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~; SOCMA 

Society of Chemical Manufacturers &Affiliates 

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February 3, 2012 puipuipiA2 o iquuuupiiiuupni,iuu~ 

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 Whom It May Concern: 

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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 MEA Triazine Consortium . 

The consortium will 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 MEA Triazine Consortium are: 

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 MEA Triazine Consortium 

is attached for reference. 

For further information concerning this consortium or 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 

MEA Triazine Consortium 

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3wib3a MA N DA 1/A A~ ~SSC~~`jA , 

CUNSULTANTS,lN SC/ENCE, ,TECHNOLQ.fiYAND REGULATORYAFFAIRS 

6860 W. DALLAS PARKWAY, SUITE 200, PL4N0, 7X ~5024 

Telephone : 972-265-7924 -Fax: 972-265-7942 ~ E-MAIL: Madhu @Mandava.com N 

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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 to join 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 inform of 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 

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CONTAINS NO CLi