p. 1 

0Pff-2-W7-o-:)31 SOCMA ~, .7CIt"' :~ G3 tiA ,C'11 "CB) r'~;~f"1~1ldCilll`E!r ~ 1'oT~d~lii~d' .` 

333 66o 

March 7, 2011 

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: 

N 0 

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 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 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. 

GE Betz, Inc. doing business as GE Water & Process Technologies 

Momentive Specialty Chemicals Inc. 

Q2 Technologies, LLC 

Stepan Company 

Syrgis PChem 

CONTAINS NO C2! 

~~che~ Scowd«j~~ 

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p. 2 

SOCMA 

A copy of each company'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(a~socma .com. 

Sincerely, 

MEA Triazine Consortium 

C. Tucker Helmes, Ph .D.' 

Executive Director 

~+s ChemStetivards' 

erPOCS,vaa SOCMA d85(P'1 St l'J~'J S i~tC 7C3U " Vya~lunc:in~ ~'~C' 7~;(I~F S R I ~ 'l . T: I -) (1 , 1`" -,, 
Baker Pstroli6 

February 11, 2011 

Dr. C. Tucker Helmes 

Senior Director 

Society of Chemical Manufacturers and Affiliates 

via helmest a~socma.com 

12645 West Airport Blvd. 

Sugar Land, Texas 77478 

P.O. Box 5050 

Sugar Land, Texas 77487-

5050 

Tel 281-276-5400 

Fax 281-275-7385 

Subject: 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) 

Dear Dr. Helmes, 

Please accept this letter as Baker Petrolite Corporation's (a Baker Hughes company) 

declaration of its commitment and member support of the SOCMA managed, MEA Triazine 

Consortium. Our understanding of this consortium's purpose is to respond to the recently 

published and aforementioned TSCA Section 4 Test Rule. 

We look forward to working with you and the other members of this Consortium in addressing 

this testing obligation . 

Sincerely, 

Baker Petrolite Corporation 

Miles R. Rhea I Sr. Mgr., Global Regulatory Affairs 

Baker Hughes I Regulatory Affairs/Western and Eastern Hemisphere/Shared Services 

Office: 281 .275.7257 1 Fax: 281 .275.7385 

Cell: 281 .380.21461 miles.rheaftbakerhuahes.com 

htta:l/www.bakerhughes.cxxn I Advancing Reservoir Performance 
~ r~ecnr,a, .°~s"- 

February 08, 2011 

Dr. C. T. Helmes 

Senior Director 

Society of Chemical Manufacturers and Affiliates 

1850 M Street, NW Suite 700 

Washington, DC 20036 

Tel 202-721-4154 / Fax 202-296-8120 

Dear Tucker, 

Champion agrees to participate in MEA Triazine Consortium to meet TSCA Section 4 Test Rule on 

1,3,5-Triazine-1,3,5(2H,4H,6H)-triethanol (CAS# 4719-04-4) which was published on Federal Register 76 (5), 1067-1093, January 7, 2011 

Should you have any questions, please feel free to contact me. 

Sincerely yours, 

~~l-7L-c.(J 

John P. Sepesi, D.V.M. 

Director Global Product Stewardship .J a l~ 

3200 Southwest Freeway, Suite 2700 ~ Houston, TX 77027 

PO Box 27727 - Houston, TX 77227-7727 - P (713) 627-3303 - F (713) 627-9353 - CHAMP TECH.COM 
Document Control Officer (7407 M) 

Office of Pollution Prevention and Toxics (OPPT) 

Environmental Protection Agency 

1200 Pennsylvania Avenue 

Washington, DC 20430-0001 

Attention: TSCA Section 4 

Docket ID Number EPA-HQ-OPPT-2007-0531 

Water & Process Technologies 

Robin Deitch 

Regulatory Specialist 

4636 Somerton Rood 

Trevose, PA 19053 

USA 

T 215-953-5657 

F 215-953-2447 

robin.deitch@ge.com 

February 18, 2011 

RE: Testing of Certain High Production Volume Chemicals; Second Group of Chemicals. 

Register 76 (5), 1067-1093, January 7, 2011. 

