GREENWICH CHEMICAL CONSULTING, INC . RECEIVED 

OPPT CRIP 

3300 PGA BOULEVARD • SUITE 635 

PALM BEACH GARDENS, FL 33410 ?nn AP& 1Q AM in. i n 

TELEPHONE 561.578.81 10

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FACSIMILE 561.578.8120 

April 18, 2013 

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OPPT Document Control Office 

EPA East Building 

Room E6428 

U.S. Environmental Protection Agency 

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4 0 1 3000003 6 

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

40 CFR 799.5089 

Re: Submission of Final Test Reports for Studies Conducted by the PCBTF 

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

Certain High Production Volume Chemicals: Third Group of Chemicals 

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

CAS RN 98-56-6 

(p^-Chlorobenzotrifluoride (PCBTF)) 

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

40 CFR 799.5089 

Dear Sir/Madam: 

On behalf of the PCBTF Testing Consortium, Greenwich Chemical Consulting, Inc. 

(Greenwich Chemical Consulting) submits to the U.S. Environmental Protection Agency 

(EPA or the Agency) final test reports for the two (2) studies conducted on the chemical 

CONTAINS NO CBI 
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April 18, 2013 

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substance, b enzene, l-chloro-4-(trifluoromethyl)- [CAS RJNf 98-56-6] which is subject to a 

Toxic Substances Control Act (TSCA) Section 4 test rule.1 For purposes of this letter, the 

chemical substance, benzene, l-chloro-4-(trifluoromethyl)-, is herein referred to as, PCBTF. 

The PCBTF Testing Consortium submits these test reports in accordance with this test rule 

and the regulations set forth at 40 CFR 799.5089. 

L General Background 

Greenwich Chemical Consulting functions and operates as the panel manager for and 

authorized representative of the PCBTF Testing Consortium. Therefore, Greenwich 

Chemical Consulting submits this letter and the enclosed final test reports on behalf of the 

PCBTF Testing Consortium's 13 member companies identified below:2 

Brenntag North America, Inc. 

Chemsynergy, Inc. 

China Specialty Chemical Company, Ltd. 

EMCO Chemical Distributors, Inc. 

Greenchem Industries LLC 

Kowa American Corporation 

Malditesliim Agan of North America, Inc. 

MC International, LLC3 

Nexeo Solutions, LLC4 

Silver Fern Chemical, Inc. 

Special Materials Company 

Univar USA, Inc. 

Valspar Corporation 

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 (2) 

studies on PCBTF: 

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

• Ready Biodegradation 

' 76 Fed, Reg, 65385; October 21, 2011. 

2

 See Attachment A for the addresses of member companies. 

* It is noted that 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. 

4

 Nexeo Solutions, LLC recently joined the PCBTF Testing Consortium and submitted to EPA on April 4, 

2013 an exemption application under the test rule for PCBTF. 
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H. Use of OECD Test Guidelines and Related Protocol Matters 

In the final TSCA Section 4 test rule, EPA specified the use of an ASTM test guideline for 

the algae study and either ISO or ASTM guidelines for the biodegradation test. In its letter 

dated January 31, 2012, the PCBTF Testing Consortium requested that the corresponding 

OECD test guidelines 201 and 301D be used in the conduct of the algae and biodegradation 

studies, respectively. On February 9, 2012, the Agency granted this request.5 

Subsequently and as required under 40 CFR 790.50 and 799.5089, the PCBTF Testing 

Consortium submitted to the Agency final study plans for the algae and biodegradation tests 

identified above. In this submission, the PCBTF Testing Consortium indicated that it had 

selected CiToxLAB Hungary Ltd. (CiToxLAB) to conduct this testing. These two (2) study 

plans were then approved by EPA. 

