CBIC Control ippber 

361886 

GREENWICH CHEMICAL CONSULTING, INC. 

3300 PGA BOULEVARD • SUITE 635 

PALM BEACH GARDENS, FL 33410 

TELEPHONE 561.578.8110 

FACSIMILE 561.578.8120 

September 22, 2014 TN, 

CONTAINS NO CONFIDENTIAL 

BUSINESS INFORMATION 

By UPS 

OPPT Document Control Office 

EPA East Building 

Room E6428 

U.S. Environmental Protection Agency 

1201 Constitution Ave., NW 

Washington, DC 20004 

Attention: Docket ID Number: EPA-HQ-OPPT-2009-0112 

40 CFR 799.5089 

Re: Exemption Application Submitted by Moris Technology Center, LLC as Part 

of the PCBTF Testing Consortium under the TSCA Section 4(a)(1)(B) Test 

Rule Testing of Certain High Production Volume Chemicals; Third Group 

Benzene, 1-chloro-4-(trifluoromethyl)- 

CAS RN 98-56-6 

(para-Chlorobenzotrifluoride (PCBTF)) 

Docket ID Number: EPA-HQ-OPPT-2009-0112 

40 CFR 799.5089 

Dear Sir/Madam: 

Through this letter, Moris Technology Center, LLC (Moris Technology Center or the 

Company) submits to the U.S. Environmental Protection Agency (EPA or the Agency) this 

application for an exemption from testing under Section 4 of the Toxic Substances Control 

Act (rscA). This exemption application is' ibnitted for the chemical substance, benzene, 1- 
p. 2 

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U.S. Environmental Protection Agency 

September 22, 2014 

Page 2 

chloro-4-(trifluoromethyl)- [CAS RN 98-56-6], under the Agency's Toxic Substances Control 

Act (rscA) Section 4(a)(1)(B) test rule published on October 21, 2011. 1For purposes of this 

letter, the chemical substance, benzene, 1-chloro-4-(trifluoromethyl)-, is herein referred to as, 

PCB IL 

Moris Technology Center files this request in accordance with this final rule and the 

regulations set forth at 40 CFR 790.80 - 790.99 and 799.5089. 

I. General Background 

Greenwich Chemical Consulting, Inc. (Greenwich Chemical Consulting) functions and 

operates as the panel manager for and representative of the PCBTF Testing Consortium. 

Therefore, Greenwich Chemical Consulting submits this letter on behalf of Moris Technology 

Center as a new member of the PCBTF Testing Consortium. 

This final test rule addresses 15 high production volume (HPV) chemicals that went 

unsponsored under the Agency's voluntary HPV Chemical Challenge Program. One of the 15 

chemicals identified in the rule is PCBTF. The Agency has issued this test rule under its TSCA 

Section 4(a)(1)(B) authority based on its belief that HPV compounds, including PCBTF, are 

"produced in substantial quantities; there is or may be substantial human exposure to them; 

existing data are insufficient to determine or predict their health and environmental effects; 

and testing is necessary to develop such data."' 

In general, the final rule identifies the following two studies on PCBTF: 

• Ready Biodegradation 

• Aquatic Toxicity Testing (toxicity to plants (algae)) 

Required Information for this Exemption Application 

A. 790.82(a) 

Identity of the test rule, the chemical identig, and the CAS Registg Number of the test substance on which 

the colication is based. 

Testing of Certain High Production Volume Chemicals; Third Group 

[76 Fed. Reg. 65385; October 21, 2011] 

Benzene, 1-chloro-4-(trifluoromethyl)- [CAS RN 98-56-61 

176 Fed. Reg.65385. 

276 Fed. Reg.65387. 
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U.S. Environmental Protection Agency 

September 22, 2014 

Page 3 

B. 790.82(b) 

The Jpecilic testing requirement(s) from which an exemption is sought and the basis for the exemption request. 

This exemption application is being submitted for the ready biodegradation test and aquatic 

toxicity testing (toxicity to plants (algae)) on PCBTF as required under this test rule at 40 CFR 

799.5089 and as subsequently approved by EPA during the study plan review process. 

The primary basis for this exemption application is that these two studies have already been 

completed through testing already sponsored by the PCBTF Testing Consortium.' In addition, 

Moris Technology Center understands that EPA is not interested in receiving duplicative 

testing. The Company, as part of its membership in the PCBTF Testing Consortium, will be 

reimbursing the original members for its share of the group's original testing and 

administrative costs incurred under the test rule. 

C. 790.82(c) 

Name, address, and telephone number of applicant.4 

Moris Technology Center, LLC 

9 Ilene Court, Unit #2 

Hillsborough, NJ 08844 

Telephone: (908) 262-7364 

D. 790.82(d) 

Name, address, and telephone number of appropriate individual to contact for further information. 

Mr. John V. Massingale 

Greenwich Chemical Consulting, Inc. 

3300 PGA Boulevard, Suite 635 

Palm Beach Gardens, FL 33410 

Telephone: (561) 578-8110 

Facsimile: (561) 578-8120 

E-mail: john@graicom 

3The final reports for the algae and biodegradation studies were completed and issued on March 19, 2013 and 

April 4, 2013, respectively. In April 2013, the PCBTF Testing Consortium timely submitted these fmal test reports 

to EPA. The Agency subsequently determined that the algae study was inadequate and required that the study be 

re-conducted for purposes of the TSCA Section 4 test rule. This second algae study is in the development stage 

in conjunction with Harlan Laboratories Ltd. and EPA. 

4Company contact person: Mr. Gary Jones (Vice President); telephone (215) 264-4803. 
p. 4 

CONTAINS NO CONFIDENTIAL 

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U.S. Environmental Protection Agency 

September 22, 2014 

Page 4 

E. 790.99 

Certification 

I understand that if this application is granted before the reimbursement period described in 

section 4(c)(3)(B) of TSCA expires, I must pay fair and equitable reimbursement to the person 

or persons who incurred or shared in the costs of complying with the requirement to submit 

data and upon whose data the granting of my application was based. 

Moris Technology Center, as a member of the PCBTF Testing Consortium, therefore, submits 

this exemption application in accordance with the fmal TSCA Section 4(a)(1)(B) test rule 

described herein and the regulations set forth at 40 CFR 790.80 - 790.99 and 799.5089. 

For all questions and comments concerning this matter, please contact the PCBTF Testing 

Consortium's panel manager: 

Mr. John V. Massingale 

Greenwich Chemical Consulting, Inc. 

3300 PGA Boulevard, Suite 635 

Palm Beach Gardens, FL 33410 

Telephone: (561) 578-8110 

Facsimile: (561) 578-8120 

E-mail: john@grcci.com 

Sincerely, 

John V. Massingale 

Panel Manager 
P. 5 

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September 22, 2014 

Page 5 

cc: Brenntag North America, Inc. 

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EMCO Chemical Distributors, Inc. 

Greenchem Industries, LLC 

Kowa American Corporation 

Makhteshim Agan of North America, Inc. 

MC International, LLC (Miami Chemical) 

Moris Technology Center, LLC 

Nexeo Solutions LLC 

Silver Fern Chemical, Inc. 

Special Materials Company 

Superior Oil Company, Inc. 

Univar USA, Inc. 

Valspar CorpOration 

Mr. John Schaeffer — U.S. Environmental Protection Agency 

Ms. Heather Njo — U.S. Environmental Protection Agency