p. 1 

# AALBEMARLEO OPPr-200-7053/ 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 npP' . 

## I I MAR-9 AMII :5I 

# Ma-033,3 7/S~

Document Control Office(7407M) Office of Pollution Prevention and Toxics (OPPT) Environmental Protection Agency 1201 Constitution Ave. Washington, DC 20004-3302 Attn: TSCASection 4 40 CFR Part 799.5087 

# iu4~i`ryNiuq~iupui~0~i,wopi~i

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 thefollowing 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 programare modeled after the Organization for Economic and Community Development (OECD) Screening Information Dataset (SIDS) . OECDconsiders the developmental/reproductive endpoint to be fulfilled with either the screening study listed in EPA's test rule or a 90day repeated dose study coupled with results froma prenatal developmental study. Multiple mammalian repeated dose studies ranging in length from28 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. Arat prenatal developmental is considered the preferred testing to fulfill the reproductive/developmental endpoint. The proposed study would be performed according to OPPTS 870.3700/OECD414. Acopy 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 NOCB!The companies believe that sufficient data exists to meet the following endpoints. The existing

test data consists of data submitted to ECHAin compliance with REACH by the consortia for this chemical in Europe. Albemarle will submit the existing data and the rational forwhy 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 contactfor this testing. KimBoudreaux 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