### July 19, 2010 [NPRM: RIN 2070

- AJ43]

Page 1 of 48 

### Supporting Statement for a Request for OMB Review under The Paperwork Reduction Act

1. Identification of the Information Collection

1(a) Title of the Information Collection

Title: Proposed Rule Addendum to Partial Update of the TSCA Section 8(b) Inventory Data Base, Production and Site Reports

EPA ICR No.: 1884. 05 OMB Control No.: 2070

- 0162

1(b) Short Characterization/Abstract

The following information collection request (ICR) addendum addresses the paperwork requirements contained in a proposed rule (RIN 2070

- AJ 43) that would amend the information collection activities of the Inventory Update Reporting (IUR) program under the Toxic Substances Control Act (TSCA) (40 CFR P art 710). Under TSCA section 8(a) (15 USC 2607), the Environmental Protection Agency (EPA) is authorized to collect certain information on chemicals manufactured or processed in the United States. In addition, under TSCA section 8(b), the Agency is required to compile and keep current, via per iodic inquiry, the Inventory of Chemical Substances in Commerce (TSCA Inventory). The TSCA Inventory is a listing of chemical substances manufactured, imported, and processed for commercial purposes in the

United States. The Office of Pollution Prevention and Toxic s (OPPT) has used the IUR to update the basic chemical production information for selected larger volume chemicals in the TSCA Inventory six times (every four years), beginning in 1986, and to collect additional information relating to the manufac ture, processing, and use of those chemicals, beginning in 2006.

EPA is proposing to amend the current IUR requirements in order to clarify the reporting requirements, improve the quality and utility of the data submitted, better match data collected

wit h the Agency’s overall information needs, and where possible, reduce the paperwork burden on both regulated entities and EPA

. Manufacturers (including importers) would be required to

use e

- IUR web (the Agency

- provided reporting tool) to submit a completed F orm U (EPA Form

7740

- 8) electronically via the Internet. As proposed, the 2011 IUR would include additional manufacturing, processing, and use exposure

- related data elements, including the volume of the chemical used on the reporting site; the volume of th e chemical directly exported; whether the chemical is being recycled, remanufactured, reprocessed, reused, or reworked; and the production volumes for the previous years since the last principal reporting year. Additional

amendments to the 2011 IUR would i nclude changes to the reporting frequency from every five

years to every four years ; modif ications to the method used to determine whether a manufacture (including importer ) is subject to IUR reporting for reporting cycles subsequent to the 2011 reporting cycle ; modifications to reporting thresholds, including eliminating the upper threshold; revisions to industrial classifications used; revisions to the list of commercial and consumer product categories; and modifications to situations in which confidentia lity may be claimed and to the process for making such claims.Page 2 of 48



### OPPT will use the updated IUR data in its chemical risk

- management efforts. Individual sites manufacturing, including importing, chemicals will submit the required information. The

informati on will be stored electronically for reference by EPA staff and others. Within the

con straints of confidentiality claims, the information will be made public through the Agency’s IUR website ( www.epa.gov/iur ). Furthe r discussion of how the information is used, stored, and

collected is included in this document.

The collection is expected to involve an average of approximately 4, 221 respondent s at an annual cost of $ 40.3 million during the ICR addendum period . The de tails of the paperwork

burden and cost estimates are discussed in this document.

2. Need for and use of the Collection

2(a) Need/Authority for the Collection

Under TSCA, EPA is required to identify, assess, and control risks of injury to human

health a nd the environment posed by commercial chemicals. Under TSCA section 8(b), EPA is required to compile and keep current a complete list of chemical substances manufactured or processed in the United States. TSCA section 8(a) authorizes the Administrator to promulgate rules to provide for the maintenance and collection of records from manufacturers, importers, and processors of commercial chemicals. Sections 8(a)(1) and (2) of TSCA also authorize the Agency to collect information on the chemical manufacturing and importing industry. EPA possesses broad discretion in determining the information to be reported under TSCA section 8(a). The IUR rule currently is codified at 40 CFR 710. EPA is proposing to move the IUR rule

to a new Part at 40 CFR 711.

EPA is prop osing now to modify the IUR rule 1 

### to meet four primary goals : (1) to tailor

the information collected to better meet the Agency’s overall information needs ; (2) to increase its ability to effectively provide public access to the information; (3 ) to obtain new and updated information relating to potential exposures to a subset of chemical substances listed on the TSCA Inventory; and (4 ) to improve the usefulness of the information reported. EPA believes requiring electronic reporting; collecting comprehensiv e information for most reported chemicals; and adjusting the specific reported information

, the frequency the information is reported , and confidential business information ( CBI ) claim requirements would accomplish these goals.

The IUR provides basic expo sure

- related manufacturing, processing and use information used by EPA and others in a wide range of Agency activities. EPA’s efforts to use the 2006 IUR data have identified areas where further improvements are needed to improve risk

- screening capabilitie s

. Screening level data need not be precise, but should be accurate and reliable enough for the Agency to develop screening

- level exposure assessments. The 2011 IUR would provide more detailed information needed to better understand and interpret the IUR d ata, further enhancing the Agency’s ability to identify, screen, and manage potential chemical risks. Because exposure is a key component of risk, the IUR exposure

- related information would allow OPPT to screen chemicals based on the potential for risk in order to protect human health and the environment, as required by TSCA. The exposure

- related data on manufacturing, processing, and

1 The proposed rule is titled “TSCA Inventory Update Modifications.”Page 3 of 48



### use potentially allow the Agency and others to avoid more burdensome regulatory requirements.

These enhanced data would allo w EPA to conduct a more effective and efficient screening level review of chemicals to identify candidates for further evaluation.

2(b) Practical Utility/Users of the Data

The proposed modifications associated with reporting methods and changes to the reporting software would ensure the information reported to EPA is accurate and in compliance with the IUR requirements.

e

- IUR web Reporting Software

Beginning with the 2011 submission period, EPA is proposing to require electronic reporting for all IUR submissions, including joint submissions and amendments. Persons submitting information under the IUR rule would be required to use e

- IUR web , the Agency

provided

, web

- based software to complete Form U (the IUR reporting form). The information

would be sub mitted electronically via the Internet, through EPA’s Central Data Exchange (CDX). Users of CDX are required to register with the system, including submit ting an authorized signature agreement to EPA

.

The 2011 submission process will be similar to that av ailable for the 2006 IUR, when EPA provided an opportunity for IUR respondent s to send their reports electronically, through CDX, on a voluntary basis. Approximately one

- third of the 2006 submissions were filed through CDX, using the 2006 e

- IUR downloadabl e software

. Th e elimination of paper

- based submissions

in favor of electronic reporting , including the use of e

- IUR web , is expected to greatly improve the reporting process, both for EPA and for manufacturers (including importers )

.

The 2011 e

- IUR web woul d feature several improved capabilities over the 2006 e

- IUR

software . These improvements include an enhanced validation system, which would alert users when a required field on the form is either missing information or contains certain kinds of potentially incorrect information. EPA expects o ther updates to include automated chemical identity checks, automated company and site identity checks, and the facilitation of joint

submissions and amendments.

Electronic submission would also ensure that IUR data would have completed a basic validation check, could be quickly incorporated into a database and ready for immediate Agency use, and would eliminate subsequent data entry errors which occurred with paper submissions

. Furthermore, EPA believes the mandatory use of e

- IUR web and CDX would reduce the reporting burden on industry by reducing both the cost and the time required to review, edit and transmit data to the Agency.

CDX Registration

Each IUR submission must have an associated authorized official . Th e authorized official sign s the certification statement and submit s the IUR report via CDX

. . During the 2006 IUR, respondent s were required to complete an electronic signature agreement (ESA) and to submit the agreement in hard copy with a wet ink signatur e to EPA in order to complete the CDXPage 4 of 48



### registration. For 2011 IUR reports, EPA is modifying the 2006 ESA to identify more clearly the individual(s) required to sign the agreement. To register in CDX, the CDX registrant (also referred to as “Electronic Signa ture Holder”) would download two forms: the Electronic Signature Agreement and the Verification of Company Authoriz ing Official . For identity authentication, the registrant would complete the ESA, sign and date it, have the form notarized,

and mail it to E PA. The Verification of Company Authoriz ing Official form requires the signature of an immediate supervisor or witnessing official verifying that the registrant is the person who should sign their name in the certification statement box on Form U. Once EPA

receives both forms, EPA would activate the registrant’s CDX account and send a notification

via email.

Respondent s may need or desire to have more than one individual complete an electronic signature agreement, so that other individuals can add inform ation to an original IUR

submission. Persons submitting supplemental information for an IUR submission on behalf of a company would need to register with CDX by signing an ESA and Verification of Support

Submitter form

. Th e Verification of Support Submitte r form requires the signature of an immediate supervisor or witnessing official from the company and anyone he/she authorizes to

submit additional information. The company official can authorize an unlimited number of

s upport respondent s , but will ha ve to complete a form for each support respondent

. Support respondent s can work with an unlimited number of company official s, but will need an agreement with each company official (even if the company officials work at the same company). A support respondent ma y be a n employee of the company, an outside consultant for the company, or an authorized representative agent for the company. While this individual would not be able to sign the certification statement required for the initial IUR submission, he or she

wo uld be able to provide additional information, if needed, using CDX. For 2006 and prior IUR submissions, respondent s were not able to provide additional information electronically.

Data Elements for IUR Submissions

The IUR information collection is the only mechanism through which EPA can collect basic information on commercial chemicals listed on the TSCA Inventory of Chemical Substances, including production volume and other manufacturing (including importing) processing, and use exposure

- related data. This information collection is necessary because these

data are not otherwise available . EPA would use t he information it is propos ing to collect in the following ways:

(1) Parent company identification information : Company identification information is

collected already by the current IUR. EPA is proposing to require reporting of additional company identification information associated with the location of the company, and is clarifying that the company information is to be for the ultimate domestic pare nt

company associated with the reporting plant site. These data would help ensure the company information is consistently provided

.

(2) Manufacturing

- related information :

**•** The production volume for each of the years since the last principal reporting

y ear : T he one

- year snapshot of production volume provided by the currentPage 5 of 48



### IUR does not provide an accurate picture of the chemicals in commerce, and may provide an erroneous view of the exposure scenarios associated with a particular chemical substance

. The high turn

- over of reported chemicals from one submission period to the next indicates a dynamic, changing industry. EPA has received comments from industry concerning the year

- to

- year changes that occur for chemical production that may affect IUR reporting

. EPA would use these data for chemical manufacturing , and processing and use trend analyses ; and for the assessment of the effectiveness of Agency and public programs , among other uses

.

**•** The production volume of a manufactured (including imported) chemica l substance used at the reporting site : This data element would replace the data

element indicati ng that a chemical is site

- limited. This new data element

identifies whe ther a chemical is used by the reporting site. A domestically

manufactured chemical wou ld be identifie d as a site

- limited chemical (or that a portion of the chemical is site

- limited). An i mported chemical would be

identifie d as used by the importer. This information is related to potential exposures associated with the on

- site volumes, and w ould provid e the Agency

with more accurate information for exposure assessments and other data analyses.

**•** Whether an imported chemical is physically at the reporting site : This data element would enable the Agency and others to better assess manufacturing

related potential exposures, thereby enabling more accurate information for screening

- level analyses and other uses of the IUR data.

**•** The production volume directly exported and not domestically processed or

used : This data element would allow EPA to bett er identify the completeness of the reported processing and use information, by indicating the proportion of the production volume potentially covered by the reported processing and use

information. IUR processing and use information is required only for

d omestic use situations

, and is not required for any volumes directly exported.

**•** Whe ther a manufactured (including imported) chemical, such as a byproduct, is being recycled, remanufactured, reprocessed, reused, or reworked : This data element would provide valuable information for Agency and public programs that encourage industry to find uses for wastes rather than disposing of the wastes, such as in a landfill.

