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# ~ ; SOCMA Society of Chemical Manufacturers &Affiliates



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Document Control Office (DCO) (7407 M) Office of Pollution Prevention and Toxics (OPPT) Environmental Protection Agency (EPA) EPA East Building, Room E6428 (202-564-8930) 1201 Constitution Ave., NW Washington, DC 20460 Attention: TSCA Section 4 40 CFR 799

.5087 Docket ID Number EPA-HQ-OPPT-2007-0531 To WhomIt May Concern: tN a r N t77 "0 ("n , -c C-) co --+ ;''n -v N 

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RE: Testing of Certain High Production Volume Chemicals; Second Group of Chemicals. Federal Register 76 (5), 1067-1093, January 7, 2011 . 1,3,5 -Triazine-1,3 5(2H 4H,6H)-Triethanol (CAS No. 4719-04-4) On behalf of the companies listed below, SOCMA submits this revised letter of intent to comply with the subject test rule for 1,3,5-triazine-1,3,5(2H,4H,6H)-triethanol (CAS No. 4719-04-4), also known as MEA Triazine . These companies have agreed to participate in a cost-sharing consortium, known as the MEA Triazine Consortium, for purposes of satisfying the testing requirements of this test rule. The consortium is formed and managed under the Society of Chemical Manufacturers and Affiliates (SOCMA) . The purpose of this revised letter of intent is to update the previously revised letter of intent submitted on November 22, 2011 by adding Conlen Surfactant Technology to the list of companies agreeing to participate in the MEATriazine Consortium . The consortiumwill conduct the following study in compliance with the test rule and according to current OPPTS Harmonized Guidelines : Toxicity to Plants (Algae) : ASTM E 1218-04e' The participating member companies of the MEATriazine Consortiumare: Baker Petrolite Corporation (a Baker Hughes company) Champion Technologies, Inc. Clearwater International, LLC Conlen Surfactant Technology, Inc. GE Betz, Inc. doing business as GE Water & Process Technologies Huntsman Petrochemical Corporation Momentive Specialty Chemicals Inc.

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Q2 Technologies, LLC Stepan Company Syrgis PChem A copy of Conlen Surfactant Technology's letter of intent to participate in the MEATriazine Consortium is attached for reference. For further information concerning this consortiumor its plans to satisfy the requirements of the subject test rule, please contact the undersigned directly at 202-721-4154 or helmest(o)-socma .com Sincerely,

C . Tucker Helmes, Ph .D. Executive Director MEATriazine Consortium

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# MAN DA 1/A A~~SSC~~`jA , CUNSULTANTS,lNSC/ENCE, ,TECHNOLQ .fiYAND

REGULATORYAFFAIRS 6860W . DALLAS PARKWAY, SUITE 200, PL4N0, 7X ~5024 Telephone: 972-265-7924 -Fax: 972-265-7942 ~ E-MAIL: Madhu@Mandava.com N N rn C :) 70 January IV, 20 12 

### Dr . Tucker Helmes SOCIETY OF CHEMICAL MANUFACTURERS & AFFILIATES {SC?CMA} 1850 lttt Street NW, Suite 700 Washington, DC 20036 Subject : MEA-TRIAZINE Consortium Dear Dr . He(mes, On behalf of Conlen Surfactant Technology . Inc. (CST), please be informed that CST, as a manufacturer of HPV chemicals, intends tojoin the MEA-TRIAZINE task force for the testing of certain High Production Volume (HPV) Chemicals, unsponsored second group of chemicals . Please send the participation agreement to us and informof any other needed information, requirements and associated fees . We are enclosing a copy of the authorization letter designating us as agents to represent CST. 

### Please contact me at 972-265-7924 or via e-mail at madhu@mandava .com, you should have any questions. Thank you for your kind assistance. Best Regards, Madhu Mandava Mandava Associates, LLC Agent for CST, Inc. Enclosure Cc: Glen Walden - CST N 

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