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GREENWICH CHEMICAL CONSULTING, INC. 

3300 PGA BOULEVARD • SUITE 635 

PALM BEACH GARDENS, FL 33410 

TELEPHONE 561.578.8110 

FACSIMILE 561.578.8120 

November 4, 2014 %sows' 

_ 01 l'eCk CONTAINS NO CONFIDENTIAL 

BUSINESS INFORMATION 

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By Federal Express CBIC Control Number 

362513 

OPPT Document Control Office 

U.S. Environmental Protection Agency 

EPA East Building 

Room E6428 

1201 Constitution Ave., NW 

Washington, DC 20004 

Attn.:40 CFR 799.5089 

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

Re: Extension Request by the PCBTF Testing Consortium under the TSCA 

Section 4 Test Rule on the Testing of Certain High Production Volume 

Chemicals; Third Group 

Benzene, 1-chloro-4-(trifluoromethyl)- 

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 (the Consortium), Greenwich Chemical 

Consulting, Inc. (Greenwich Chemical Consulting) submits to the U.S. Environmental 

Protection Agency (EPA or the Agency) an extension request for additional time to conduct 

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U.S. Environmental Protection Agency 

November 4, 2014 

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the algae study on the chemical substance, benzene, 1-chloro-4-(trifluoromethyl)- [CAS RN 

98-56-6] which is currently subject to a Toxic Substances Control Act (TSCA) Section 4 test 

rule.' For purposes of this letter, the chemical substance, benzene, 1-chloro-4- 

(trifluoromethyl)-, is herein referred to as, PCBTF. The Consortium files this request in 

accordance with this test rule and the regulations set forth at 40 CFR 790.55 and 799.5089. 

I. General Background 

Greenwich Chemical Consulting functions and operates as the panel manager for and 

authorized representative of the Consortium. Therefore, Greenwich Chemical Consulting 

submits this letter on behalf of the Consortium's 15 member companies identified below: 

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, LLC2 

• Moris Technology Center, LLC 

• Nexeo Solutions, LLC 

• Silver Fern Chemical, Inc. 

• Special Materials Company 

• Superior Oil Company 

• Univar USA, Inc. 

• Valspar Corporation 

This final 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 

on PCBTF: 

• 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 April 18, 2013. Based on EPA's review of the algae test report, 

the Agency concluded that the study was inadequate for purposes of the TSCA Section 4 test 

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

2 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. 
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rule and must be re-conducted. The Agency's conclusions were set forth in its letter of 

September 26, 2013. 

Extension Request 

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

test must be submitted to the Agency with the final report submitted by October 12, 2014. 

The Agency subsequently granted the PCBTF Testing Consortium's request dated November 

6, 2013 for a delay to the date by which the final report must be submitted. This date was 

December 12, 2014 which was granted by EPA in its response 

The PCBTF Testing Consortium is requesting an additional extension due to the fact that 

there has been a significant delay in the development of the final study plan because the 

substance's high volatility and low water solubility have presented a number of technical 

challenges which needed to be resolved among the laboratory, the Consortium, and EPA. 

Indeed, the original study plan that was submitted to EPA in January of this year resulted in a 

significant number of comments from the Agency. These comments were received in March. 

The Consortium then required additional time to review and respond to EPA's comments, as 

well as work with a laboratory to address these complex technical issues. Because of 

subsequent comments and questions raised by the laboratory, the Consortium was compelled 

to submit additional, follow up questions back to the Agency in August in order to obtain 

EPA's guidance on the conduct of the test. Due to a backlog, the Agency was delayed in 

responding to this request until October. It then took an additional month to work with the 

laboratory to develop the final study plan. The study plan has now been finalized and signed 

between the Consortium and the laboratory.' 

The laboratory expects that the experimental starting date will be in the second half of 

November with a draft report issued sometime in mid to late January. It is also quite possible 

that because of the substance's high volatility and poor water solubility, technical issues may 

arise in the course of the test which may require input from EPA in order to address and 

resolve. It is likely also that the holidays may cause delay. Therefore. the PCBTF Testing 

Consortium respectfully requests an extension through April 30, 2015. 

The Consortium understands that EPA will accept a schedule modification request if such a 

request is made in accordance with 40 CFR 790.55. Concurrent with this, die Agency stated 

the following in the final rule: 

A company that submits a letter of intent to test under the final rule and that 

subsequently anticipates difficulties in completing the testing by the deadline set 

forth in the final rule may submit a modification request to the Agency, pursuant to 

40 CFR 790.55. EPA will determine whether modification of the test schedule is 

appropriate... 4 

3 The study plan was signed by the Consortium on November 4, 2014. 

4 76 FecL Reg. 65397. 
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U.S. Environmental Protection Agency 

November 4, 2014 

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With respect to the requirements set forth at 40 CFR 790.55, The Consortium does not believe 

that the requested modification to the test schedule requested herein would "significantly alter 

the scope of the test[s] or significantly change the schedule for completing the test[s]" because 

it does not meet any of the conditions set forth at 790.55(b)(4)(i)-(iv) and further because it 

does not rise to the level of "significant" in terms of time. 5Moreover, this alleviates EPA from 

having to seek public comment before approving these modifications. 

The Consortium believes that this additional extension to the test schedule is a minor schedule 

modification and would not prevent the Agency from meeting its statutory obligations under 

TSCA Section 4 or its voluntary commitments under either the HPV Chemical Challenge 

Program or the OECD HPV SIDS Program. In addition, this schedule modification request 

does not significantly change the schedule for completing the tests as described in 790.55. 

The Consortium thanks the Agency for its consideration in this matter. For all questions, 

comments, and determinations 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@grcci.com 

Sincerely, 

John V. Massingale 

Principal 

cc: Mr. John Schaeffer — U.S. EPA 

PCBTF Testing Consortium 

540 CFR 790.55(b)(3).