These data would also be used in other ways, such as in chemical exposure and risk screening, testing and/or priority setting, and exposure estimation required by the Interagency Testing Committee (ITC) under TSCA section 4; for EPA monitoring activities of newly manufactured substances that have completed PMN review under TSCA section 5(a); to su pport the development of TSCA regulations under section 6; and to measure potential human and environmental exposure under TSCA section 8(e). Each data element would correspond to a data point necessary for basic risk

- screening.Page 6 of 48



### Under the current IUR rule , only manufacturers ( including importers ) of larger

- volume chemicals are required to report processing and use information. As proposed, respondent s would be required to report processing and use information for all reported chemical substances, regardles s of production volume, unless the chemical substance is partially exempt. This

p roposed change provide s exposure

- related processing and use information to EPA and others

for moderate

- volume chemicals, enabling the Agency to address such chemicals in the s ame manner as the higher

- volume chemicals.

(3) Industrial processing and use data : This proposal does not add any industrial processing and use data elements. The industrial function categories would be revised to better identify the functions of the chem ical substances. The North American Industrial Classification System (NAICS) codes would be replaced with industrial sector (IS) codes.

The IS codes reduce the number of choices available to the respondent

, thus streamlining the reporting process and makin g the data easier to use.

(4) C onsumer and commercial end

- use exposure data : EPA is proposing to add two data

elements: an indication of consumer or commercial use and the number of commercial

workers. These data would be used to determine exposure poten tial based on consumer or commercial populations. These two populations are very different from each other, and the ability to distinguish uses between the two enables better exposure

- based screening of

the chemical. The number of commercial workers is nee ded to better assess the size of the commercial population. In addition, the product categories would be revised to better identify the uses of the chemical substances.

Special Considerations for Joint Respondent s

I n certain situations IUR respondents cu rrently are allowed to report the IUR information jointly with the supplier of the chemical substance for which the respondent is reporting

. For example, i mporters may not know the specific chemical identity of the imported Inventory

substance because the foreign supplier chooses to keep the information confidential

. In addition, a manufacturer may not know the specific chemical identity of the substance being manufactured because the supplier of a reactant used to manufa cture the substance chooses to keep the

information confidential. In such situation s , the manufacturer (including importer ) is still responsible for ensuring that the IUR information is submitted to EPA and may do so by submitting a joint report. For example, in the case of an imported subst ance , the U.S. importer, as the primary respondent , completes the majority of the required information on Form U, and provides a trade name in P art II.2.A.4 to identify the chemical substance. The primary respondent then contacts the foreign supplier, who is the secondary respondent , to notify them of the need to report the specific chemical identity information directly to EPA in the joint submission section ( P art IV ) of Form U, using the e

- IUR web reporting software.

For 2006 an d prior IUR submissions, respondents were not able to submit joint reports electronically. EPA has added P art IV to Form U to accommodate joint submissions. Because signatures are required by each party of a joint submission, they must each register with CDX

, complete t heir own se ctions on Form U, and submit their own sections of the same report electronically to EPA. T he secondary respondent will not be able to access the information

p rovided by the primary respondent and vice versa. The reporting tool will match bothPage 7 of 48



### submissions based upon company and chemical information provided by the manufacturer (including importer) , acting as a primary respondent , and by the supplier, acting as a secondary

res p ondent . EPA will also use the identifying number a ssigned to the primary responden t during CDX registration to link the joint reports in an internal database . The information provided by

the primary and secondary respondent s will be saved and combined as one joint submission. EPA will process the joint submission once all F orm Us are re ceived and matched by the Agency

.

T his information collection would allow EPA to connect submissions from the primary

r espondent and secondary r espondent and to request clarification from the secondary r espondent

if needed

. The data EPA propose s to collec t would be utilized in the following ways:

(1) Joint Submission Information (primary r espondent only): The primary r espondent provides only a trade name or other designation to identify the chemical substance being reported. Therefore, the requested data are needed by the Agency to identi f y the

chemical substance correctly and provide the company name and complete mailing address of the secondary respondent

.

(2) Secondary Company Identification I nformation : These data would identify the secondary respondent ’s co mpany name and the complete mailing address of the

company. The information provided would help ensure that the company information is provided consistently , and would be used to associate the secondary respondent ’s company with the primary respondent ’s co mpany and site plant.

(3) Technical Contact Information: T he company’s technical contact information would provide EPA with the name and complete mailing address of the person who would be able to answer questions EPA may have about the reported chemical sub stance.

(4) Primary Company Identification I nformation : These data would provide the primary respondent ’s parent company name and the complete address of the company to help

ensure that the company information is provided consistently , and would be used to

a ssociate the primary respondent ’s company and site plant with the secondary respondent ’s company.

(5) Trade Product Identification Information : These data would identify the primary respondent ’s company name, site name, and site address , as well as the CAS R egistry Number, the appropriate specific che mical identities, and product composition. These data are needed by EPA to combine the secondary respondent ’s chemical

- specific information with the primary respondent ’s information to result in a complete IUR

su bmission.

Information secured through the IUR collections is used increasingly by a wide variety of governmental and non

- governmental users. Consistent with Congress’s intent that TSCA data be used to facilitate any government public health and environmen t efforts, IUR data have been used by EPA’s Office of Water, Office of Solid Waste and Emergency Response, and Office of Air and Radiation to identify and characterize particular chemical substances. Non

- confidential IUR data are incorporated into a number of databases and products maintained by organizationsPage 8 of 48



### including Right

- To

- Know

- Net and INFORM 2 

### . IUR data were used to identify chemicals of particular concern for the National Institutes of Health. Non

- confidential IUR data were also

released to selected s tates to help them identify facilities manufacturing suspected endocrine disrupters.

Data reported under the 2011 IUR w ould enhance the capabilities of the Agency and other Federal agencies to ensure risk management actions are taken on chemicals posing the

most concern. More in

- depth reporting of the processing and use data, more careful

consideration of the need for confidentiality claims, and adjustments to the specific data elements

would better support a robust risk assessment and management program

. By enhancing the data supplied to Agency risk

- screening programs, EPA expects to more effectively and expeditiously identify and address potential risks posed by chemicals and provide improved access and information to the public

.

EPA would also use t he in formation submitted through the 2011 collection to update the Agency’s comprehensive chemical manufac turing, exposure, and use database, maintained as part of the Manage Toxic Substances (MTS) system. IUR data prior to the 2006 collection are

maintain ed in a series of databases known as the Chemical Update System (CUS). The MTS IUR data, combined with CUS and the Chemicals in Commerce Information System (CICIS) database, serves as a primary source of information about the chemical industry for EPA, as well as other Federal Agencies . The MTS IUR data provide information about the chemicals used, where they are produced, how much is produced or imported, and how they are processed and used. The chemical industry is dynamic , as demonstrated by the approxim ately 30 percent change in chemicals reported from one IUR submission period to the next ; therefore continual updating of the database is essential

.

3. Non duplication, Consultations, and Other Collection Criteria

3(a) Non duplication

The data inclu ded in this information collection (i.e., production volume, chemical manufacture, exposure, and processing and use data) are not collected comprehensively or systematically at the national level. There are a variety of sources for certain data elements, b ut the sources are either incomplete or incompatible.

3(b) Public Notice Required Prior to ICR submission to OMB

The proposed rulemaking serves as the public notice for this ICR. Interested parties

should submit comments referenci ng Docket ID No. EPA

- HQ

- OPPT

- 200 9

- 0187 to the address listed at the end of this document. Responses will be taken into account in developing the final rulemaking.

3(c) Consultations

2 INFORM is a nonprofit environmental research organization.Page 9 of 48



### In addition to the public notice and comment period, OMB regulations , at 5 CFR 1320.8(d)(1), require agencies to consult with potential ICR respondent s and data users about specific aspects of an ICR before the agency submits the ICR to OMB for review and approval. In accordance with this regulation, EPA will solicit consultat ion feedback from nine potential respondents and data users with respect to this final rule ICR.

3(d) Effects of Less Frequent Collection

EPA is proposing to return the reporting frequency to every four years, which was the frequency in effect from 1986 to 2006. In an effort to reduce the reporting burden associated with the 2003 amendments, EPA had changed the reporting frequency to every five years. While the less frequent reporting does reduce burden , a review of the 2006 IUR reporting has revealed

an approximately 30 percent change in the chemicals that are reported from one submission period to the next. EPA now believes that reporting every five years does not provide data sufficiently current to meet Agency and public needs and now considers every four years to be the minimum acceptable frequency. In addition, the IUR Modifications proposed rule requests comment on even more frequent reporting. Comments from industry representatives have led EPA to believe that more frequent reporting creates effic iencies, both for the respondent and for EPA. With more frequent reporting, companies would be able to establish standard systems and practices to collect the required information.

The Agency needs to be able to make accurate chemical risk management de cisions in a timely and cost effective manner, especially because alternative data sources do not exist for these data. The effect of less frequent collection of these data is to diminish significantly the Agency’s ability to understand the chemical indust ry and monitor the production levels of

chemicals manufactured (including imported ) in the United States. As described above, the IUR

data demonstrate that chemical industry product lines and manufacturing in the United States change substantially from one submission period to the next. The Agency needs up

- to

- date

information in order to fulfill its mandate to keep the TSCA Inventory current under section 8(b)

of TSCA ; collecting the data every five years means the Agency is working with data which are

pote ntially six or more years old

, and therefore

, cannot be considered current.

Less frequent collection could result in EPA using outdated information in its decision making. For example, changing market conditions, batch processing, or the development of new uses for the chemical can cause production volumes or chemical uses to change from one year to

the next. Companies buy and sell plant sites, and the chemicals produced at a site can change. Based on past IUR reporting, the Agency would be working with the IUR data which approximately 30 percent of the chemical substances known to be in commerce at volumes of 25,000 lb. or more may not actually be in commerce at those levels.

3(e) General Guidelines

This collection does not exceed any of the Paper work Reduction Act guidelines at 5 CFR 1320.6, with the exceptions listed below.

The record retention period of this collection is five years, as specified in 40 CFR 710.57, exceeding the PRA maximum of three years. This is necessary to ensure companies retainPage 10 of 48



### records long enough to facilitate completion of Form U (EPA Form 7740

- 8) in the next collection, which is in four years (as proposed), and to allow EPA’s enforcement activities to overlap two IUR reporting cycles.

Confidential Business Information (CBI) claims limit access to the IUR data, especially by the public. EPA recognizes that some information submitted to the Agency is legitimately

confidential business information ; because of this, EPA’s review of CBI data is an inherently governmental fu nction that EPA must perform to protect human health and the environment.

3(f) Confidentiality

Respondent s may claim information reported to EPA under this rule as confidential if

such information would reveal the respondent s’ trade secrets or proprie tary information as defined by TSCA section 14 and existing TSCA regulations. EPA has long

- established procedures for handling, storing, processing, and disposing of TSCA confidential information. Transfers of this information to other governmental agencie s can be made only if the other agency agrees to adhere to all TSCA confidentiality provisions. EPA will maintain standard CBI procedures to protect any confidential, trade secret, or proprietary information from disclosure in

accordance with EPA’s confide ntiality regulation, 40 CFR Part 2, Subpart B.

3(g) Sensitive Questions

This collection does not include questions of a sensitive nature.

4. The Respondents and the Information Requested

4(a) Respondents / NAICS Codes

The regulated community consist s of companies manufacturing or importing chemicals listed on the TSCA Inventory and regulated under TSCA section 8. In general, the industry segments that compose the regulated community for the rule are those that produce or import organic and inorganic chemicals. Most respondent s previously reported information under the IUR. The Agency’s previous experience with IUR collections has shown that the majority of the respondent s affected by this collection activity are from the following North American Indus trial Classification System (NAICS) code categories:

325

- Chemical Manufacturing (including importing)

324

- Petroleum and Coal Product Manufacturing (including importing)

The subsectors identified above represent the designation of sites that likely would be subject to IUR reporting. However, activities at these sites may vary , making identification of the regulated community more difficult. For example, NAICS codes reflect a site’s primary activity, omitting substantial participation a company may h ave in other industry activities. Second,

NAICS codes selected by parent companies reflect the parent company’s primary activity, even though many parent companies are primarily holding companies with small subsidiaries. Each of

these small subsidiaries ma y belong in a completely different industry classification based on its own primary activity. Information on parent company NAICS codes does not provide a veryPage 11 of 48



### accurate characterization of the types of sites subject to reporting, and facilities that do not fall under these categories must still report if they meet the reporting criteria.

