

Attn.: 40 CPR 799.5089 

Docket ID Number: EP A-HQ-OPPT -2009-0112 

Re: Extension Request 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. (Greenwich Chemical Consulting) submits to the U.S. Environmental 

Protection Agency (EPA or the Agency) an extension request for additional time to review 
U.S. Environmental Protection Agency 

November 6, 2013 

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and respond to the Agency's notice of inadequacy regarding the algae study conducted on the 

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

currendy 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, PCBTF. The Consortium files 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 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 13 member companies identified below: 

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Brenn tag North America, Inc . 

Chemsynergy, Inc . 

China Specialty Chemical Company, Ltd . 

EMCO Chemical Distributors, Inc . 

Greenchem Industries LLC 

I<.owa American Corporation 

Makhteshim Agan of North America, Inc . 

MC International, LLC2 

N ex eo Solutions, LLC 

Silver Fern Chemical, Inc . 

Special Materials Company 

U nivar USA, Inc . 

V alspar Corporation 

This fmal 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 fmal rule identifies the following two (2) studies 

onPCBTF: 

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

• Ready Biodegradation 

The PCBTF Testing Consortium conducted these tests and timely submitted fmal test reports 

to the Agency in its letter dated April18, 2013. Based on EPA's review of the algae test report, 

the Agency has concluded that the study is inadequate for purposes of the TSCA Section 4 

test rule and must be re-conducted. The basis of the Agency's conclusions were set forth in 

its letter of September 26, 2013. 

1 76 Fed. Reg. 65385; October 21, 2011. 2 MC International, LLC operates the entity, :Miami Chemical, Inc., as a DBA. For purposes of U.S. Customs 

and TSCA, MC International, LLC is the importer. 
U.S. Environmental Protection Agency 

November 6, 2013 

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II. Extension Request 

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In its September 26, 2013 determination letter, EPA states that a new study plan must be 

submitted to the Agency by November 12, 2013 with the fmal report submitted by October 

12,2014. The PCBTF Testing Consortium respectfully requests a two (2) month delay to each 

of these dates such that the study plan would be submitted by January 12. 2014 and the fmal 

report submitted by December 12. 2014. 

The principal reason for this extension request pertains to two complex issues which EPA 

describes in its determination letter. First, the Agency states that the test material was not 

tested at the level of solubility. The Agency cites a Merck Index value of 29 mg/L while the 

Consortium's testing indicated a value of7.04 mg/L. The compound's correct solubility needs 

to be reviewed and assessed. And second, PCBTF is a volatile material which presented 

technical issues during testing. The Agency notes that there may have been excessive 

volatilization of the test material during testing. In sum, the Consortium needs additional time 

to review and respond to EPA's comments, as well as work with a laboratory to address these 

complex technical issues. 

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 fmal rule: 

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 ... 3 

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. 4 Moreover, this alleviates EPA from 

having to seek public comment before approving these modifications. 

The Consortium believes that a two (2) month extension to the test schedule dates set forth 

in its determination letter of September 26, 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. 

3 76 Fed. Reg. 65397. 

4 40 CFR 790.55(b)(3). 

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U.S. Environmental Protection Agency 

November 6, 2013 

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Finally, the Consortium has become aware that a reliable algae study has been added to the 

European Union's REACH dossier for PCBTF. The Consortium is assessing whether this 

study, which was completed earlier this year, would adequately meet EPA's requirements 

under the test rule in lieu of re-conducting the study. The Consortium would also utilize the 

additional time in the extension to review this study in the REACH dossier and whether the 

group could obtain access to this study for purposes of the TSCA Section 4 test rule. 

* * * 

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@)grcci.cotn 

Sincerely, 

John V. Massingale 

Principal 

cc: Mr. John Schaeffer- U.S. EPA 

PCBTF Testing Consortium