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 CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION 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. 1 For 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. 2 76 Fed. Reg. 65387.P. 3 CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION 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. 4 Company contact person: Mr. Gary Jones (Vice President); telephone (215) 264-4803.

### p. 4 CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION 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 ManagerP. 5 CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION U.S. Environmental Protection Agency September 22, 2014 Page 5



### cc: Brenntag North America, Inc. Chemsynergy, Inc. China Specialty Chemical Company, Ltd. 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