Generally, TSCA section 8 excludes small manufacturers (including importers) from reporting. EPA defines small manufacturers (including importers) for purposes of IUR and certain other reporting in 40 CFR 704.3.

In addition to the anticipated respondent s listed above, manufacturers (including importers) of byproducts may be required to report under the IUR rule. Byproduct manufacturers (including importers) may be listed under a different primary activity for a site, such as NAICS

codes 22, 322, 331, and 3344; e.g., utilities, paper manufacturing, primary metal manufacturing, and semiconductor and other electronic component manufacturing. For purposes of the IUR, a byprod uct is a chemical substance produced without a separate commercial intent during the manufacture, processing, use or disposal of another chemical substance or mixture (40 CFR 704.3). Such a chemical substance, like any other manufactured chemical substance , is subject to IUR reporting if it is manufactured, is listed in EPA’s Master Inventory File, is not otherwise

excluded from reporting, and its manufacturer is not specifically exempted from IUR reporting requirements

. For instance, 

### a manufacturer (includ ing importer) that uses a chemical substance in

the production of an article may produce a byproduct substance that is chemically different from the starting substance; the manufacturer (including importer) therefore may incur reporting obligations under t he IUR for that byproduct. While some manufacturers (including importers) of byproducts may not have reported to the IUR in the past, they should be aware now of their reporting obligations under the IUR rule.

4(b) Information Requested

(i) Data elements

, including record keeping requirements

The IUR data elements are related to or indicative of three components of exposure. These components are: (1) the number of ecosystems or size of human populations potentially exposed, (2) the potential human or envi ronmental exposure concentrations, and (3) the frequency and duration of potential exposures. The data enhances EPA’s ability to evaluate each of these components of exposure. Respondents are required to submit certain known or reasonably ascertainable man ufacturing, processing, and use exposure

- related information. For the 2006 IUR, respondents were required to submit the processing and use information to the extent it was readily obtainable; the IUR Modifications rule proposes to standardize all of the

s ubmitted information to the single “known to or reasonably ascertainable by” reporting

standard.

Using e

- IUR web , individuals would report the proposed data elements as follows (the following list identifies new or revised data elements and does not addre ss the full data requirements):

**•** Authorized Company Official’s e

- mail Address . The e

- mail address of the company official authorized to sign and submit the IUR Form U

.Page 12 of 48



### • Parent Company Name and Address . The name and mailing address of the ultimate

domestic parent company. The requirement that the ultimate parent company reported be the ultimate domestic parent company is part of the IUR Modifications proposal; the parent company name is already required by the IUR. This is not a new requirement; rather the change better identifies the correct company name.

**•** Manufacturing Information. T he production volume for each of the years sinc e the last principal reporting year; the volume of the reported chemical substance used at the reporting site; w hether an importe d chemical is physically at the reporting site ; t he production volume directly exported and not domestically processed or used ; and

whether a manufactured (including imported) chemical, such as a byproduct, is being recycled, reused, reprocessed, remanufac tured , or reworked

.

**•** Processing and Use Information. For the 2006 IUR, only th os e manufacturers ( including importers ) of chemicals with production volumes of 300,000 lb. or more were required to report processing and use information. The IUR Modification s rule proposes to require respondents to report this information for all reported chemicals, unless the chemical is specifically partially exempted.

**•** Industrial Processing and Use Data. For the 2006 IUR, respondents were able to select up to 10 unique combi nations of the type of process or use (code), NAICS code associated with the industrial use, and industrial function category. The IUR Modifications rule proposes to r evise the list of in dustrial function categories and to

r eplace the NAICS codes with Indu strial Sector s

.

**•** Consumer and Commercial Use Data. For the 2006 IUR, respondents were able to select up to 10 consumer and commercial product categories. The IUR Modifications rule proposes to r evise the list of consumer and commercial product categories. The respondent must indicate whether the use is consumer
, commercial or both, and, if commercial, the number of reasonably likely to be exposed commercial workers must be reported as a range.

Joint Submissions

Joint submissions are allowed only in those instances where a supplier w ill not disclose to

the r espondent the specific chemical name of the imported Inventory substance or of a reactant
used to manufa cture the Inventory substance. This may happen , for instance, when a company is importing a mixture under a trade name, and the foreign manufacturer does not want to reveal the components in the mixture. (See Special Considerations for Joint Respondents in section 2b, above) Proposed changes to the IUR would make it easier for respondents to use electronic reporting for both the primary and the secondary portions of a joint submission. In addition to signing the certification statement and completing P arts I, II, and III, primary respondent s wouldPage 13 of 48



### report on proposed data elements in P art II, Block s 2.A.4 through 2.A.10, on Form U as follows (see Attachment A):

**•** Joint Submission Information. Trade name of the chemical substance being reported, secondary company name, and complete mailing address (city, state, zip code, and country (if applicable)).

S econdary respondents would register with CDX and r equest to submit a joint report by selecting “ J oint s ubmission

- as secondary respondent ” on the main page of the e

- IURweb reporting tool. They would provide the primary company’s information and the trad e product name, supplied to them by the primary respondent, to gain access to the Form U containing information specific to the trade product name. After the secondary respondent is granted access

to the form

, it would report on proposed data elements in P art IV on Form U as follows (see Attachment A):

**•** Certification. The c ompany o fficial must certify by signature and date that to the best

of his/her knowledge and belief : 1) all information entered on Form U has been completed in compliance with the regula tory requirements; and 2) any confidentiality claims are true and correct as to that information for which they have been asserted.

**•** Secondary Company Information. The s econdary company name and complete mailing address (city, state, zip code, and country (if applicable)).

**•** Secondary Technical Contact Information. T he t echnical contact name, phone number, complete mailing address (city, state, zip code, and country (if applicable)), and

email address.

**•** Primary Company Information. The p rimary company name , site name, and complete mailing address ((city, state, and zip code).

**•** Trade Product Information. T he t rade product name, chemical name, CAS Registry Number, ID code, and percentage of each chemical component of a trade product.

(ii) Respondent Acti vities /Information Collections (ICs)

EPA identified the following ICs in the currently

- approved ICR (EPA ICR No. 1884.04) for activities that respondents would complete when complying with the existing rule:

**•** Compliance Determination;

**•** Rule Familiarization ;

**•** Report Preparation and Submission

– Partial Reports ;

**•** Report Preparation and Submission

- Full Reports ; and

**•** Recordkeeping.

As a result of this proposed rule, EPA would include a new IC addressing the initial paperwork activities a company would need to complete in order to be able to submit reportsPage 14 of 48



### electronically through CDX

. EPA also would incorporate recordkeeping activities into the ICs that address the preparation and submission of partial and full reports

, rather than include them

as a stand

- alone I C (see Table 1).

Table 1 : Information Collections (ICs) for IUR Reporting



### I nformation

Collection Description

Compliance

Determination Determine whether reporting is required for a chemical manufactured (including imported ) at a particular site, based on the chemical’s production volume and the applicability of certain reporting exemptions.

Beginning with reporting cycles subsequent to the 2011 reporting cycle,

t he proposed rule would modify the method used to determine whether a

manufacture r (includi ng importer ) is subject to IUR reporting. For example, for a 2015 submission period, r eporting would be required if the production volume of a chemical substance met or exceeded the 25,000 lb. threshold in the 201 4 principal reporting year for the 201 5

sub mission period, and in any calendar year since the last the last principal reporting year (i.e., since 2010 for the 2011 reporting cycle)

Rule Familiarization Become familiar with the full requirements of the rule, which entails reading the rule, underst anding the various reporting and administrative requirements, and determining the manner in which reporting requirements will be met for each chemical

. CDX Registration

Activities The proposed rule would require electronic reporting, and therefore

would r equire that all respondents complete the CDX registration

process. As part of registering with CDX, each respondent would provide identifying information that would comprise all or most of the information requested in Part I of Form U (EPA Form 7740

- 8). Th is information will then be pre

- populated whenever the respondent prepares a partial or full report.

In order to submit electronically to EPA via CDX, the respond ent’s authorized official, who will be signing and submitting the site’s IUR

Form U , must reg ister with CDX and must submit an E lectronic

S ignature A greement (ESA) and a Verification of Company Authorizing

Official form

. This is the same process required for electronic

submissions for the 2006 IUR.

Once the registration process is completed, the registered individual

would receive a case number and be able to access the e

- IURweb reporting software. Prepar e and Submi t Report, and Maintain

Records

- Partial Report Compile the required information, determine the CBI status of

information and fulfil l appropriate substantiation measures, and use e

IUR web to complete and submit only Parts I and II (and Part IV, if a joint submission) of Form U (EPA Form 7740

- 8) for chemicals specifically listed in the proposed regulation for which there is a partial re portingPage 15 of 48



### exemption. Retain all records related to the submission for five years after the submission period. Prepar e and Submi t Report, and Maintain

Records

- Full Report Compile the required information, determine the CBI status of

information and fulfil l appropriate substantiation requirements , and use

e

- IUR web to complete and submit Parts I, II, and III (and Part IV, if a joint submission) of Form U (EPA Form 7740

- 8) for all reportable

chemical substances. Retain all records related to the submission fo r five years after the submission period.

5. The Information Collected

– Agency Activities, Collection Methodology, and Information Management

5(a) Agency Activities

The activities routinely conducted by EPA related to the processing, analysis and sto rage of the information collected under this rule include the following:

**•** Review and verify forms as they are received ;

**•** Answer respondent questions and provide any necessary assistance ;

**•** Process submissions for inclusion in IUR database ;

**•** Review requests for confidentiality in the submissions ;

**•** Maintain the database ; and

**•** Distribute the data.

5(b) Collection Methodology and Management

The next IUR collection will occur in 2011. All manufacturers (including importers), except for those defined as “small manu facturers” by EPA’s regulations

, are required to submit information on every substance subject to this proposed rule that they manufacture ( including import ) in quantities that meet or exceed the IUR thresholds. As proposed, the collection would

occur ever y four years.

(i) Collection Methodology

Respondents would be required to submit information associated with this data collection electronically via the Internet using e

- IUR web and CDX. The 2006 IUR allowed and encouraged electronic reporting, thus p roviding both respondent s and the Agency the opportunity to test an electronic reporting system. Comments from respondent s and lessons learned from the collection of paper, CD, and electronic submissions were used to develop the 2011 collection methodology

. Some of the changes to this methodology are regulatory and are included in the IUR Modifications proposal; others are process

- oriented or internal to EPA or the respondent

.

Potential respondents would be notified of the need to report in three ways: ( 1) EPA plans to publish a Federal Register notice, (2) email notices will be sent to previous IUR respondents , and (3) articles will be published in the trade press. Reporting materials, including a

non

- submission version of the e

- IUR web reporting software and a variety of guidancePage 16 of 48



### documents (Instruction Manual, Q&As, Case Studies), will be available on EPA’s IUR website. Respondents also can obtain these materials from the TSCA Hotline. Respondents obtain the

submission version of the e

- IUR web reporting so ftware as part of the CDX registration process,

as described in section 4 of this document.

As proposed, EPA will receive all IUR submissions electronically. The CDX registration process, required for all respondents , would provide a case number which th e respondent would use to identify its submission and which the Agency would use to track any additional information or changes related to that submission. EPA believes this is an improvement over the 2006 IUR, which resulted in the generation of several i dentifying numbers by either the respondent or EPA.

Information quality and validation begins with the e

- IUR web reporting tool, which will be programmed to help the respondent provide the information required, in the correct format as required by the IUR rule. Use of e

- IUR web will eliminate many of the problems with incorrect chemical identifications experienced in the past by providing a current listing of the TSCA Inventory chemicals and their associated identification numbers. Other respondent

- generate d errors, such as incorrect codes, will also be eliminated due to the use of techniques such as drop

down menus, restrictions on the specific information that can be entered, and error

- checking algorithms.

Mandatory IUR reporting via the Internet is the most efficient collection method for respondent s and EPA. Respondents receive almost immediate notification that EPA has received their submission, and EPA is able to upload the information directly into the IUR database, which improves the efficiency of EPA’s d ata receipt and processing activities. This collection

method also eliminates the introduction of errors by avoiding the need to scan or key

- enter data submitted on paper or CD. Additional validations will be programmed into the data

- entry system

to further ensure the quality of the data.