1,3,5-Triazine-1,3,5(2H,4H,6H)-Triethanol (CAS No 4719-04-4) 

Dear Sir or Madam: 

Federal 

GE Betz, Inc. doing business as GE Water & Process Technologies, agrees to participate as a member of the MEA Triozine Consortium for purposes of satisfying the testing requirements of the subject test rule. 

The consortium is formed and managed under the Society of Chemical Manufacturers and Affiliates (SOCMA). The technical contact is Dr. Tucker Helmes and he can be reached at (202) 721-4154 or helmest@socma.com. 

Sincerely, 

Robin Deitch 

Regulatory Specialist 
p. 6 

MQMENTI'VE" 

February 18, 2011 

Momentive Specialty Chemicals Inc . 

180 East Broad Street 

Columbus, OH 43215 

momentive .com 

Dr. C. T. Helmes 

Senior Director 

Society of Chemical Manufacturers and Affiliates 

1850 M Street, NW Suite 700 

Washington, DC 20036 

Via Email; helmestgsocma.com 

RE : Testing of Certain High Production Volume Chemicals ; Second Group of Chemicals . 

Federal Register 76 (6),1067-1093, January 7, 2011 . 

1,3,5-Triazine-1,3,5(2H,4H,6H)-Triethanol (CAS No. 4719-04-4) 

Dear Tucker, 

At this time, Momentive Specialty Chemicals Inc. plans to participate the SOCMA managed 

Consortia for this test rule . 

If additionaUP&Rhation is needed, please feel free to contact me. 

Sydney Lindquist 

N.A. Director Product Safety & Regulatory Compliance 

Momentive specialty Chemicals Inc. " 180 E. Broad St . . Columbus, OH 43212 " (614)225-4778 

E-maii : sydney yndquistOmom nYng~m 
Technologies 

Letter of Intent 

March 2, 2011 

Dr. C. T. Helmes 

Society of Chemical Manufacturers and Affiliates 

1850 M Street, NW Suite 700 

Washington, DC 20036 

Dear Dr. Helmes, 

It is QZ Technologies, LLC intention to participate in the MEA Triazine Consortium as discussed in your e-mail of February 23, 2011 . 

, . 

Rega~ds, \ 

, 

. 

Hugo LO zaro 

Presiderrtl 

/ 

14729 Highway 105 West #200 e Montgomery " Texas " 77356 
. 

Stepan 

February 16, 2011 

Stepan Company 

C.T. Helmes, Ph.D. 

Senior Director 

Society of Chemical Manufacturers and Affiliates 

Washington, DC 20036 

Subject: MEA Triazine TSCA Test Rule 

Dear Dr. Helmes: 

Northfield, Illinois 60093 

Telephone 847 446 7500 

Stepan Company agrees to join the MEA Triazine Consortium 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 . 

Lela Jovanovich, Ph.D. will be Stepan's contact. She can be reached at (847) 501-2272 or at 

IjovanovichQstepan.com. 

V1 G 

at Hartman 

Global Director Regulatory Affairs 
SYRGISO ..=~,.~- 

PERFORfAAWCE CHEMICALS 

February 24, 2011 

C . Tucker Helmes, Ph.D. 

SOCMA 

Executive Director 

MEA Triazine Consortium 

1850 M Street, NW Suite 700 

Washington, DC 20036 

Dear Dr. Tucker: 

Please allow this letter to serve as notification that my company, Syrgis PChem will be 

participating in the cost sharing consortium to test 1,3,5- Triazine-1,3,5 (2H,4H,6H)-

triethanol for Toxicity to plants(algae) as required to satisfy the testing requirements of 

the TSCA Section 4 Docket ID Number EPA-HQ-OPPT-2007-0531 . 

If you have any questions please do not hesitate to contact me at 936-544-5174 . 

Sincerely, 

Lois Waits 

Senior Vice President of Operations 

General Manager 

P.O . Box 977 " 3985 U.S . Highway 287 North " Lotexa,'fX 75849 

7eiephone:936-534-5174 " fox-. 936-544-4958 " www.syrgispccom 

ISO 9001 Cerlified