1 

### Njo, Heather

From: Schaeffer, John

Sent: Wednesday, August 06, 2014 3:42 PM

To: Jessica Fegan; Jeff Vanderlip

Cc: 'Frank Farish'; Mattheisen, Mike; Njo, Heather; Lewis, Paul

Subject: RE: Exemption Request

Jessica, Yes.

Jeff, Please let your folks at Tiarco know that the exemption grant to Connection Chemical for CASRN 127

‐ 68

‐ 4 was a

mistake on our (EPA’s) part. The exemption request by Connection Chemical (and subsequent grant) was actually for

CASRN 144

‐ 62

‐ 7. Unfortunately, our docket does not allow us to remove items once entered. Let me apologize again,

this time to both companies, for any confusion that this has caused.

Best regards,

John

John Schaeffer

Senior Biologist

USEPA/OPPT/CCD/CITB

1201 Constitution Ave, NW

Washington, DC 20460

Mail Code: 7405M

Phone: 202-564-8173

From: Jessica Fegan [mailto:jessica@connectionchemical.com]

Sent: Wednesday, August 06, 2014 3:17 PM

To: Schaeffer, John

Cc: 'Frank Farish'

Subject: RE: Exemption Request

Hi John,

It was brought to our attention today that the letter Connection Chemical received from the EPA dated 6/4/14 which

referenced our testing exemption for the incorrectly cited substance CASRN 127

‐ 68

‐ 4 is posted under docket # EPA

‐ HQ

‐

OPPT

‐ 2009

‐ 0112. Please see below.

Is there any way to remove this letter and our mistakenly granted exemption from the docket? Tiarco Chemical, the

company that paid for the testing saw our “exemption” and is now thinking we are a competitor and is expecting us to

pay them. We need explanation to assure them we are not involved in this, we are not a competitor, and we never

applied for exemption for CASRN 127

‐ 68

‐ 4.

Can you help?

Thank you,

Jessica2 Regards,

Jessica Fegan

Director of Quality & Operations

Connection Chemical, LP

126 South State Street, Suite 200

Newtown, PA 18940

(Phone) 215

‐ 493

‐ 4240

(Direct) 215

‐ 642

‐ 8706

(Fax) 215

‐ 493

‐ 38013 From: Jessica Fegan [ mailto:jessica@connectionchemical.com ]

Sent: Thursday, June 19, 2014 2:15 PM

To: 'Schaeffer, John'

Subject: RE: Exemption Request

Great! Thanks, John...I thought I did something wrong!

Regards,

Jessica Fegan

Director of Quality & Operations

Connection Chemical, LP

126 South State Street, Suite 200

Newtown, PA 18940

(Phone) 215-493-4240

(Direct) 215-642-8706

(Fax) 215-493-3801

From: Schaeffer, John [ mailto:Schaeffer.John@epa.gov ]

Sent: Thursday, June 19, 2014 1:20 PM

To: Jessica Fegan

Cc: Mattheisen, Mike; Njo, Heather; Lewis, Paul; Gorder, Chris; 'Frank Farish'; 'Phil'

Subject: RE: Exemption Request

Jessica,

You are correct, we have had more than a few applications for both of these substances and incorrectly cited the 127

‐

68

‐ 4 chemical in our response to you. A letter (approving your conditional exemption request for 144

‐ 62

‐ 7) will be

mailed to you shortly.

My apologies.

Best regards,

John

John Schaeffer

Senior Biologist

USEPA/OPPT/CCD/CITB

1201 Constitution Ave, NW

Washington, DC 20460

Mail Code: 7405M

Phone: 202-564-8173

From: Jessica Fegan [ mailto:jessica@connectionchemical.com ]

Sent: Thursday, June 19, 2014 12:53 PM

To: Schaeffer, John

Cc: Mattheisen, Mike; Njo, Heather; Lewis, Paul; Gorder, Chris; 'Frank Farish'; 'Phil'

Subject: RE: Exemption Request

Hi John,4 Thank you for your prompt response.

I think there may be some confusion. Our exemption request was for CAS 144

‐ 62

‐ 7 (Oxalic Acid Dihydrate also known as

Ethanedioic Acid) Testing of certain HPV Chemicals; Second Group of Chemicals Federal Register, Vol. 76, No. 5, January

7, 2011. This was under Docket EPA

‐ HQ

‐ OPPT

‐ 2007

‐ 0531.

We do not handle the chemistry (CAS 127

‐ 68

‐ 4) referenced in the PDF you forwarded.

Can you please look into this?

Regards,

Jessica Fegan

Director of Quality & Operations

Connection Chemical, LP

126 South State Street, Suite 200

Newtown, PA 18940

(Phone) 215-493-4240

(Direct) 215-642-8706

(Fax) 215-493-3801

From: Schaeffer, John [ mailto:Schaeffer.John@epa.gov ]

Sent: Thursday, June 19, 2014 12:25 PM

To: Jessica Fegan

Cc: Mattheisen, Mike; Njo, Heather; Lewis, Paul; Gorder, Chris; 'Frank Farish'; 'Phil'

Subject: RE: Exemption Request

Jessica,

You should have received it in the mail.

