### GREENWICH CHEMICAL CONSULTING, INC. 3300 PGA BOULEVARD • SUITE 635

PALM BEACH GARDENS, FL 

### 33410 TELEPHONE 561.578.8110 fACSIMILE 561.578.8120


### April23, 2015

ByFederalExpress



### OPPT Document Control Office EPA EastBuilding 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 ofthe FinalTest 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 AgencyU.S. Environmental Protection Agency Apri123, 2015 Page2 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 testreportin 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 authorizedrepresentative ofthePCBTFTestingConsortium. Therefore, GreenwichChemical 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 NorthAmerica, Inc. • Chemsynergy, Inc. • China Specialty Chemical Company, Ltd. • EMCO Chemical Distributors, Inc. • Greenchem Industries LLC • KowaAmerican Corporation • MakhteshimAgan ofNorthAmerica, Inc. • MC International, LLC3 • Moris Technology Center, LLC • Nexeo Solutions, LLC • Silver Fem Chemical, Inc. • Special Materials Company • Superior Oil Company, Inc. • Univar USA, Inc. • Valspar Corporation This fmal test rule addresses 15 high production volume (HPV) chemicals that went unsponsoredundertheAgency's voluntary HPVChemical Challenge Program. One ofthe 15 chemicals identifiedintherule is PCBTF. The fmal rule identifies the following two (2) studies onPCBTF:

• Aquatic Toxicity Testing: toxicity to plants (algae)) • Ready Biodegradation ThePCBTFTesting Consortium conducted these tests andtimely submitted final testreports to theAgencyinits letter datedApril18, 2013. Based onEPA'sreview ofthe algae testreport,

t 76 Fed. Reg. 65385; October 21, 2011. 2 See Attachment A for the addresses ofmember companies. 3 MC International, LLC operates the entity, Miami Chemical, Inc., as a DBA. For purposes ofU.S. Customs and TSCA, MC International, LLC is the importer.U.S. Environmental Protection Agency April23, 2015 Page3 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 ofSeptember 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 compoundwhichwas 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 ofSeptember 26, 2013. Harlan Laboratories developed this study plan takinginto account andincorporatingthese comments and also addressing the technical difficulties associated with testing PCBTF (i.e., poor water solubility and high volatility). This studyplanwas submitted to theAgency onJanuary 9, 2014 (ahead oftherevisedJanuary 12, 2014 deadline). In its response dated March 6, 2014, EPA determined that the submitted study planwas adequate with certain stipulations andmodifications. 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 toincorporate all oftheAgency's stipulations andmodifications. Attherequest ofthePCBTF Testing Consortium, additional guidancewas subsequentlyrequested from EPA on the use of serial dilutions alongwith otherminormatters. TheAgencyprovided this guidance inits 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 onApril21, 2015 and is included herein ahead ofthe April30, 2015 deadline. II. Submission Deadlines for the Study Plan and FinalTest Report Inits 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 bywhich 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 inits letter dated November4, 2014 for the submission ofthe final testreport. This date was April30, 2015 which was granted by EPAin its response dated November 10,2014.

4 In the final TSCA Section 4 test rule, EPA specified the use ofanASTM 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 ofthe algae. TheAgency granted this request inboth cases.U.S. Environmental Protection Agency April23, 2015 Page4
III. List ofFinal Test Report CONTAINSNO 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 ofRobust 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 DevelopingRobustSummaries. TheAgencypreviously signaledto thePCBTFTestingConsortium 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 Consortiumwill 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 contactinformation 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
JohnV. Massingale PrincipalU.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

### AttachmentA- Addresses ofMember Companies

Com

**pan~** 

### Address Brenntag NorthAmerica, Inc. 5083 Pottsville Pike Reading, PA 19605 Chemsynergy, Inc. 1100 Burl oakDrive Suite 101 Burlington, ON L7L 6B2 Canada China Specialty Chemical Company, Ltd. UnitA (RM 9) 3/F Cheong Sun Tower 116-118 WingLok 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 NewYork, NY 10022 MakhteshimAgan ofNorthAmerica, Inc. 171 Madison Avenue Room 1605 NewYork, NY 10016 MC International, LLC 2 NE 40th Street Suite 501 Miami, FL 33137 Moris Technology Center, LLC 9 Ilene Court, Unit #2 Hillsborough, NJ 08844 Nexeo Solutions, LLC Nexeo Solutions, LLC 3 Waterway Square Place Suite 1000 The Woodlands, TX 77380 Silver Fern Chemical Inc. 2226 QueenAnneAvenue North Seattle, WA 98109 Special Materials Company 70 West 40th Street 2nd Floor NewYork, 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