1,3-Butadiene; TSCA Review

Filed on regulations.gov — full text not in the inline record.

Filed as an attachment.

Filed on regulations.gov — full text not in the inline record.

Filed on regulations.gov — full text not in the inline record.

Attached please find comments from the American Chemistry Council. Thank you.

Please find attached the Updated ACC Butadiene Consortium's (Consortium) Industrial Hygiene Data Report. The Consortium is being submitted to the EPA's Docket for the ongoing TSCA Risk Evaluation for 1,3-Butadiene. Please let me know if you have any questions.

Dear Ms. Porter, Hope you are doing well. Please find attached the ACC Butadiene Consortium's Industrial Hygiene Data Report. I would appreciate your help in uploading the attached report to the EPA's Docket for the ongoing TSCA Risk Evaluation for 1,3-Butadiene. Please let me know if you have any questions. Kind regards, Neera Neeraja Erraguntla, Ph.D.; DABT | American Chemistry Council Director, Chemical Products & Technology Division neeraja_erraguntla@americanchemistry.com 700 2nd Street NE | Washington, DC | 20002 O: (202) 249-6712 www.americanchemistry.com

May 26, 2020 Document Control Office (7407M) Office of Pollution Prevention and Toxics (OPPT) Environmental Protection Agency 1200 Pennsylvania Ave. NW Washington, DC 20460-0001 Submitted via the Federal eRulemaking Portal: http://www.regulations.gov Re:Draft Scope of the Risk Evaluation for 1,3-butadiene (CAS # 106-99-0), Docket number: EPA-HQ-OPPT-2018-0451 CC: Jeffrey Taylor; sent via email to taylor.jeffrey@epa.gov Dear Mr. Taylor: The American Chemistry Council (ACC) 1, 3-Butadiene TSCA Risk Evaluation Consortium (the Consortium) appreciates the opportunity to provide comments on the Draft Scope of the Risk Evaluation issued by the U.S Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA) pertaining to 1,3-butadiene (CAS # 106-99-0) . Please feel free to contact me by phone at 202-249-6712 or by email at neeraja_erraguntla@americanchemistry.com if you have questions regarding these comments. Sincerely yours, Neeraja K. Erraguntla Director American Chemistry Council (ACC) Chemical Products & Technology Division

Document Control Office (7407M) Office of Pollution Prevention and Toxics (OPPT) Environmental Protection Agency 1200 Pennsylvania Ave. NW Washington, DC 20460-0001 Submitted via the Federal eRulemaking Portal: http://www.regulations.gov Re:1,3-Butadiene (CAS # 106-99-0) as a Candidate for Designation as High-Priority Substance for TSCA Risk Evaluation, Docket number: EPA-HQ-OPPT-2018-0451 CC: Jeffrey Taylor; sent via email to taylor.jeffrey@epa.gov Dear Mr. Taylor: The American Chemistry Council (ACC) 1,3-Butadiene TSCA Risk Evaluation Consortium (the Consortium) appreciates the opportunity to provide comments in response to the Prioritization notice (Proposed High-Priority Designation) put forth by the U.S Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA) pertaining to 1,3-butadiene (CAS # 106-99-0). Please find attached detailed comments. The newly formed 1,3-Butadiene TSCA Risk Evaluation Consortium looks forward to working with the EPA to provide more information pertaining to 1,3-butadiene hazards and exposures and to assess risks. We look forward to being a constructive participant throughout the risk evaluation process and meeting with the Agency to discuss relevant scientific information. Please feel free to contact me by phone at 202-249-6712 or by email at neeraja_erraguntla@americanchemistry.com if you have questions regarding these comments. Sincerely yours, Neeraja K. Erraguntla Director American Chemistry Council (ACC) Chemical Products & Technology Division

Document Control Office (7407M) Office of Pollution Prevention and Toxics (OPPT) Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, DC 20460 0001 CC: Jeffrey Taylor; sent via email to taylor.jeffrey@epa.gov Re:Comments on 1,3-butadiene (CAS # 106-99-0), Docket number: EPA-HQ-OPPT-2018-0451; Sent electronically to http://www.regulations.gov Dear Sir/Madam: The Olefins Panel (the Panel) of the American Chemistry Council (ACC) appreciates the opportunity to provide comments in response to the Initiation of Prioritization notice (84 Fed. Reg. 10491 (March 21, 2019) put forth by the U.S Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA). The Initiation of Prioritization notice lists 1,3-butadiene (CAS # 106-99-0) as one of the candidate High Priority Substances for risk evaluation under TSCA. The Panel writes to respond to the EPAs decision and is pleased to provide some general comments on 1,3-butadiene (CAS # 106-99-0). The Panel is currently working to provide a central resource for the 1,3-butadiene industry in the United States and will soon establish a new industry TSCA consortium (ACC 1,3-butadiene TSCA Risk Evaluation Consortium) under the ACCs Center for Chemical Safety to centralize information gathering and communication for TSCA purposes. I will serve as the contact point for the consortium. In response to EPAs High Production Volume (HPV) Challenge Program, members of the Panel (previously known as CMA Olefins Panel) have previously submitted important information to the EPA regarding 1,3-butadiene (CAS # 106-99-0). Additionally, the Panel is also currently updating its factual product stewardship manual with important information regarding the uses and handling of 1,3-butadiene (CAS # 106-99-0). This information will be published in the coming months and will be provided to the EPA when available. The Panel seeks a greater understanding of 1,3-butadiene (CAS 106-99-0) as a candidate high priority chemical. There are many uses of 1,3-butadiene and it has widespread function as a monomer for several types of polymers. Thus, sources of manufacture for 1,3-butadiene report varying substance purity, from pure 1,3-butadiene with the CAS # 106-99-0, to petroleum streams containing percentages of 1,3-butadiene ranging from 10 to 80 percent. The Panel seeks clarification of the candidate listing. The Panel, and the soon to be formed ACC 1,3-butadiene TSCA Risk Evaluation Consortium, look forward to working with the EPA to provide more information pertaining to 1,3-butadiene hazards and exposures. Again, the Panel appreciates the opportunity to provide comments on 1,3-butadiene (CAS#106-99-0). If you have any questions regarding these comments or if we can be of further assistance, please contact Dr. Neeraja Erraguntla, Chemical Products & Technology Division at +1 202-249-6712 or at neeeraja_erraguntla@americanchemistry.com. Sincerely yours, Neeraja K. Erraguntla, Ph.D., DABT Director Chemical Products & Technology Division American Chemistry Council (ACC)