GREENWICH CHEMICAL CONSULTING, INC. 

3300 PGA BOULEVARD • SUITE 635 

PALM BEACH GARDENS, FL 33410 

TELEPHONE 561.578.8110 

fACSIMILE 561.578.8120 

April23, 2015 

By Federal Express 

OPPT Document Control Office 

EPA East Building 

RoomE6428 

U.S. Environmental Protection Agency 

1201 Constitution Ave., NW 

Washington, DC 20004 

CONTAINS NO CONFIDENTIAL 

BUSINESS INFORMATION 

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

40 CFR 799.5089 

Re: Submission of the Final Test Report for the Algae Study Re-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, 1-chloro-4-(trifl.uoromethyl)-

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, Greenwich Chemical Consulting, Inc. 

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

Apri123, 2015 

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CONTAINS NO CONFIDENTIAL 

BUSINESS INFORMATION 

(EPA or the Agency) the final test report for the algae study re-conducted on the chemical 

substance, benzene, 1-chloro-4-(trifluoromethyl)- [CAS RN 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, 1-chloro-4-(trifluoromethyl)-, is herein referred to as, PCBTF. 

The PCBTF Testing Consortium submits this test report in accordance with this test rule and 

the regulations set forth at 40 CPR 799.5089. 

I. 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 report on behalf of the PCBTF 

Testing Consortium's 15 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 

• Makhteshim Agan of North America, Inc. 

• MC International, LLC3 

• Moris Technology Center, LLC 

• N ex eo Solutions, LLC 

• Silver F em Chemical, Inc. 

• Special Materials Company 

• Superior Oil Company, Inc. 

• Univar 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 final test reports 

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

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

2 See Attachment A for the addresses of member companies. 

3 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 

April23, 2015 

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CONTAINS NO CONFIDENTIAL 

BUSINESS INFORMATION 

however, the Agency concluded that the study was inadequate for purposes of the TSCA 

Section 4 test rule and must be re-conducted. The Agency's conclusions were set forth in its 

letter of September 26, 2013. The algae study was re-conducted as described below. 

As required under 40 CFR 790.50 and 799.5089, the PCBTF Testing Consortium timely 

submitted to EPA the study plan for a new algae test on the compound which was developed 

by the group's new contract lab, Harlan Laboratories Ltd. (Harlan Laboratories). As part of 

the development of this study plan, the PCBTF Testing Consortium provided to Harlan 

Laboratories the Agency's comments of September 26, 2013. Harlan Laboratories developed 

this study plan taking into account and incorporating these comments and also addressing the 

technical difficulties associated with testing PCBTF (i.e., poor water solubility and high 

volatility). 

This study plan was submitted to the Agency on January 9, 2014 (ahead of the revised January 

12, 2014 deadline). In its response dated March 6, 2014, EPA determined that the submitted 

study plan was adequate with certain stipulations and modifications. In addition, EPA granted 

the PCBTF Testing Consortium's request to again use OECD test guideline 201.4 Thereafter, 

the PCBTF Testing Consortium worked with Harlan Laboratories to modify the study plan 

to incorporate all of the Agency's stipulations and modifications. At the request of the PCBTF 

Testing Consortium, additional guidance was subsequently requested from EPA on the use of 

serial dilutions along with other minor matters. The Agency provided this guidance in its letter 

dated October 2, 2014. 

The PCBTF Testing Consortium subsequently finalized the study plan with Harlan 

Laboratories, and the testing program began in November 2014. The final test report was 

issued on April21, 2015 and is included herein ahead of the April30, 2015 deadline. 

II. Submission Deadlines for the Study Plan and Final Test Report 

In its September 26, 2013 determination letter, EPA stated that a new study plan for the algae 

test must be submitted to the Agency by November 12, 2013 and the final report submitted 

by October 12, 2014. The Agency subsequently granted the PCBTF Testing Consortium's 

extension request dated November 6, 2013 for a delay to these dates by which the study plan 

would be submitted by January 12, 2014 and final report submitted by December 12, 2014. 

This request was granted by EPA in its response dated November 12, 2013. 

Because of several technical issues, the PCBTF Testing Consortium requested an additional 

extension in its letter dated November 4, 2014 for the submission of the final test report. This 

date was April30, 2015 which was granted by EPA in its response dated November 10,2014. 

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

both the first and second algae tests, the PCBTF Testing Consortium requested that the corresponding OECD 

test guidelines 201 be used in the conduct of the algae. The Agency granted this request in both cases. 
U.S. Environmental Protection Agency 

April23, 2015 

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III. List of Final Test Report 

CONTAINS NO CONFIDENTIAL 

BUSINESS INFORMATION 

Consistent with the ftnal TSCA Section 4 test rule, the following ftnal test report is included 

herein. 

Benzene, 1-chloro4-(trijluorometf?yl)- CAS RN 98-56-6 (para-Chlorobenzotrijluoride (PCBTF)): Algal 

Growth Inhibition Test 

IV. Submission of Robust Summaries through HPVIS 

In the ftnal 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 Drcift Guidance on 

Developing Robust Summaries. The Agency previously 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@gxcci.com ~/-- · 

I Sincerely, 1 

John V. Massingale 

Principal 
U.S. Environmental Protection Agency 

April 23, 2015 

Page 5 

cc: Mr. P. Lewis- U.S. EPA 

Mr. M. Matteisen - U.S. EPA 

Ms. H. Njo - U.S. EPA 

Mr. J. Schaeffer- U.S. EPA 

PCBTF Testing Consortium 

Enclosure 

CONTAINS NO CONFIDENTIAL 

BUSINESS INFORMATION 
Attachment A- Addresses of Member Companies 

Com pan~ Address 

Brenn tag North America, Inc. 5083 Pottsville Pike 

Reading, PA 19605 

Chemsynergy, Inc. 1100 Burl oak Drive 

Suite 101 

Burlington, ON L7L 6B2 

Canada 

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

Cheong Sun Tower 

116-118 Wing Lok Street 

SheungWan 

Hong Kong 

EMCO Chemical Distributors, Inc. 8601 95th Street 

Pleasant Prairie, WI 53158 

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 

Moris Technology Center, LLC 9 Ilene Court, Unit #2 

Hills borough, NJ 08844 

Nexeo Solutions, LLC Nexeo Solutions, LLC 

3 Waterway Square Place 

Suite 1000 

The Woodlands, TX 77380 

Silver Fern Chemical Inc. 2226 Queen Anne Avenue North 

Seattle, WA 98109 

Special Materials Company 70 West 40th Street 

2nd Floor 

New York, NY 10018 

Superior Oil Company, Inc. 1402 North Capitol Avenue 

Suite 100 

Indianapolis, IN 46202 

Univar USA Inc. 17425 NE Union Hill Road 

Redmond, WA 98052 

Valspar Corporation PO Box 1461 

Minneapolis, MN 55440