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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 

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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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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, LLC 2

• 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. 2MC 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.P. 3 CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION U.S. Environmental Protection Agency November 4, 2014 Page 3
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.p. 4 CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION U.S. Environmental Protection Agency November 4, 2014 Page 4

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. 5 Moreover, 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

5 40 CFR 790.55(b)(3).