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AALBEMARLEO OPP r- 200- 7 053/ 

Albemarle Corporation 

451 Florida Street Telephone: 225-388-8011 

Baton Rouge, Louisiana 70801-1765 Facsimile: 225-388-7686 

March 8, 2011 

Overnight Courier 

REiZ MAR 15 2011 

RECEIVED 

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Document Control Office(7407M) 

Office of Pollution Prevention and Toxics (OPPT) 

Environmental Protection Agency 

1201 Constitution Ave. 

Washington, DC 20004-3302 

Attn: TSCA Section 4 

40 CFR Part 799.5087 

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In compliance with the final rule, "Testing of Certain High Production Volume Chemicals; Second 

Group of Chemicals", 76FR1067, January 17, 2011, Albemarle Corporation submits this Letter of 

Intent to test for "Benzenediamine, ar,ar-diethyl-ar-methyl=", CAS number 68479-98-1 . Albemarle 

Corporation intends to conduct the required testing in conjunction with Lonza Inc. Lonza will be 

submitting a separate letter of intent to test. The two companies, together, plan to conduct and/or 

submit testing to meet all the required endpoints as outlined in the final rule and detailed below. 

The companies plan to conduct the testing for the following endpoints . 

A3 - Vapor Pressure 

A5 - Water Solubility 

C1 - Test Group 1 

Acute Toxicity to Fish 

Acute Toxicity to Daphnia 

The companies plan to request modification to the testing requirements for the following endpoint. 

F1 - Mammalian toxicity - repeated dose/reproduction/developmental . 

The repeated dose/reproduction/developmental test is based on the Agency's requirement for 

information on the developmental/reproductive endpoint under the HPV program . The data 

requirements of the HPV program are modeled after the Organization for Economic and 

Community Development (OECD) Screening Information Dataset (SIDS). OECD considers the 

developmental/reproductive endpoint to be fulfilled with either the screening study listed in EPA's 

test rule or a 90 day repeated dose study coupled with results from a prenatal developmental 

study. Multiple mammalian repeated dose studies ranging in length from 28 days to two years 

with histopathological examination of the male and female reproductive tracts have been 

performed on this chemical. The reproductive tract was not a target organ . Additional repeated 

dose testing would be redundant. A rat prenatal developmental is considered the preferred 

testing to fulfill the reproductive/developmental endpoint. The proposed study would be 

performed according to OPPTS 870.3700/OECD 414. A copy of the 90-day repeated does study 

will be submitted along with the protocol for the rat prenatal test in the request for modification of 

the testing requirements. 

CONTAINS NO CB! 
The companies believe that sufficient data exists to meet the following endpoints . The existing 

test data consists of data submitted to ECHA in compliance with REACH by the consortia for this 

chemical in Europe. Albemarle will submit the existing data and the rational for why it meets the 

endpoints in a separate letter. 

A1 - Melting point 

A4 - n-OctanoUWater Partition Coefficient 

C1 -Test Group 1 

Toxicity to Plants (algae) 

E1 - Mammalian toxicity - Genotoxicity (Bacterial Reverse Mutation Test) 

E2 - Mammalian toxicity - Genotoxicity (Chromosomal Damage) 

The contact information for the corporation and contact person filing this letter of intent to test is 

provided below. The Albemarle contact named below will be the primary contact for this testing . 

Kim Boudreaux 

Albemarle Corporation 

451 Florida Street 

Baton Rouge, LA 70801-1765 

Telephone 225-388-7776 

Fax 225-388-7046 

Email: Kim. Boudreaux@albemarle.com 

The contact information for Lonza Inc, is provided below. 

Robert Sloan 

Lonza Inc . 

90 Boroline Road 

Allendale, NJ 07401 USA 

Telephone 201-316-9365 ` 

Fax 201-696-3569 

Email: bob.sloan@lonza.com 

If you have any questions, please contact me and at the number provided above . 

Sr. Advisor, Regulatory Affairs