To aid persons subject to this information collection, the Agency’s TSCA and CDX Hotlines are available to answer questions regarding the IUR requirements or submission process. When Hotline staff are unable to a nswer questions, the respondent is referred to OPPT’s Information Management Division (IMD) or Chemical Control Division (CCD), as appropriate. Other Divisions within OPPT or OEI are used as necessary.

(ii) Data Management

This section describes the A gency tasks required for efficiently processing submissions under the IUR. The tasks for which the Agency is responsible are presented under four main categories: database systems development, guidance document development, Form U processing,

and additiona l tasks. The task descriptions presented below generally do not change from

collection to collection.

IUR data is stored in a database managed by the Agency. Once updated, the IUR database is then available to EPA technical reviewers to search or export into their various analytical modeling systems and databases. The IUR database is also available for quickPage 17 of 48



### screening and other direct uses. The Agency makes publicly available as much information as possible, within the confines of protecting CBI.

**•** Databas e Systems Development and Maintenance

-- The Agency is responsible for having adequate information systems in place to support the database that serves as the primary data storage medium for IUR collections. File servers with appropriate backup

are used to contain the IUR databases. Following the 2006 IUR collection, EPA updated the technology used to store the IUR data, storing it in a larger Manage Toxic Substances (MTS) database. In addition, IUR data are tracked via the correspondence tracking

system ut ilized by the Confidential Business Information Tracking System (CBITS) located within the Confidential Business Information Center (CBIC).

**•** Guidance Document Development

-- The Agency is responsible for developing guidance

to assist respondent s in complyi ng with IUR requirements. The guidance documents usually are developed by a contractor with oversight by Agency personnel.

**•** Form U Processing

-- The Agency is responsible for processing IUR Form U submissions. This includes developing standard operating p rocedures and documentation for all stages in the IUR document life cycle, document receipt and tracking, data input, quality control, file and database maintenance, information security, CBI aggregation policy, data dissemination, and staff training. For the 2011 IUR submission period, EPA will develop new processes to receive IUR submissions over the Internet, using CDX.

**•** Additional Activities

-- The Agency develops various supporting documents associated

with the reporting software and makes them availa ble on the Internet

. . In addition, the Agency is responsible for providing the TSCA Hotline with standardized responses for frequently asked questions; preparing mailings, mailing lists, and labels; and developing outgoing information materials.

5(c) Sma ll Entity Flexibility

The current IUR regulation provides ample flexibility to small entities. This regulation affects only businesses

-- governmental jurisdictions and not

- for

- profit organizations are not required to take any action. Small manufacturers (including importers), in accordance with TSCA section 8(b) (40 CFR Sections 710.29 and 710.28), are exempt and therefore are generally not subject to any of the reporting or recordkeeping requirements. A manufacturer (including importer) is considered a small business if (1) the firm’s total annual sales when combined with those of its parent company (if any) are less than $40 million for the submission period and (2) its total production and/or importation of the chemical substances, mixture or category, for the reporting period, does not exceed 100,000 pounds (45,000 kilograms) at an individual site owned and controlled by the firm. The Economic Analysis for the Proposed Inventory Update Reporting Modifications Rule determined that the impact on these co mpanies is , on average, significantly

less than one percent of revenues (EPA 200 9 ).

5(d) Collection SchedulePage 18 of 48



### The submission period shall be from June 1, 2011 to September 30 , 2011 . This submission period/schedule follows the requirements of 40 CFR 710 .53 (proposed 40 CFR

711.1 3 )

.

6. Estimating the Burden and Cost of the Collection

This section presents the burden and costs estimates incurred by all affected entities as a result of the proposed IUR rule amendments. This addendum to the supporting sta tement covers the years 201 1 , 201 2 , and 201 3

. Therefore, it provides burden and cost estimates for the information collection corresponding to the 2011 reporting cycle ( which is the first submission after the proposed amendments to the IUR rule are finaliz ed ), and also for the information collection corresponding to the next reporting cycle, for which respondents will be preparing during 2012 and 2013

. Even though reporting occur s only once per reporting cycle (o nce every five years for the 201 1 cycle and, as proposed, every four years in the future)

, EPA believes that rule compliance and data collection activities, and thus, costs and burdens

, are in curred over the course of the reporting cycle. Therefore, for purposes of this analysis, the burden and cost for one reporting cycle are averaged over the number of years in the reporting cycle and are presented here as average annual figures. All costs are presented in year 2008 dollars. The IUR requires reporting on a “per site” basis rather than a “per company ” basis

. T herefore, each site is

c onsidered a respondent and is likely to submit one Form U containing one or more chemical

specific report s

. EPA estimates that a total of 4, 085 respondents will respond to this information

collection in the 2011 reporting cycle, and 4,289 respondents will respond in future reporting cycles

.

Burden and cost calculations are based on the assumption that EPA will receive an average of 29,253 full reports and 6 18 partial reports during the first reporting cycle , and 30,716

fu ll reports and 649 partial reports in future reporting cycles

. Each report is for a single chemical/site combination. Each site is expected to submit an average of 7.16 full reports and 0.15 partial reports. The average burden per respondent, which is one site, is estimated to be 7 9 2 hours for the 2011 reporting cycle, or 1 58 hours annually over a f ive

- year cycle. For future four

year reporting cycles, the average burden per respondent is estimated to be 615 hours per cycle, or 154 hours annually

, over a fo ur

- year cycle. Given that this ICR addendum covers a time period that spans both the first and a future reporting cycle, t he average annual burden over the three year period of 2011 through 2013 is 155 hours. This is higher than the burden estimated for

th e currently approved ICR ) (EPA ICR No. 1884.04 , due to both program changes and an adjustment in reporting requirement criteria, including additional data requirements and modifications to reporting thresholds.

6(a) Estimating Respondent Burden

For th e 2011 reporting cycle, e ach manufacturing site (including importers) must submit a Form U if the site meets or exceeds the 25,000 lb. threshold for at least one chemical in the

2010 principal reporting year. In future cycles, this reporting threshold will apply for any calendar year since the last principal reporting year. For purposes of the ICR, one manufacturing site is equivalent to one respondent. Form U contains four Parts. Part I contains basic site identification information and must be completed b y all sites. Part II contains manufacturing data (production volumes, etc.) specific to each chemical, which also must be completed by all sites.Page 19 of 48



### Together, Part I and Part II are considered a “partial report.” Part III contains processing and use

informati on . Under the proposed amendments, Part III would be completed for all chemicals unless the chemical is specifically exempted from the requirement to do so. Part IV contains secondary company identification information and specific information identifying a chemical

substance. Part IV is completed only by a secondary respondent (see Section 2(b)). For purposes of this analysis, burden and costs associated with P art IV are considered part of the burden and

costs estimates of Part I ( respondent identification ) and the beginning of Part II (chemical identification)

, and therefore were not separately calculated. Together, P arts I, II, and III (and Part IV, when applicable) are considered a “full report.” Each report is submitted for a unique

chemical/site combin ation; that is, a site must complete a separate report for each applicable chemical, but Part I of Form U is completed only once per site

. EPA anticipates that it will be completed when respondents register with CDX . To comply with the regulation, manufact urers (including importers) must complete the following activities in Table 2. Table 2 also provides a

cross

- walk of the related Information Collection that corresponds to each activity.

Table 2 : Cross

- W alk between Industry Activities and Related Informat ion Collections ( ICs)
Activity Description Related IC(s) Compliance

Determination Site staff must determine whether reporting is required for a chemical manufactured (including imported ) at a particular site, based on the chemical’s production volume and the applicability of certain reporting exemptions. This involves determining whether the production volume of a chemical substance met or exceeded the 25,000 lb.

threshold in the 2010 principal reporting year for the 2011 submission period . In future repo rting cycles, site staff must determine whether the production

volume met or exceeded the threshold in the associated principal reporting cycle and in any calendar year since the last principal reporting year in future reporting cycles

. Compliance Determi nation

Rule

Familiarization Site staff must familiarize themselves with the requirements of the rule. Staff from sites that reported previously must become familiar with new requirements, and staff from sites new to reporting

must become familiar with all requirements. This entails reading the rule, understanding the various reporting and administrative requirements, and determining the manner in which the reporting requirements will be met. Rule Familiarization

CDX Registration Before submitting Form U, all respondent s must register with CDX. In addition, respondent s must complete an Electronic Signature Agreement form

, which is signed, dated, and notarized ; complete a

Verification of Company Authoriz ing Official form

, which is signed by an immediate su pervisor or witnessing official ; and mail both forms back to

EPA. CDX Registration Activities

Preparation of Reports Site staff must collect all of the required information,

and complete partial and/or full reports using a Form

U report form , for each of the reportable chemicals

at that site . The information must be reviewed, and submitted to EPA. This task involves any research Prepare and Submit Report, and

Maintain Records

Partial Report

Prepare and Submit Report, andPage 20 of 48

necessary to identify the correct information to report, the act of completing Form U (technical and clerical burden), and manage rial review. Once Form U is completed, company staff must submit it electronically to EPA via CDX. Maintain Records

– Full Report

Recordkeeping Respondent s mu st keep records supporting their submissions for five years. Prepare and Submit Report, and

Maintain Records

- Partial Report

Prepare and Submit Report, and

Maintain Records

Full Report



### Burden estimates were derived originally from a survey conduc ted by EPA in 1996 (under OMB Control No. 2070

- 0034) to assess the potential burden associated with the IUR, as amended at that time. The survey was distributed to previous IUR respondent s selected from the IUR database. Burden estimates were updated for a 2005 amendment to the rule as described in Economic Analysis of IUR Modifications Final Rule (EPA, 2005) 3 

### . Burden estimates for new reporting elements in the current proposal were derived as described in the Economic Analysis for the Proposed Inventory Up date Reporting (IUR) Modifications Rule ( EPA, 2010b )

.

Table 3 and Table 4 illustrate the burden for a typical respondent on a per

- activity basis, including time required to complete each section of Form U. Because IUR reporting for all respondents occurs within a required timeframe, which EPA is proposing to change from once every five years to once every four years, the Agency expects only one collection to occur , in
2001, during the three

- year period covered by this ICR addendum . Therefore, burden hour

e stimates for 2011 (Table 3) are based on the first reporting cycle burdens in the Economic Analysis for the Proposed Inventory Update Reporting (IUR) Modifications Rule ( EPA, 2010b ).

Burden hour estimates for 2012 and 2013 (Table 4) are based on the futur e reporting cycle

burdens as also described in the economic analysis ( EPA, 2010b )

. 4 

### The section

- by

- section industry burden estimates for report preparation also include the burden of compliance

determination and rule familiarization . EPA estimates the tota l industry burden for completing and submitting one partial report to be 57.36 hours, and the estimated burden for completing and submitting one full report, to be 140

. 38 hours in the first reporting cycle . Each site is expected to submit an average of 7.1 6 full reports and 0.15 partial reports.

EPA calculated burden estimates for each element of Form U individually using the 1996 survey results, economic analyses for other rules with similar requirements (such as the

Premanufacture Notification Electron ic Reporting final rule), and EPA’s best professional judgment. More detailed information on the derivation of these estimates is found in the IUR EA ( EPA, 2010b ).

3 The economic analysis for the 2005 Amendments assumed a 15 percent reduction in burden for the completion of Part III because submitters were no longer required to report use and downstream proce ssing information for

exports.

