July 10, 2014 By Chemical Information Submission System Document Control Office (DCO) (7407M) Office of Pollution Prevention and Toxics (OPPT) U.S. Environmental Protection Agency (EPA) 1200 Pennsylvania Avenue , NW Washington , D.C
. 20460-0001 Attention: TSCA Section 4 40 C.F.R. § 799.5089 (Docket No. EPA-HQ

- OPPT

- 2009-0112) Re: Application for Exemption from Testing Test Rule: 40 C.F.R. § 799 .5089 (Docket No. EPA -HQ - OPPT -2009-0112) Test Substance: Benzene, 1 -chloro - 4-(trifluoromethyl) - , Chemical Abstracts Service Registry Number 98-56-6 Dear Sir or Madam: The Chemical Company ("TCC) hereby requests an exemption from all testing of benzene, 1

- chloro-4

- (trifluoromethyl)- , Chemical Abstracts Service Registry Number ("CASRN") 98-56-6 ( " PCBTF") , under the TSCA § 4 test rule for PCBTF codified at 40 C .F. R. § 799
. 5089. The basis for TCC's exemption request is as follows
. TCC imports PCBTF in small quantities for commercial distribution within the United States. TCC projects its imports of PCBTF in 2014 and in future years to be less than one percent( < 1 %) of the 28,964,014 pounds of domestic production reported for calendar year 2011 under the 2012 Chemical Data Reporting Rule. 1 By letter dated April18, 2013 from Greenwich Chemical Consulting , Inc . , the PCBTF Testing Consortium has submitted to EPA all ofthe testing from which ICC seeks an

Chemical Data Access Tool (CDAT) , U.S
. ENVTL. PROT. A GENC Y, http ://java
. epa . gov/oppt chem ical search/ (last visited July 8, 2014) (for CASRN 98-56

- 6, the " National Production Volume for Chemical" is "28,964,014 lb/yr . "). The Chemical Company • 44 Southwest Ave. Jamestown, RI 02835 • 401.423
.3100 www .thechemco
.comexemption ? Therefore, TCC's submission of the required test data for PCBTF would duplicate the data that the PCBTF Testing Consortium already has submitted to EPA under 40 C.F.R. 

### § 799.5089. In addition, EPA does not require TCC to demonstrate that its imported PCBTF is equivalent to the PCBTF tested by the PCBTF Testing Consortium. 3 For these reasons , TCC's exemption application satisfies the requirements for conditional approval by EPA. 4 Lastly , TCC understands that if this application is granted before the reimbursement period described in section 4(c)(3)(B) ofTSCA expires, TCC 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 ofTCC's application was based. Please address any questions about this exemption application to the undersigned. TCC appreciates EPA's consideration ofthis application
.

I 

# \ Robert N. Roach , III President THE CHEMICAL COMPANY 44 Southwe st Avenue Jamestown , Rhode Is land 02835 Phone: (401) 360-2800 Email: Robb@thechemco.com RR:mb

See also Toxic Substance s Control Act Chemical Te s ting ; Receipt ofTest Data, 78 Fed. Reg. 66 , 700, 66,703 (Nov. 6, 201 3 ) , available at http: //www.gpo.gov / fdsys /pkg/FR

- 2013-Il-06/pdf / 20 1 3

- 26644.pdf
. 3 Testing of Certain High Production Volume Chemicals; Third Group of Chemicals, 76 Fed. Reg. 65,385 , 65 , 396 (Oct. 21, 20 11) ("In this final rule , EPA will not require the submission of equivalence data (i.e. , data demon strating that the chemical s ubstanc e is eq uivalent to the chemical sub stance actuall y being tested) as a condition for approval of yo ur exemption. " ) , available at http: //www.gpo.gov/fdsys/pkg/FR

2011- I 0-21 /pdf /20 11

-27227.pdf
. 4 40 C.F.R. § 790
. 87(a). The Chemical Company • 44 Southwest Ave. Jamestown, RI 02835 • 401.423.3100 www.thechemco.com