Attached is a pdf of the mailed letter.

Best regards,

John

John Schaeffer

Senior Biologist

USEPA/OPPT/CCD/CITB

1201 Constitution Ave, NW

Washington, DC 20460

Mail Code: 7405M

Phone: 202-564-8173

From: Jessica Fegan [ mailto:jessica@connectionchemical.com ]

Sent: Thursday, June 19, 2014 11:57 AM

To: Schaeffer, John

Cc: Mattheisen, Mike; Njo, Heather; Lewis, Paul; Gorder, Chris; 'Frank Farish'; 'Phil'

Subject: RE: Exemption Request

Hello John,5 We submitted our exemption request through CSPP on June 3 rd

. I am unfamiliar with what happens next. Can you please

tell me when we should expect to hear a response from the EPA and how they will contact us (through CSPP, email,

USPS, etc.)?

Regards,

Jessica Fegan

Director of Quality & Operations

Connection Chemical, LP

126 South State Street, Suite 200

Newtown, PA 18940

(Phone) 215-493-4240

(Direct) 215-642-8706

(Fax) 215-493-3801

From: Jessica Fegan [ mailto:jessica@connectionchemical.com ]

Sent: Tuesday, June 03, 2014 2:14 PM

To: 'Schaeffer, John'

Cc: 'phil@connectionchemical.com'; 'Frank Farish'; 'Mattheisen, Mike'; 'Njo, Heather'; 'Lewis, Paul'; 'Gorder, Chris'

Subject: RE: Exemption Request

Hi John,

Our exemption request has been submitted electronically. Mike Mattheisen did help me with some of my

questions. Since this was my first time using the program, I’m not 100% confident I did everything correctly; if you are in

need of any more information, please let me know.

Regards,

Jessica Fegan

Director of Quality & Operations

Connection Chemical, LP

126 South State Street, Suite 200

Newtown, PA 18940

(Phone) 215-493-4240

(Direct) 215-642-8706

(Fax) 215-493-3801

From: Jessica Fegan [ mailto:jessica@connectionchemical.com ]

Sent: Friday, May 30, 2014 8:32 AM

To: 'Schaeffer, John'

Cc: 'phil@connectionchemical.com'; 'Frank Farish'; 'Mattheisen, Mike'; 'Njo, Heather'; 'Lewis, Paul'; 'Gorder, Chris'

Subject: RE: Exemption Request

Good morning John,

Thanks for your prompt reply. Attached please find the PDF of our exemption request.

Hopefully I will be able to confirm our electronic submission shortly. If you have any questions or need more

information, please contact me.6 Regards,

Jessica Fegan

Director of Quality & Operations

Connection Chemical, LP

126 South State Street, Suite 200

Newtown, PA 18940

(Phone) 215-493-4240

(Direct) 215-642-8706

(Fax) 215-493-3801

From: Schaeffer, John [ mailto:Schaeffer.John@epa.gov ]

Sent: Friday, May 30, 2014 6:39 AM

To: Jessica Fegan

Cc: phil@connectionchemical.com ; 'Frank Farish'; Mattheisen, Mike; Njo, Heather; Lewis, Paul; Gorder, Chris

Subject: RE: Exemption Request

Jessica, good morning.

Thank you for the update. I’m sorry to hear you have been having difficulty with the CDX. I am unfamiliar with the Small

Business Compliance Program, but will see what I can find out. In the meantime, you can send me a pdf of your

exemption request and our office can respond to it as appropriate.

Best regards,

John

John Schaeffer

Senior Biologist

USEPA/OPPT/CCD/CITB

1201 Constitution Ave, NW

Washington, DC 20460

Mail Code: 7405M

Phone: 202-564-8173

From: Jessica Fegan [ mailto:jessica@connectionchemical.com ]

Sent: Thursday, May 29, 2014 5:34 PM

To: Schaeffer, John

Cc: phil@connectionchemical.com ; 'Frank Farish'

Subject: Exemption Request

Dear John,

My colleague, Phil Kiefer, has been in touch with you regarding Oxalic Acid testing under TSCA Section 4.

We would like to submit an exemption request. I have signed up for CDX, but the program is having trouble validating

my electronic signature. I have been in touch with the help desk and we are trying to resolve the issue.

In the meantime, I just wanted to make you aware of our intentions. Betty Barnes of Region Three’s Office of

Enforcement, Compliance & Environmental Justice has advised me to send our self

‐ disclosure document to the Chemical

Risk and Reporting Enforcement Branch in DC. If you know anything about self

‐ disclosure and the EPA’s Small Business

Compliance Program, please confirm that this is where we should send this document. There was some confusion over

where to send it because TSCA matters seem to have different protocol.7 Thank you for your guidance.

Regards,

Jessica Fegan

Director of Quality & Operations

Connection Chemical, LP

126 South State Street, Suite 200

Newtown, PA 18940

(Phone) 215-493-4240

(Direct) 215-642-8706

(Fax) 215-493-3801

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