4 EPA believes that the burden for future reporting cycles will be reduced because of efficiencies achieved through the establishment of compliance processes; as described in the IUR EA (EPA, 2010b). A fter a site’s first repo rting cycle, the availability of data from previous reporting cycles and familiarity with reporting requirements will expedite the process for submitters who have previously submitted a Form U.Page 21 of 48



### Table 3 : Total Industry Burden, by Activity, First Reporting Cycle

Activity Clerical Burd e n (hours) Technical Burden (hours) Managerial

Burden (hours) Total Burden (hours)

(a) (b) (c) (d) = (a)+(b)+(c)
PREPARATION OF REPORT (Includes rule familiarization associated with each data element)

Part I. Site Identification Information

Certifica tion 0 .00 0.85 1.01 1.86 Company Information (Parent Company Name, D&B Number, Mailing Address , Technical Contact , Technical Contact Mailing Address) 0 .00 0.04 0.02 0.06

Plant Site Identification (Site Name, D&B Number, Mailing Address ) 0 .00 0.06 0. 02 0.08

Total for Part I 0.00 0.95 1.05 2.00

Part II. Manufacturing Information

Site

- Limited, Activity, Production Volume (lb

. ) 0.00 2.28 0.56 2.84

Chemical Identification Upfront CBI Substantiation 0.00 1.45 0.77 2.22

Plant Site Upfront Substa ntiation 0.00 0.83 0.51 1.34

Total Number of Workers 0.00 1.43 0.59 2.02 Maximum Concentration, Physical Form, Percent Volume of

Production 0.00 2.79 1.07 3.86

Production Volume for Each of the Years since Last Principal Repor ting Year 0.00 4.10 1.01 5.11

Production Volume Used On

- Site 0.00 0.20 0.05 0.25

Whether Imported Chemical is Physically at Reporting Site 0.00 0.11 0.03 0.14 Volume Exported 0.00 1.03 0.25 1.28

W hether a C hemical is to be R ecycled , R emanufactured,

R eprocessed, Re used, or Re worked 0.00 0.11 0.03 0.14

Total for Part II 0.00 14.34 4.85 19.19

Part III. Processing and Use Information

Upfront S ubstantiation for P rocessing and U se I nformation

CBI Claims 0.00 0.43 0.26 0.69

Industrial Processing and Use Exposure

- Related Data Determination of Applicability 0.00 1.01 0.28 1.29 Industrial Function Category 0.00 4.67 2.07 6.73

Sector 0.00 0.94 0.40 1.33Page 22 of 48

Activity Clerical Burd e n (hours) Technical Burden (hours) Managerial

Burden (hours) Total Burden (hours)

(a) (b) (c) (d) = (a)+(b)+(c)

Percent of Production Volume 0.00 10.00 5.27 15.27
Total Number of Processing and Use Sites 0. 00 9.14 3.52 12.67 Total Number of Potentially Exposed Workers 0.00 15.43 3.83 19.26
Consumer and Commercial Use Exposure

- Related Data
Determination of Applicability 0.00 0.94 0.25 1.19 Identification of Production Category/Use by Children 0 .00 1.68 0.25 1.92

Percent of Production Volume 0.00 1.26 0.45 1.71
Maximum Concentration by Category 0.00 1.36 0.34 1.70

Number of C ommercial W orkers R easonably L ikely to be

E xposed 0.00 15.43 3.83 19.26

Total for Part III 0.00 62.26 20.7 6 83.02

COMPLIANCE DETERMINATION

Compliance Determination 0.00 2.50 0.00 2.50

RULE FAMILIARIZATION

Rule Familiarization 0.00 19.00 9.00 28.00

CDX REGISTRATION ACTIVITIES

CDX Registration 0.00 0. 73 0.18 0. 92
CDX Electronic Signature Agre ement 0.00 1.00 0.75 1.75

Total for CDX Registration Activities 0.00 1,73 0.93 2.67

RECORDKEEPING

Recordkeeping 0.75 1.50 0.75 3.00

TOTAL BURDEN

Burden for one Partial 0.75 Report (Parts I, II, Compliance Determination, Rule Familiarization, Recordkeepi ng and CDX Registration Activities ) 38.29 15.65 57.36

Burden for one Full 0.75 Report (Parts I, II, III, Compliance Determination, Rule Familiarization, Recordkeeping and CDX Registration Activities ) 100.55 36.41 140.38

Note: Totals may not sum due to rounding

. Source: Economic Analysis for the Proposed Inventory Update Reporting (IUR) Modifications Rule ( EPA, 2010b )

.Page 23 of 48



### Table 4: Total Industry Burden, by Activity, Future Reporting Cycles

Activity Clerical Burde n (hours) Technical Burden (hours) Mana gerial

Burden (hours) Total Burden (hours)

(a) (b) (c) (d) = (a)+(b)+(c)
PREPARATION OF REPORT (Includes rule familiarization associated with each data element)

Part I. Site Identification Information

Certification 0.00 0.85 1.01 1.86 Company Infor mation (Parent Company Name,, D&B Number, Mailing Address , Technical Contact , Technical Contact Mailing Address) 0.00 0.01 0.00 0.01

Plant Site Identification (Site Name, D&B Number, Mailing Address ) 0.00 0.01 0.00 0.02

Total for Part I 0.00 0.95 1.05 2.00

Part II. Manufacturing Information

Site

- Limited, Activity, Production Volume (lb

. ) 0.00 1.82 0.45 2.27

Chemical Identification Upfront CBI Substantiation 0.00 1.16 0.61 1.77

Plant Site Upfront Substantiation 0.00 0.66 0.41 1.07

Total Numbe r of Workers 0.00 1.14 0.47 1.61 Maximum Concentration, Physical Form, Percent Volume of

Production 0.00 2.23 0.86 3.09

Production Volume for Each of the Years since Last Principal Repor ting Year 0.00 3.28 0.81 4.09

Production Volume Used On

- Site 0.00 0.16 0.04 0.20

Whether Imported Chemical is Physically at Reporting Site 0.00 0.09 0.02 0.11 Volume Exported 0.00 0.82 0.20 1.02

W hether a C hemical is to be R ecycled , R emanufactured,

R eprocessed, Reused, or Re worked 0.00 0.09 0.02 0.11

Tot al for Part II 0.00 11.47 3.88 15.35

Part III. Processing and Use Information

Upfront S ubstantiation for P rocessing and U se I nformation

CBI Claims 0.00 0.43 0.21 0.64

Industrial Processing and Use Exposure

- Related Data Determination of Applicab ility 0.00 0.81 0.23 1.03 Industrial Function Category 0.00 3.53 1.65 5.18

Sector 0.00 0.75 0.32 1.06Page 24 of 48

Activity Clerical Burde n (hours) Technical Burden (hours) Mana gerial

Burden (hours) Total Burden (hours)

(a) (b) (c) (d) = (a)+(b)+(c)

Percent of Production Volume 0.00 8.00 4.22 12.22
Total Number of Processing and Use Sites 0.00 7.31 2.82 10.13

Total Number of Poten tially Exposed Workers 0.00 12.34 3.06 15.41
Consumer and Commercial Use Exposure

- Related Data
Determination of Applicability 0.00 0.75 0.20 0.95 Identification of Production Category/Use by Children 0.00 0.67 0.20 0.87

Percent of Productio n Volume 0.00 1.01 0.36 1.37
Maximum Concentration by Category 0.00 1.09 0.28 1.36

Number of C ommercial W orkers R easonably L ikely to be

E xposed 0.00 12.34 3.06 15.41

Total for Part III 0.00 49.03 16.60 65.63

COMPLIANCE DETERMINATION

Complia nce Determination 0.00 2.50 0.00 2.50

RULE FAMILIARIZATION

Rule Familiarization 0.00 2.00 2.00 4.00

CDX REGISTRATION ACTIVITIES

CDX Registration 0.00 0.73 0.18 0.92
CDX Electronic Signature Agreement 0.00 1.00 0.75 1.75

Total for CDX Regi stration Activities 0.00 1.73 0.93 2.67

RECORDKEEPING

Recordkeeping 0.75 1.50 0.75 3.00

TOTAL BURDEN

Burden for one Partial 0.75 Report (Parts I, II, Compliance Determination, Rule Familiarization, Recordkeeping and CDX Registration Activities ) 18.34 7.65 29.41

Burden for one Full 0.75 Report (Parts I, II, III, Compliance Determination, Rule Familiarization, Recordkeeping and CDX Registration Activities ) 67.37 24.26 95.04

Note: Totals may not sum due to rounding

. Source: Economic Analysis for the P roposed Inventory Update Reporting (IUR) Modifications Rule ( EPA, 2010b )

.Page 25 of 48



### 6(b) Estimating Cost

EPA multiplied b urden estimates by standard wage rates for managerial, technical, and clerical levels developed from information published by the Bureau of L abor Statistics (BLS)

and a method outlined in the document Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b). Wage data for the three occupational categories was gathered for manufacturing industries from Employer Costs for Employee Compensation Supplementary

Tables: Historical Data December 2006

– December 2008 (BLS, 2009).

The cost of fringe benefits, such as he alth insurance and vacation, is taken for each labor category from the same ECEC series. Following the metho dology outlined in (EPA, 2002b), fringe benefits are calculated as a percentage of total wages for each category. EPA added 17 percent to the wages in each category to account for overhead, based on information provided by the chemical industry and chemica l industry trade associations in the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a). The wages for each of the three categories were then multiplied by benefits and overhead factors to estimate loaded, annual

sal aries in year 2008 dollars. Table 5 contains the loaded wage rates f or the managerial, technical and clerical occupation categories.

Table 5 : Derivation of Loaded Wage Rates for the Private Manufacturing Sector in 2008 $

Wage 1 Fringe

Benefits 1 Fringes as %

of Wage Overhead %

of Wage 2 Fringe +

Overhead

Factor Loaded Wages

(a) (b) (c) = (b)/(a) (d) (e)=(1)+(c)+(d) (f) = (a) x (e) Managerial $43.22 $19.46 48.37% 17% 1.62 $70.03

Technical $35.29 $17.55 47.58% 17% 1.67 $58.84

Clerical $17.22 $8.33 45.0 3% 17% 1.65 $28.48

1 Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006

– December
2008, US Bureau of Labor Statistics, March 12, 2009 (BLS, 2009).

2 An overhead rate of 17 percent was estimated based on industry data gathered for the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002 a )

.



### Table 6 contains the cost per activity of completing Form U for one respondent in the first reporting cycle . Burden hours presented in Tabl e 3 were multiplied by the corresponding loaded wage rage in Table 5 . EPA estimates the total cost for completing and submitting one partial report in the first reporting cycle is $ 3,538 and the cost for completing and submitting one full report is $ 8,655

. More information on the derivation of these costs is found in the IUR EA ( EPA, 2010b ).

Similarly, Table 7 contains the cost per activity of completing Form U for one respondent in future reporting cycles . Burden hours presented in Table 4 were multiplied by the corresponding loaded wage rage in Table 5 . EPA estimates the total cost for completing and submitting one partial report in future reporting cycle s is $ 1 ,636 and the cost for completing and submitting one full report is $ 5,684 . More information on the derivation of these costs is found in the IUR EA ( EPA, 2010b ).Page 26 of 48



### Table 6 : Total Industry Cost

, by Activity , First Reporting Cycle

Activity Clerical Cost ( 2008 $ ) Technical Cost ( 2008 $ ) Managerial

Cost ( 2008) Total Cost ( 2008 $ )

(a) (b) (c) (d) = (a)+( b)+(c)
PREPARATION OF REPORT (Includes rule familiarization associated with each data element)

Part I. Site Identification Information

Certification $0.00 $50.01 $70.73 $120.74
Company Information (Parent Company Name, D&B Number, Mailing Address , Te chnical Contact , Technical Contact Mailing Address) $0.00 $2.35 $1.40 $3.75

Plant Site Identification (Site Name, D&B Number, Mailing Address ) $0.00 $3.53 $1.40 $4.93

Total for Part I $0.00 $55.90 $73.53 $129.43

Part II. Manufacturing Information

Site

- Limited, Activity, Production Volume (lbs) $0.00 $134.15 $32.95 $167.10

Chemical Identification Upfront CBI Substantiation $0.00 $85.32 $45.01 $130.33

Plant Site Upfront Substantiation $0.00 $48.84 $30.01 $78.84

Total Number of Workers $0.0 0 $84.14 $34.42 $118.56
Maximum Concentration, Physical Form, Percent Volume of

Production $0.00 $164.16 $62.96 $227.12

Production Volume for Each of the Years since Last Principal Report ing Year $0.00 $241.48 $59.31 $300.79

Production Volume Used On

- Site $0.00 $11.71 $2.88 $14.59

Whether Imported Chemical is Physically at Reporting Site $0.00 $6.71 $1.65 $8.36
Volume Exported $0.00 $60.37 $14.83 $75.20