Because of technical issues that arose in the conduct of the OECD 301D biodegradation 

test, CiToxLAB determined that the OECD 301D test protocol could not be used to 

effectively asses the degradation of PCBTF. These technical issues were discussed in detail in 

the PCBTF Testing Consortium's letter to EPA dated October 22, 2012. The laboratory 

recommended the use of OECD 301F in which the study would be carried out at the 

Institute for Biological Analysis and Consulting GmbH (IBACON) in Germany. On 

December 5, 2012, the PCBTF Testing Consortium submitted to EPA a revised study plan 

for the testing of the material under OECD 301F at IBACON. After its review, the Agency 

on December 12, 2012 granted this request and approved the new study plan. 6 

III . Final Submission Deadline under the Test Rule 

The deadline set forth in the original TSCA Section 4 test rule required that the two (2) test 

reports on PCBTF be submitted to EPA by December 21, 2012 unless the Agency has 

granted a test schedule modification. Due to technical issues that arose in the course of 

testing, the PCBTF Testing Consortium requested in its October 22, 2012 letter to the 

Agency a four-month extension in accordance with 40 CFR 790.55. EPA granted this 

extension on November 14, 2012 which resulted in the final deadline changing from 

December 21, 2012 to April 21, 2013.7 

IV. List of Final Test Reports 

Consistent with the final TSCA Section 4 test rule, the following two (2) final test reports are 

included herein along with the final test report on the analytical method. 

5

 Electronic mad from Dr. Paul J. Campanella (EPA) to Mr. John V. Massingale (Greenwich Chemical 

Consulting). 

'•Id 

7 Id. 
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U.S. Environmental Protection Agency 

April 18, 2013 

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• Growth Inhibition Test with Benzene, l-chloro-4-(trifluoromethyl)- on Algae 

{Pseudokhxhneriella subcapitatd) 

• Ready Biodegradability of Benzene, l-chloro-4-(tri£luoromethyl)- in a Manometric 

Respirometry Test 

B

 Validation of the Analytical Method for the Determination of Benzene, l-chloro-4-

(trifluoromethyl) -

V. Submission of Robust Summaries through HPVIS 

In the final test rule, EPA requests, but does not require, that a robust summary also be 

included for each test identified in the rule consistent with the Agency's Draft Guidance on 

Developing Robust Summaries. The Agency recently signaled to the PCBTF Testing Consortium 

that the submission of these robust summaries was unnecessary. This is acceptable to the 

group. If EPA decides at a later date that it wishes to receive such robust summaries, the 

PCBTF Testing Consortium will provide them. 

* # # 

The PCBTF Testing Consortium thanks the Agency for its consideration in this matter. For 

all questions and comments 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.com 

Sincerely, 

John V. Massingale 

Principal 
U.S. Environmental Protection AgencyApril 18, 2013 

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BUSINESS INFORMATION 

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

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 

Nexeo Solutions, LLC 

Silver Fern Chemical, Inc. 

Special Materials Company 

Univar USA, Inc. 

Valspar Corporation 

Enclosures 
Attachment A - Addresses of Member Companies 

Companv Address 

Brenntag North America, Inc. 5083 Pottsville Pike 

Reading, PA 19605 

Chemsynergy, Inc. 1100 Burloak Drive 

Suite 101 

Burlington, ON L7L 6B2 

Canada 

China Specialty Chemical Company, Ltd. Unit A (RM 9) 3/F 

Cheong Sun Tower 

116418 Wing Lok Street 

Sheung Wan 

Hong Kong 

EMCO Chemical Distributors, Inc. 2100 Commonwealth Avenue 

North Chicago, IL 60064 

Greenchem Industries, LLC 222 Clematis Street 

West Palm Beach, FL 33401 

Kowa American Corp. 55 East 59th

 Street 

19th Floor 

New York, NY 10022 

Makhteshim Agan of North America, Inc. 171 Madison Avenue 

Room 1605 

New York, NY 10016 

MC International, LLC 2 NE 40th Street 

Suite 501 

Miami, FL 33137 

Nexeo Solutions, LLC Nexeo Solutions, LLC 

1400 Woodloch Forest Drive 

Suite 200 

The Woodlands, TX 77380 

Silver Fern Chemical Inc. 2226 Queen Anne Avenue North 

Seatde,WA 98109 

Special Materials Company 70 West 40th Street 

2

n d

 Floor 

New York, NY 10018 

Univar USA Inc. 17425 NE Union Hill Road 

Redmond, WA 98052 

"Valspar Corporation PO Box 1461 

Minneapolis, MN 55440