April 4, 2013 

CONTAINS NO CONFIDENTIAL 

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OPPT Document Control Office 

EPA East Building m iiiiiiiiiiiiiiii 

4 0 1 3000003 4 

III III 

Room E6428 

U.S. Environmental Protection Agency 

1201 Constitution Ave, NW 

Washington, DC 20004 

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

Re: Exemption Application Submitted by Nexeo Solutions, LLC as Patt of the 

PCBTF Testing Consortium under the TSCA Section 4(a)(1)(B) Test Rule 

Testing of Certain High Production Volume Chemicals; Third Group 

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

CAS RN 98-56-6 

(paia-Chlorobenzotrifluoride (PCBTF)) 

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

40 CFR 799.5089 

Dear Sir/Madam: 

Through this letter, Nexeo Solutions, LLC (Nexeo Solutions or the Company) submits to 

the U.S. Environmental Protection Agency (EPA or the Agency) this application for an 

exemption from testing under Section 4 of the Toxic Substances Control Act (TSCA). This 

exemption application is submitted for the chemical substance, benzene, l-chloro-4-

40 CFR 799.5089 

CONTAINS NO CBt 
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CONTAINS NO CONFIDENTIAL 

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U.S. Environmental Protection Agency 

April 4, 2013 

Page 2 

(ttifluoromethyl)- [CAS RN 98-56-6], under the Agency's Toxic Substances Control Act 

(TSCA) Section 4(a)(1)(B) test rule published on October 21, 2011.1 For purposes of this 

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

PCBTF. 

Nexeo Solutions is submitting this exemption application since the Company plans to 

import for the first time later this year PCBTF in amounts greater than 500 kg for 

commercial purposes. Therefore, the Company files this request in accordance with this final 

rule and the regulations set forth at 40 CFR 790.80 - 790.99 and 799.5089. In addition, 

Nexeo Solutions is a new member of the existing PCBTF Testing Consortium which it 

joined in March 2013. 

J. General Background 

Greenwich Chemical Consulting, Inc. (Greenwich Chemical Consulting) functions and 

operates as the panel manager for and representative of the PCBTF Testing Consortium. 

Therefore, Greenwich Chemical Consulting submits this letter on behalf of Nexeo Solutions 

as a new member of the PCBTF Testing Consortium. 

This final test rule addresses 15 high production volume (FIPV) 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 Agency has issued this test rule under its 

TSCA Section 4(a)(1)(B) authority based on its belief that HPV compounds, including 

PCBTF, are "produced in substantial quantities; there is or may be substantial human 

exposure to them; existing data are insufficient to determine or predict their health and 

environmental effects; and testing is necessary to develop such data."2 

In general, the final rule identifies the following two studies on PCBTF: 

• Ready Biodegradation 

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

I I . Required Information for this Exemption Application 

A. 790.82fa) 

Identity of the test rule, the chemical identity, and the CAS Registry Number of the test substance on which 

the application is based. 

Testing of Certain High Production Volume Chemicals: Third Group 

[76 Fed Reg, 65385; October 21, 2011] 

1

 76 Fed. Reg. 65385. 

* 76 Fed, Reg, 65387. 
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U.S. Environmental Protection Agency 

April 4, 2013 

Page 3 

Benzene, l-chloro-4-(tafluoromethyi)- [CAS RN 98-56-6] 

B. 790.82(b) 

The specific testing requirements) from which an exemption is sought and the basis for the exemption request. 

This exemption application is being submitted for the ready bio degradation test and aquatic 

toxicity testing (toxicity to plants (algae)) on PCBTF as required under this test rule at 40 

CFR 799.5089 and as subsequently approved by EPA during the study plan review process. 

The primary basis for this exemption application is that these two studies have already been 

completed through testing already sponsored by the PCBTF Testing Consortium.3 In 

addition, Nexeo Solutions understands that EPA is not interested in receiving duplicative 

testing. The Company, as part of its membership in the PCBTF Testing Consortium, will be 

reimbursing the original members for its share of the group's original testing and 

administrative costs incurred under the test rule. 

C. 790.82(c) 

Name, address, and telephone number of applicant.4 

Nexeo Solutions, LLC 

1400 Woodloch Forest Drive 

Suite 200 

The Woodlands, TX 77380 

Telephone: (281) 297-0700 

D. 790.82(d) 

Name, address, and telephone number of appropriate individual to contactforfurther information. 

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: iohnfSigrcci.com 

1

 The final reports for the algae and biodegradation studies were completed and issued on March 19, 2013 and 

April 4, 2013, respectively. 

4

 Company contact person: Mr. Sol Bobst (Senior Regulatory Compliance & Toxicology Advisor); telephone 

(281) 297-0352. 
p. 4 

CONTAINS NO CONFIDENTIAL 

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U.S. Environmental Protection Agency 

April 4, 2013 

Page 4 

E. 790.99 

Certification 

I understand that if this application is granted before the reimbursement period 

described in section 4(c)(3)(B) of TSCA expires, I 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 

my application was based. 

Nexeo Solutions, as a member of the PCBTF Testing Consortium, therefore, submits this 

exemption application in accordance with the final TSCA Section 4(a)(1)(B) test rule 

described herein and the regulations set forth at 40 CFR 790.80 - 790.99 and 799.5089. 

For all questions and comments concerning this matter, please contact the PCBTF Testing 

Consortium's panel manager: 

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 

Panel Manager 
p. 5 

i 

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U.S. Environmental Protection Agency 

April 4, 2013 

Page 5 

cc: 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 (Miami Chemical) 

Nexeo Solutions, LLC 

Silver Fern Chemical, Inc. 

Special Materials Company 

Univar USA, Inc. 

Valspar Corporation 

Mr. John Schaeffer - U.S. Environmental Protection Agency 
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