W hether a C hemical is to be R ecycled , R emanufactured,

R eprocessed, Reused, or Re worked $0.00 $6.71 $1.65 $8.36

Total for Part II $0.00 $843.58 $339.98 $1,183.56

Part III. Processing and Use Information

Upfront S ubstantiation for P rocessing and U se I nformation

CBI Claims $0.00 $25.12 $18.37 $43.49

Industrial Processing and Use Expos ure

- Related Data Determination of Applicability $0.00 $59.27 $19.94 $79.21 Industrial Function Category $0.00 $274.49 $144.64 $419.13

Sector $0.00 $55.01 $27.68 $82.69Page 27 of 48

Activity Clerical Cost ( 2008 $ ) Technical Cost ( 2008 $ ) Managerial

Cost ( 2008) Total Cost ( 2008 $ )

(a) (b) (c) (d) = (a)+( b)+(c)

Percent of Production Volume $0.00 $588.41 $369.34 $957.75

Total Num ber of Processing and Use Sites $0.00 $537.89 $246.72 $784.62 Total Number of Potentially Exposed Workers $0.00 $907.74 $268.15 $1,175.90
Consumer and Commercial Use Exposure

- Related Data
Determination of Applicability $0.00 $55.01 $17.56 $72.57
Identification of Production Category/Use by Children $0.00 $98.73 $17.26 $116.00

Percent of Production Volume $0.00 $74.02 $31.55 $105.57

Maximum Concentration by Category $0.00 $80.02 $24.11 $104.13

Number of C ommercial W orkers R eason ably L ikely to be

E xposed $0.00 $907.74 $268.15 $1,175.90

Total for Part III $0.00 $3,663.47 $1,453.48 $5,116.95

COMPLIANCE DETERMINATION

Compliance Determination $0.00 $147.10 $0.00 $147.10

RULE FAMILIARIZATION

Rule Familiarization $0.00 $1,117 .95 $630.25 $1,748.19

CDX REGISTRATION ACTIVITIES

CDX Registration $0.00 $43.15 $12.84 $55.99

CDX Electronic Signature Agreement $0.00 $58.84 $52.52 $111.36

Total for CDX Registration Activities $ 0.00 $101.99 $65.36 $167.35

RECORDKEEPING

Recordkeeping $21.36 $88.26 $52.52 $162.14

TOTAL COST

Cost for one Partial $21.36 Report (Parts I, II, Compliance Determination, Rule Familiarization, Recordkeeping and CDX Registration Activities ) $2,354.77 $1,161.63 $3,537.76

Cost for one Full $21.36 Report (Parts I, II, III, Compliance Determination, Rule Familiarization, Recordkeeping and CDX Registration Activities ) $6,018.24 $2,615.11 $8,654.71

Note: Totals may not sum due to rounding

. Source: Economic Analysis for the Proposed Invento ry Update Reporting (IUR) Modifications Rule ( EPA, 2010b )

.Page 28 of 48



### Table 7 : Total Industry Cost

, by Activity , Future Reporting Cycle s

Activity Clerical Cost (2008$) Technical Cost (2008$) Managerial

Cost (2008) Total Cost (2008$)

(a) (b) (c) (d) = (a)+(b)+(c)
PREPARATION OF REPORT (Includes rule familiarization associated with each data element)

Part I. Site Identification Information

Certification $0.00 $50.01 $70.73 $120.74
Company Information (Parent Company Name, D&B Number, Mailing Address , Techn ical Contact , Technical Contact Mailing Address) $0.00 $0.47 $0.28 $0.75

Plant Site Identification (Site Name, D&B Number, Mailing Address ) $0.00 $0.71 $0.28 $0.99

Total for Part I $0.00 $51.19 $71.29 $122.48

Part II. Manufacturing Inform ation

Site

- Limited, Activity, Production Volume (lbs) $0.00 $107.32 $31.37 $138.70

Chemical Identification Upfront CBI Substantiation $0.00 $68.25 $42.86 $111.11

Plant Site Upfront Substantiation $0.00 $39.07 $28.57 $67.64

Total Number of Workers $0.00 $67.31 $32.77 $100.08
Maximum Concentration, Physical Form, Percent Volume of

Production $0.00 $131.33 $59.94 $191.27

Production Volume for Each of the Years since Last Principal Report ing Year $0.00 $193.18 $56.47 $249.65

Production Volume Used On

- Site $0.00 $9.37 $2.74 $12.11

Whether Imported Chemical is Physically at Reporting Site $0.00 $5.37 $1.57 $6.93
Volume Exported $0.00 $48.30 $14.12 $62.41

W hether a C hemical is to be R ecycled , R emanufactured,

R eprocessed, Reused, or Re worked $0.00 $5.37 $1.57 $6.93

Total for Part II $0.00 $674.87 $271.98 $946.85

Part III. Processing and Use Information

Upfront S ubstantiation for P rocessing and U se I nformation

CBI Claims $0.00 $25.12 $14.70 $39.8 2

Industrial Processing and Use Exposure

- Related Data Determination of Applicability $0.00 $25.12 $15.95 $41.07 Industrial Function Category $0.00 $0.00 $115.71 $115.71

Sector $0.00 $47.41 $22.14 $69.56Page 29 of 48

Activity Clerical Cost (2008$) Technical Cost (2008$) Managerial

Cost (2008) Total Cost (2008$)

(a) (b) (c) (d) = (a)+(b)+(c)

Percent of Production Vol ume $0.00 $207.82 $295.47 $503.30
Total Number of Processing and Use Sites $0.00 $44.01 $197.38 $241.39 Total Number of Potentially Exposed Workers $0.00 $470.73 $214.52 $685.25
Consumer and Commercial Use Exposure

- Related Data

Deter mination of Applicability $0.00 $47.41 $14.05 $61.46
Identification of Production Category/Use by Children $0.00 $207.82 $13.81 $221.63

Percent of Production Volume $0.00 $44.01 $25.24 $69.25

Maximum Concentration by Category $0.00 $4 70.73 $19.29 $490.01

Number of C ommercial W orkers R easonably L ikely to be

E xposed $0.00 $430.32 $214.52 $644.84

Total for Part III $0.00 $2,884.62 $1,162.78 $4,047.40

COMPLIANCE DETERMINATION

Compliance Determination $0.00 $147.10 $0.00 $147.10

RULE FAMILIARIZATION

Rule Familiarization $0.00 $117.68 $140.05 $257.73

CDX REGISTRATION ACTIVITIES

CDX Registration $0.00 $43.15 $12.84 $55.99

CDX Electronic Signature Agreement $0.00 $58.84 $52.52 $111.36

Total for CDX Regi stration Activities $ 0.00 $101.99 $65.36 $167.35

RECORDKEEPING

Recordkeeping $21.36 $88.26 $52.52 $162.14

TOTAL COST

Cost for one Partial $21.36 Report (Parts I, II, Compliance Determination, Rule Familiarization, Recordkeeping and CDX Registration Acti vities ) $1,079.09 $535.84 $1,636.29

Cost for one Full $21.36 Report (Parts I, II, III, Compliance Determination, Rule Familiarization, Recordkeeping and CDX Registration Activities ) $3,963.71 $1,698.63 $5,683.70

Note: Totals may not sum du e to rounding

. Source: Economic Analysis for the Proposed Inventory Update Reporting (IUR) Modifications Rule ( EPA, 2010b )

.Page 30 of 48



### 6(c) Estimating Agency Burden and Cost

EPA is responsible for the following activities associated with administering the IUR rule:

**•** Document receipt and tracking;

**•** Data entry and quality control of data entry;

**•** Backup systems operation;

**•** Data processing;

**•** Systems development;

**•** Contract oversight and management;

**•** Publication and printing of forms and materials; and

**•** Operation of the TSCA Hotline to handle IUR

- related calls.

Costs related to EPA activities that involve using the data are not included.

EPA Staff Activities

Of the tasks listed above, Agency personnel are responsible for 1) quality control of data entry; and 2) data processing, systems development, and contract oversight and management. Contractors perform the other activities, as described below.

EPA estimates the total burden of completing Agency tasks to be one full

- time equivalent

at the GS 13 level for data pro cessing, systems development, and contract oversight and

management, per

- report ing cycle. An estimated 0.181 FTEs are needed at the GS 12 level for quality control of data entry. Calculations of the Agency burden are presented in Economic Analysis for the Proposed Inventory Update Reporting (IUR) Modifications Rule ( EPA, 2010b ).

EPA labor costs are based on annual federal wage rates published by the Office of Personnel Management for the Washington

- Baltimore

- Northern Virginia, DC

- MD

- PA

- VA

- WV locality pay area for 2008 (OPM, 2008). Wages are presented in terms of GS

- level and step. Based on previous IUR economics analyses, a Step 3 is assumed for all FTEs (EPA, 2002a and EPA, 2005). Following the methodology outlined in Economic Analysis for the Amended

Inv entory Update Rule: Final Report (EPA, 2002a), EPA added 58 percent to the wage rate to account for fringe benefits and overhead costs.

Table 8 shows the loaded wage rates for Agency staff at the GS

- 12 Step 3, an d GS

- 13 Step 3 levels.Page 31 of 48



### Table 8 : D erivatio n of Loaded Agency Wage Rates (2008 $ )

Pay Grade Annual Salary Overhead and Fringe

Benefits ( % of w ages ) Overhead and Fringe

Benefit Cost Total

GS 12 Step 3 $77,416 58% $44,901 $122,317

GS 13 Step 3 $88,493 5 8% $51,326 $139,819

Source: The unloaded Federal salary for 2008 is from the Office of Personnel Management salary table for Washington

- Baltimore

- Northern Virginia (OPM, 2008).



### Table 9 contains the burden and c ost per report for all EPA staff activities. The activities performed by the GS

- 13 level staff member, including systems development, and contract oversight and management, are fixed costs and are not dependent on the number of reports

submitted to EPA. Th erefore, the total burden for systems development and contract oversight is

one FTE at the GS

- 13 level, with a cost of $139,819. Quality control of data entry is performed by the GS

- 12 level staff member and is dependent on the number of reports received. The burden for quality control of data is approximately 0.000054 FTE per report and the total cost per

- report is approximately $0.81. The burden and cost of processin g each data element in Form U are

derived in the Economic Analysis for the Proposed Invent ory Update Reporting (IUR) Modifications Rule ( EPA, 2010b ). EPA multiplied the burdens by the number of data elements in each section to estimate the total cost and burden of processing each Form U. For more detail on

the derivation of these burdens

, see t he IUR EA ( EPA, 2010b ).

Table 9 : EPA Staff Burden and Cost of Processing One Report

Activity Agency Burden per Activity (FTE) Agency Burden per Activity (hours) Agency Cost per Activity

( 2008$ )

GS

- 12 Step 3 per

- Report Burden Quality Control of Data fo r Part I 0.0000009 0.0019 $0.11
Quality Control of Data for Part II 0.0000027 0.0056 $0.33
Quality Control of Data for Part III 0.0000030 0.0063 $0.37

Total GS

- 12 Burden, per report 0.0000066 0.0138 $0.81

GS

- 1 3 Step 3 Fixed Cost Burden Systems dev elopment, and contract oversight and management 1 2,080 $139,819

Total GS

- 13 Burden, per reporting cycle 1 2,080 $139,819



### Contractor Activities

Agency costs also include payment for extramural tasks completed by contractors (this category includes co sts to EPA, but not burden hours). Contractor activities include document receipt, tracking, data entry, maintaining backup systems, printing and publishing forms and materials, and managing the TSCA hotline, as presented in Table 10 . With the exception of document receipt, tracking, and data entry, all contractor costs are fixed and are not dependent on the number of reports received. All fixed costs are taken from the last published ICR and were

inflated from 2007 to 2008 dollars with an inflation factor calculated using the Employment Cost Index (ECI), seasonally adjusted, for white

- collar occupations in private industry (BLS, 2009).Page 32 of 48



### EPA calculated the cost estimate per report for document receipt, tracking, and data entry, $0.63, by starting with the c ost estimated in the 2007 ICR, and updating it to reflect the new data elements and the electronic submission requirement in the proposed amendments. The reduction in burden caused by the electronic submission requirement is based on a study conducted by E PA, “A Business Case Analysis of EPA’s Central Data Exchange” (EPA, 2007), of the costs and benefits of the electronic Central Data Exchange (CDX) system. The study estimates an 88.6 percent decrease in EPA processing burden as a result of using the CDX

sy stem. For more information, see the Economic Analysis for the Proposed Inventory Update Reporting (IUR) Modifications Rule ( EPA, 2010b ).

