Document dnYOdkb96gM6mQ23a97VnbEMe

Norman, Fox & Co. "Your Quality Source for Quality Chemical " 14970 Don Julian Road Industry, CA 91746 323 973.4900 Fax 323.973 4874 www norfoxdiem.com info@norfoxthemcom August 7.2017 Mr. Scott Pruitt Administrator. EPA Environmental Protection Agency 1200 Pennsylvania Avenue. N.W.. 1101A Washington, DC 20460 Ref': Request tor Relief Dear Administrator Pruitt Q cr rC--?. ' m ern cz CD CCD; O "r-k 54 H > -ki 3C O 5> rv> OD I am the president of Norman, Pox & Co., a small chemical distribution company located in the City of Industry. California, with operations in the City of Industry and in Vernon, California. We have roughly 50 employees. As part of its normal business. Norman, box & Co. purchases v arious industrial chemicals in bulk quantities from sources within the I S and also overseas. It then repackages these chemicals into smaller sizes for its various customers. Occasionally. Norman, f ox <V Co. also creates custom blends of compounds for its customers and also manufactures a few specialty products. I write to you to resolve a regulatory issue, which, on its face, makes little sense and adversely affects our operations with absolutely no environmental benefits whatsoever. I am aware that the I PA. under your stewardship, is engaged in a process to simplify regulations, especially, in cases when the regulations in question create perverse outcomes. I he specific chemical in question is p-chlorobcnzotrifluoride (PCBTF). Its Chemical Abstracts Service (CAS) number is 98-56-6. It is on the list of HPA's "High Production Volume" (HPV) list of compounds. In 201 1. Norman, Fox & t o. was purchasing PC Ml E from a domestic supplier. However, due to the cost difference between ihe domestic price and the cost that the company could get when importing the material directly. Norman. Fox & Co. decided to purchase the material directly from a Chinese supplier (who is the same supplier to our domestic supplier) beginning in 2012. Between 2012 through 2016. we imported/purchased u total of 906.091 pounds of PCBTF from China. Currently, we have switched back to purchasing PCM 11 from the higher-priced domestic supplier for the reason stated below It is our understanding that when we purchase the material from the domestic supplier (as we did in 2011 and as we do currently, we are in compliance with ISC A requirements. 1 lovvever. it is our understanding that when we directly import PCBTF from China (i.e., from the same source Page 1 of 2 Norman, Fox & Co. 'Your Quality Source tor Quality Chemic als" 14970 Don Julian Rood Industry. CA 91746 323.973 4900 Fax 323.9/3.48/4 www norfoxrhem tom info@norfoxchem rom Olilllt i St*uM<tKi - who supplies our domestic supplier), we might be non-complianl with TSCA. fhis makes no sense to us. Wc would like your help in rcsolv ing this TSCA regulatory conundrum. Simply, there should not he two different regulatory outcomes one compliant and the other potentially not when dealing with the same compound (PCB I f), simply due to the manner in which the material is procured. Clearly, the en\ ironmental outcomes are the same if we directly import the compound or if someone else imports it and we obtain it from them. I would be happy to discuss this further with your staff. Looking forward to a response from you on this matter. 1 can be reached by phone at 626-581-5600. or via email at shalpin a norfoxchem.com. Norman. Fox & Co. Page 2 of 2 14970 Dor Julian Rd * Industry, CA 91743 FCL206-956 AUG 1 7 AM \lr. Scott Pruitt . 'Administrator, EPA Environmental Protection Agency 120(J Pennsylvania Avenue. XA\.. 1101A Washington. DC 20460 ______ \ US POSTAGE $00.46p First-Class f/aited Prprn 91 '*6 032A0061S07953