### Ma y 16 , 2014

Director Tanya Hodge Mottley

National Programs Chemicals Division

Office of Pollution Prevention and Toxics

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

Dear Director :

The intent of this letter is to supply the additional information requested in your letter dated

May 5, 2014 concerning Nation Ford Chemical ’ s ( NFC ) desire to import Chloranil (CAS #

118

- 75

- 2) from two Chinese manufacturers and for NFC to be granted a waiver from the

Dioxin/Furan Test Rul e (D/F Test Rule) testing requirements. The following section re

- states

each of the eight (8) requests and then provides the information requested in italicized text or

references the attachment that contains the requested information. All confidential

i nformation is underlined.

Request 1. D etailed information on:

(a) H ow the $200,000 estimated cost for testing pursuant to t he D/F Test Rule was

determined:

Contained in Attachment 1.

(b) W hether NFC is contemplating a waiver in which alternative testing of each lot

wou ld be a condition of the waiver:

NFC’s desire is to follow the guidelines of the MOU, which requires certification from

the manufacturer that each shipment is LDC. Under the MOU, it is up to the foreign

manufacturer to determine how often to test.

(c) I f not, what type of alternative monitoring/sampling plan, if any, NF C contemplates

as a condition of the waiver:

I f following the guidelines in the MOU is not acceptable, NFC would be willing to have

SGS test a composite sample of every lot using the E VDI3499 test method. Only

LDC would be allowed to be shipped. This plan would add about $0.08/lb of C hloranil

for the 5 MT lots.

(d) Typical size of a lot:

Contained in At tachments 2 and 3.

Request 2. D etailed information on how the cost of testing affects NFC’s market

position on the product (VP23) from Chloranil , i.e.:

(a) C urrent product mark et value, e.g., dollars/pound :Chloranil

May 16 , 2014

Page 2 of 3

Confidential

(b) C urrent NFC product value :

Confidential

(c) NFC product value when manuf actured with Chloranil :

Confidential

(d) NFC product v alue with cost of testing added:

Confidential

Request 3. Chloranil analysis fro m one of the sources from China:

Contained in Attachment 4.

Request 4. D ata from the second source from Ch ina and also from Clariant:

Contained in Attachments 5 and 6, respectively.

Request 5. A n explanation of whether o r not the laborato ries for the China sources

(SGL Germany) use EP A

- approved analytical protocols:

The Chinese companies use the E VDI3499 test method, which we understand is the

most accepted international method for conducting this analysis.

Request 6. A n explanation of whether or not the laboratories used for Clariant use

EPA

- approved analytical protocols :

Clariant use s the E VDI3499 test method, which we understand is the most accepted

international method for conducting this analysis.

Request 7. E vidence to support the statement that Clariant is the sole source of

Chloranil for the US market:

It is common knowledge in the industry that Clariant is the sole source of C hloranil in

the US market. The EPA recognizes that there is no domestic pro duc tion in the

memo in Attachment 7( memo of April 14

, 2006, page 4 , yellow highlight ). Clariant is

the on ly company presently producing C hloranil that has done the testing required by

the EPA. The product they offer to the market is produced at a Clarian t facility in

India. The only countries know n to produce C hloranil are India and China. The only

recorded imports of C hloranil since Jan 2012 have been from Clariant in India. This

information is available from Zepol, an import bill of lading service re ceiving its

information from U.S. Customs. The Zepol results are contained in A tt achment 8

.

Request 8. I nformation on the protocol used by the Analytical Perspective laboratory

to analyze Chloranil :

Contain ed in Attachment 9.

If you have any question s or concerns regarding this information , please contact me at your

earliest convenience

.Chloranil

May 16 , 2014

Page 3 of 3

Sincerely,

Phillip McCarter

Vice President

encl: Attachments 1

- 9

cc: Jay Dickson, Nation Ford Chemical

Jo hn Dickson, Nation Ford Chemical

Steve Schmidt, Sun Chemical

Hiroshi Dodohara, US EPA