Table 10 : C ost of Contractor Activities

Activity Annual Cost ( 200 7 $ ) Inflation

Factor Annual Cost ( 2008$ )

Variable Costs Document receipt, tracking, and data entry for Part I $0.78 n/a $0.09

Document receipt, tracking, and data entry for Part II $1.92 n/a $0.25

Document receipt, tracking, and data entry for Part III $2.45 n/a $0.29

Total Cost of Document receipt

, tracking, and data entry

, per full
report $ 5.14 n/a $0.63

Fixed Costs Maintaining and Operating Back

- Up Systems $56,711 1.04 $59,145

Printing and Publishing Forms and

Materials $5,298 1.04 $5,525

Managing the TSCA Hotline $42,855 1.04 $44,694

Total Fixed Cost $104,864 n/a $109,364



### 6(d) Bottom

- Line Industry Burden and Cost Estimates

This section describes the estimated total social paperwork burden and cost of the IUR rule, including the proposed amendments. The next IUR submission period w ill occur in 2011

for chemicals manufactured (including imported) during the calendar year 2010. Even though reporting occurs only once per reporting cycle (once every five years for the 2011 cycle and, as proposed, once every four years in the future), EP A believes rule compliance and data collection activities, and thus, costs and burdens

, are in curred over the course of the reporting cycle. Therefore, for purposes of this analysis, the burden and cost for one reporting cycle are averaged

over the number of years in the reporting cycle and are presented here as average annual figures.

This ICR addendum supporting statement is for the three

- year period of 2011 through 2013; therefore, average annual figures for each of these three years are presented below

.

Respondent tally

EPA calculated t he numbers of sites and reports submitted based on submission information from the December 2008 version of the IUR database, which includes data from thePage 33 of 48



### most recent (2006) IUR collection. The EPA IUR database contains information collected under the IUR for previous submission periods and was used to generate estimates of expected reports for the 2011 reporting cycle. In the 2011 reporting year, EPA expects a total of 4, 085 sites to
submit 29,253 full reports (98 perce nt of all reports) and 6 18 partial reports (two percent of all reports) for a total of 29,871 reports. In future reporting cycles , EPA expects 4,289 sites to submit 30,716 full reports and 649 partial reports for a total of 31,365 reports (98 percent and

two percent of all reports, respectively)

.

Total Industry Burden/ Cost for First Reporting Cycle

. EPA estimates t he total industry burden for the first reporting cycle, including both current baseline burden and the burden resulting from the proposed ame ndments, to be 3. 24 million hours. Given that this data

collection is part of a five

- year reporting cycle , EPA estimates the annual industry burden for

2011 to be 647,016 hours. As presented in Table 11

, EPA estimates the total cost to industry would be $ 1 99 million, or an annual cost of $ 39.7 million.

Table 11 : Estimated Respondent Burden and Cost Associated with the F irst Reporting Cycle (2011)

Activity Total

Burden

per Activity (hours) Total

Number of

Units Total Cost per Activity (2008$) Total

Burden

p er Reporting

Cycle (hours) Total Cost

per Reporting

Cycle (2008$) Annual

Burden (hours) Annual

Cost (hours)

Compliance

Determination (per Site) 2.50 4, 085 S ites $147.10 10,213 $600,896 2,043 $120,179

Rule

Familiarization (per Site) 28.00 4, 085 S ites $1 ,748.19 114,380 $7,141,370 22,876 $1,428,274

CDX Registration Activities (per Site) 2.67 4, 085 S ites $111.36 10,893 $454,905 2,179 $90,981

Part I Preparation (per site) 2.00 4,085 Sites $129.43 8,170 $528,706 1,634 $105,741

Partial Report Preparation (Part II, per Report) 19.19 6 18 Partial Reports $1,183.56 11,861 $731,438 2,372 $146,288

Full Report Preparation (Part II and Part III, per Report) 102.21 29,253 Full Reports $6,300.50 2,989,951 $184,308,643 597,990 $36,861,729

Recordkeeping (per Repor t) 3.00 29,871 Reports $162.14 89,613 $4,843,211 17,923 $968,642

Total Industry Burden and Cost for the First Reporting Cycle 3,235,080 $198,609,168 647,016 $39,721,834Page 34 of 48



### Total Industry Burden and Cost for Future Reporting Cycles

. EPA estimates the total industry burden for future reporting cycle s , including both current baseline burden and the burden resulting from the proposed amendments, to be 2.64 million hours. Given that this data

collection will occur every four years , EPA estimates the annual indu stry burden for future years

to be 659,742 hours. As presented in Table 12

, EPA estimates the total cost to industry would be $ 162 million, or an annual cost of $40.5 million.

Table 12 : Estimated Annual Respondent Burden and Cost Associated with F uture Re porting Cycle s

Activity Total

Burden

per Activity (hours) Total

Number of

Units Total Cost per Activity (2008$) Total

Burden (hours) Total Cost

per Reporting

Cycle (2008$) Annual

Burden (hours) Annual

Cost (hours)

Compliance

Determination (per Site) 2.50 4, 289 S ites $147.10 10,723 $630,904 2,681 $157,726

Rule Familiarization (per Site) 4.00 4, 289 S ites $257.73 17,156 $1,105,419 4,289 $276,355

CDX Registration Activities (per Site) 2.67 4, 289 S ites $167.35 11,437 $717,751 2,859 $179,438

Part I Preparat ion (per S ite) 1.89 4,289 Sites $122.48 8,098 $525,309 2,024 $131,327

Partial Report Preparation (Part II, per Report) 15.35 6 49 Partial Reports $946.85 9,964 $614,503 2,491 $153,626

Full Report Preparation (Part II and Part III, per Report) 80.98 30,7 16 Full Reports $4,994.25 2,487,494 $153,403,359 621,873 $38,350,840

Recordkeeping (per Report) 3.00 31,365 Reports $162.14 94,095 $5,085,444 23,524 $1,271,361

Total Industry Burden and Cost for

Future Reporting Cycle s 2,638,966 $162,082,689 659,742 $4 0,520,672Page 35 of 48



### Annual Industry Burden and Cost for 2011 to 2013. As shown in Table 13, EPA

calculated the estimated total annual respondent burden and cost associated with this ICR

a ddendum by taking a weighted average of the first and future reporting cyc les, to reflect that the period covered by this ICR, 2011 through 2013, spans two reporting cycles with different

burdens and costs. The total annual burden associated with this ICR a ddendum is 655,500 hours. The total annual cost is $40.3 million.

Ta ble 13: Estimated Annual Average Burden and Cost Associated with this ICR Addendum

Activity 2011 2012 2013 2011

- 2013 Average

Annual

Burden (hours) Annual

Cost (2008$) Annual

Burden (hours) Annual

Cost (2008$) Annual

Burden (hours) Annual

Cost (2008$) To tal

Annual

Burden (hours) Total

Annual

Cost (2008$) Compliance

Determination (per S ite) 2,043 $120,179 2,681 $157,726 2,681 $157,726 2,468 $145,210

Rule

Familiarization (per Site) 22,876 $1,428,274 4,289 $276,355 4,289 $276,355 10,485 $660,328

CDX Regi stration

Activities (per Site) 2,179 $90,981 2,859 $179,438 2,859 $179,438 2,632 $149,952

Part I Preparation (per S ite) 1,634 $105,741 2,024 $131,327 2,024 $131,327 1,894 $122,798

Partial Report Preparation (Part II, per Report) 2,372 $146,288 2,491 $153 ,626 2,491 $153,626 2,451 $151,180

Full Report Preparation (Part II and Part III, per Report) 597,990 $36,861,729 621,873 $38,350,840 621,873 $38,350,840 613,912 $37,854,469

Recordkeeping (per Report) 17,923 $968,642 23,524 $1,271,361 23,524 $1,271,361 2 1,657 $1,170,455

Total 655,500 $40,254,393Page 36 of 48



### Average Burden and Cost per Site. As shown in Table 1 4 , t he Agency estimates the typical respondent burden for this i n formation collection activity to be 792 hours in the first reporting cycle and 615 hours in future reporting cycles

. Given that the 2011 (first) collection is

based on a five

- year reporting cycle, the average annual burden for the first reporting cycle would be 158 hours. Given that a collection would occur once every four years under the

pro posed rule, the average annual burden for future cycles would be 154 hours. Th e s e burden

estimate s assume each site will submit an average of 7.16 full reports and 0.15 partial reports in

both the next , and future, reporting cycle. This is a decrease of 2. 01 partial reports per site and an increase of 2.98 full reports per site compared to the average number of reports completed per site presented in the current ly approved ICR (EPA ICR No. 1884.04)

.

Table 1 4 : Average Burden per Site

Activity Burden Hour s Total

Hours

per Activity Reports

per Average

Site Total

Burden (h ours

per

average

site) Annual

Burden (hours

per

average

site) Managerial Technical Clerical

First Reporting Cycle

Rule Familiarization. Compliance Determination, CDX Registration Activities and Part I Preparation (per S ite) 10.98 24.18 0.00 35.17 1.00 35.17 7.03

Partial Report Preparation (Part II, per Report) 4.85 14.34 0.00 19.19 0.15 2.90 0.58

Full Report Preparation (Part II and Part III, per Report) 25.61 76.60 0.00 102. 21 7.16 732 146

Recordkeeping (per Report) 0.75 1.50 0.75 3.00 7.31 21.9 4.39

Total Hours 792 158
Future Reporting Cycles

Rule Familiarization. Compliance Determination, CDX Registration Activities and Part I Preparation (per site) 3.95 7.10 0.00 11. 05 1.00 11.05 2.76

Partial Report Preparation (Part II, per Report) 3.88 11.47 0.00 15.35 0.15 2.32 0.58

Full Report Preparation (Part II and Part III, per Report) 20.49 60.50 0.00 80.98 7.16 580 145

Recordkeeping (per Report) 0.75 1.50 0.75 3.00 7.31 21.9 5.48

Total Hours 615 154Page 37 of 48



### Table 1 5 presents the average cost per site, by activity

, for an IUR respondent . EPA estimates the average site will submit 7.16 full reports and 0.15 partial reports and incur a total cost of $ 48, 678 during the first repor ting cycle ($9,736 annually), and $37,790 during future reporting cycle s ($9,448 annually) for Form U completion and submission.

Table 1 5 : Average Cost per Site

Activity Cost (2008$) Total

Cost

per Activity Reports

per Av era g e

Site Total

Cost ( 2008$

per

average

site) Annual

Cost (2008$

per

average

site) Managerial Technical Clerical

First Reporting Cycle

Rule Familiarization. Compliance Determination, CDX Registration Activities and Part I Preparation (per site) $769.13 $1,423 $0.00 $2 ,192.

06 1.00 $2,192 $438

Partial Report Preparation (Part II, per Report) $339.98 $843.58 $0.00 $1,183.

56 0.15 $179 $35.82

Full Report Preparation (Part II and Part III, per Report) $1,793.45 $4,507 $0.00 $6,300.

50 7.16 $45,122 $9,024

Recordkeeping (p er Report) $52.52 $88.26 $21.36 $162.14 7.31 $1,186 $237

Total Cost $48,678 $9,736
Future Reporting Cycles

Rule Familiarization. Compliance Determination, CDX Registration Activities and Part I Preparation (per site) $276.70 $417.96 $0.00 $694.66 $1.00 $695 $174

Partial Report Preparation (Part II, per Report) $271.98 $674.87 $0.00 $946.85 $0.15 $143 $35.82

Full Report Preparation (Part II and Part III, per Report) $1,434.76 $3,559.49 $0.00 $4,994.

25 $7.16 $35,767 $8,942

Recordkeeping (per Report) $ 52.52 $88.26 $21.36 $162.14 $7.31 $1,186 $296

Total Cost $37,790 $9,448Page 38 of 48



### As shown in Table 16 , EPA calculated the estimated burden and cost per site associated

with this ICR a ddendum by taking a weighted average of the first and future reporting cycles to reflect that the period covered by this ICR addendum , 2011 through 2013, spans two reporting cycles with different burdens and costs. The average annual burden per site is 155 hours and the average annual cost per site is $9,544

.

Table 16 : Estimated Annual Burden and Cost per Site Associated with this ICR Addendum

Activity 2011 2012 2013 2011

- 2013 Average

Annual

Burden (hours) Annual

Cost (2008$) Annual

Burden (hours) Annual

Cost (2008$) Annual

Burden (hours) Annual

Cost (2008$) Annual

Burden (hours ) Annual

Cost (2008$)

Rule

Familiarization. Compliance Determination,

CDX Registration

Activities and

Part I Preparation (per site) 7.03 $438 2.76 $174 2.76 $174 4.19 $262

Partial Report Preparation (Part II, per Report) 0.58 $35.82 0.58 $36 0.58 $36 0.58 $36

Full Report Preparation (Part II and Part III, per Report) 146 $9,024 14 5 $8,942 14 5 $8,942 145 $8,969

Recordkeeping (per Report) 4.39 $237 5.48 $296 5.48 $296 5.12 $277

Total 155 $9,544



### Table 17 presents the burden hours, organized by in formation collection, for both the first

and future reporting cycle

, and weighted, annual average s for the ICR addendum period, for IUR respondents.Page 39 of 48



### Table 1 7 : Information Collection Tally for First and Future Reporting Cycles

I nformation Collection No. of Respondents No. of Responses / Respondent Responses

Subtotal Burden

Hours

per Response Burden Hours

Subtotal

First Reporting Cycle Compliance Determination 4,085 1 4

, 085 2.50 10,213

Rule Familiarization 4,085 1 4

, 085 28.00 114,380 CDX Registration A ctivities 4,085 1 4

, 085 4.67 19,063

**−** CDX Registration 4,085 1 4

, 085 0.92 3,745

**−** ESA 4,085 1 4

, 085 1.75 7,149

**−** Part I of Form U 4,085 1 4

, 085 2.00 8,170 Prepare and Submit Report, and

Maintain Records

– Partial Report 4,085 0.15 618 22.19 13,718

**−** Part II of Form U 4,085 0.15 618 19.19 11,863

**−** Recordkeeping 4,085 0.15 618 3 .00 1,854 Prepare and Submit Report, and

Maintain Records

- Full Report 4,085 7.16 29,255 105.21 3,077,924

**−** Part II and III of Form U 4,085 7.16 29,255 102.21 2,990,159

**−** Recordkeeping 4, 085 7.16 29,255 3 .00 87,765

Future Reporting Cycle s Compliance Determination 4,289 1 4,289 2.50 10,723

Rule Familiarization 4,289 1 4,289 4.00 17,156 CDX Registration Activities 4,289 1 4,289 4.55 19,535

**−** CDX Registration 4,289 1 4,289 0.92 3,932

**−** ESA 4,289 1 4,289 1.75 7,506

**−** Part I of Form U 4,289 1 4,289 1.89 8,098 Prepare and Submit Report, and

Maintain Records

– Partial Report 4,289 0.15 649 18.35 11,911

**−** Part II of Form U 4,289 0.15 649 15.35 9,964

**−** Recordkeeping 4,289 0.15 649 3.00 1,947
Prepa re and Submit Report, and

Maintain Records

- Full Report 4,289 7.16 30,716 83.98 2,579,642

**−** Part II and III of Form U 4,289 7.16 30,716 80.98 2, 487,494

**−** Recordkeeping 4,289 7.16 30,716 3.00 92,148 Average for ICR Addendum Period

Compliance Determination 4,221 1 4, 221 2.50 10, 553

Rule Familiarization 4,221 1 4, 221 12 .00 49,564 CDX Registration Activities 4, 221 1 4, 221 4. 59 19, 378 Prepare and Submit Report,

and Maintain Records

– Partial Report 4, 221 0.15 639 19.63 1 2,513

-- Part II of Form U 4, 22 1 0 .15 639 1 6.63 10,597

-- Recordkeeping 4, 22 1 0.15 639 3 .00 1, 916 Prepare and Submit Report, and

Maintain Records

- Full Report 4, 221 7.16 30,229 91.05 2,745,736

-- Part II and III of Form U 4, 22 1 7.16 30,229 88.06 2, 655,049

-- Recordkeeping 4, 22 1 7. 16 30,229 3 .00 90,687
Some burden estimate subtotals may not calculate due to rounding of unit burden estimatesPage 40 of 48



### Agency Tally

Table 1 8 presents the Agency costs associated with the IUR rule for the first r eporting cycle

. EPA multiplied the costs per report by the total number of Part s I, II, and III to calculate the total burden and cost associated with the number of reports EPA expects to be submitted. The

total burden is 0.1 72 FTEs and the total cost is $ 3 7

, 39 6 in the first reporting cycle, for variable cost activities. The burden and cost of the fixed cost activities remains unchanged by the number of reports submitted; the total fixed burden is one FTE per reporting cycle and the cost is $249, 184 . The to tal Agency burden is 1.181 FTEs. The estimated total cost incurred by the Agency for the first reporting cycle , $28 6 ,5 8 0, was calculated by summing the Agency staff and

contractor activities.

Table 1 8 : Total Cost and Burden of Age ncy Activities ( First Reporting Cycle )

Activity Staff Form U

Section Total

Burden

per Activity

(FTE) Total

Number of

Units Total Cost per Activity ( 2008$ ) Total

Burden (FTE) Total Cost ( 2008$ )

Variable Burdens and Costs

Document receipt, tracking, and da ta
entry Contractor Part I N/A 4, 085 Sites $0.09 N/A $ 360

Part II N/A 29,871 Part

IIs $0.25 N/A $7, 550

Part III N/A 29,253 Part

IIIs $0.29 N/A $8, 402

Quality Control of

Data EPA Employee

(GS

- 12 Step 3) Part I 0.0000009 4, 085 Sites $0.11 0.0 04 $ 465

Part II 0.0000027 29,871 Part

IIs $0.32 0.08 0 $ 9.759

Part III 0.0000030 29,253 Part

IIIs $0.37 0.0 89 $ 10.860

Total Variable Cost and Burden 0.1 72 $ 37,396

Fixed Burden s and Costs

Data Processing, Systems Development, and

Contract Over sight and Management EPA Employee

(GS

- 13 Step 3) N/A N/A N/A N/A 1.000 $139,819

Maintaining and Operating Back Up Systems Contractor N/A N/A N/A N/A N/A $59,145

Printing and Publishing Forms

and Materials Contractor N/A N/A N/A N/A N/A $5,525

Managing t he TSCA

Hotline Contractor N/A N/A N/A N/A N/A $44,694

Total Fixed Cost and Burden 1.000 $249,18 4 Total Agency Cost and Burden 1.1 72 $ 286,580Page 41 of 48



### 6(e) Reasons for Change in Burden

EPA estimates industry will incur a n increase of 245,015 hours in annual burden compared to the estimate in the information collection request most recently approved by OMB (from 410,485 hours currently approved as reported in the currently approved ICR (EPA ICR No. 1884.04) (EPA, 2008a), to 655

, 500 hours as estimated in Secti on 6(d) above ) . This increase is due to both program changes and an adjustment in reporting requirement criteria. Several of the proposed IUR amendments change the number of partial and/or full reports EPA expects to be submitted, based on the specific che micals the amendments affect. Details on the proposed

amendments and the burden and cost impacts of each amendment when taken individually and considered together (i.e., one proposed amendment may change the impact of another)

, are described in the Economi c Analysis for the Proposed Inventory Update Reporting (IUR) Modifications Rule ( EPA, 2010b )

.

6(f) Burden Statement

The annual public burden for this collection of information is estimated to average 1 55 hours per respondent. According to the Paperwo rk Reduction Act, “burden” means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. For this collection it includes the time needed to

determine w hether a site is subject to the rule ( C ompliance Determination); review and understand instructions; prepare and submit reports (including searching data sources); complete and review the collection of information; transmit the information; and keep record s.

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control number for this information collection appears above. The OMB contr ol numbers for EPA's regulations in title 40 of the CFR, after appearing in the Federal Register when approved,

are listed in 40 CFR P art 9, are displayed either by publication in the Federal Register or by other appropriate means, such as on the related c ollection instrument or form, if applicable. The display of OMB control numbers in certain EPA regulations is consolidated in 40 CFR P art 9.

To comment on the Agency’s need for this information, the accuracy of the provided burden estimates, and any sugg ested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a docket for this ICR addendum

under Docket ID No. EPA

- HQ

- OPPT

- 2009

- 0187 which is available for public viewing at the

Pollution Preven tion and Toxics Docket in the EPA Docket Center (EPA/DC), EPA West, Room

3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.

The t elephone number for the Reading Room is (202) 566

- 1544 and the telephone number for the Pollution Prevention and Toxics Docket is (202) 566

- 0280.

An electronic version of this docket is available at http://www.re gulations.gov/ . Use the federal government wide electronic docket and comment system at www.regulations.gov to submit or view public comments, access the index listing of the docket contents, and to access

those do cuments in the docket that are available electronically. Once in the system, selectPage 42 of 48



### “advance search,” then key in the docket ID number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management a nd Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please

include the EPA Docket ID No. EPA

- HQ

- OPPT

- 200 9

- 0187 and OMB control number 2070

- 0162 in any correspondence.

7. Sources

BLS 2009. U.S. Bureau of Labor Statistics. Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006

– December 2008. (March12, 2009) http://www.bls.gov/ncs/ect/sp/ecsuphst.pdf

.

EPA, 2002a. U.S. EPA, Off ice of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA

- HQ

- OPPT

- 2002

- 0054

- 0260). August 2002

.

EPA, 2002b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Wage Rates for Economic Analysis of the Toxics Release Inventory Program.
June 10, 2002.

EPA, 2005. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis

Branch. Economic Analysis of IUR Mod ifications Final Rule (EPA

- HQ OPPT 2004

- 0106

- 0055 ). July 2005

.

EPA, 2006. US EPA, Office of Pollution Prevention and Toxics, Instructions for Reporting for the 2006 Partial Updating of the TSCA Chemical Inventory Database . Nov. 2006. Available

at http://www.epa.gov/iur/pubs/2006_inst_tsca_cheminv.pdf

.

EPA, 2007. U.S. EPA, Office of Environmental Information. A Business Case Analysis of EPA’s Central Data Exchange . March, 2007.

EPA, 2008a. ICR No. 1884.04

. [Information Collection Request for] Partial Update of the TSCA Section 8(b) Inventory Data Base, Production and Site Report Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act . September 5, 2008. EPA

- HQ

OPPT

- 2008

- 0504

- 0002.

EPA, 2008 b . U.S. EPA, Office of Pollution Prevention and Toxics, Information Management Division, 2006 IUR Database Statistics for IUR Modifications Rule . Washington, DC. December 17, 2008.

EPA, 2009 a

. U.S. EPA, Office of Pollut ion Prevention and Toxics. TSCA Section 4 Federal Register Enforceable Consent Agreements. http://www.epa.gov/oppt/chemtest/pubs/4eca.html

. Washington, DC. Updated October 1,

2009.Page 43 of 48



### EPA, 2009 b

. U.S. EPA, Office of Pollution Prevention and Toxics, Sunset Dates of Chemicals Subject to Final TSCA Section 4 and Related 12(b) Actions, Modified on September 1, 2009. http://www.epa.gov /oppt/chemtest/pubs/sunset.html

. Washington, DC. Updated September 1,

2009.

EPA, 2010 a

. TSCA Section 5 Premanufacture and Significant New Use Notification Electronic Reporting; Revisions to Notification Regulations; Final rule. Federal Register (7 5 FR 77 3

- 790 ), January 6, 2010 )

EPA, 2010 b . U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch

. Economic Analysis for the Proposed Inventory Update Reporting (IUR) Modifications Rule

. July 2010.

OPM, 2008. Office of Person nel Management, Salary Table 2008

- DCB, Washington Baltimore

- Northern Virginia, DC

- MD

- PA

- VA

- WV. Accessed from http://www.opm.gov/oca/08tables/pdf/DCB.pdf.Attachment A

- Page 1 of 4 

### Attachment A: 2011 IUR Form UAttachment A

- Page 2 of 4Attachment A

- Page 3 of 4Attachment A

- Page 4 of 4