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Re: Revised EA for Revocation of Testing Requirements D 

Stephanie Suazo to: Catherine Roman 1 2/14/2009 09:02 AM 

This looks good to me. 

Stephanie A. Suazo 

Economist, Economic and Policy Analysis Branch 

U.S. EPA / OPPT / EETD 

Phone: (202) 564-3286 

Fax: (202) 564-8896 

Catherine Roman 

From: 

To: 

Date: 

Subject: 

I've made additional changes, primarily in the fo . . . 12/11/2009 05:00 :34 PM 

Catherine Roman/DC/USEPA/US 

Stephanie Suazo/DC/USEPA/US@EPA 

12/11/2009 05:00 PM 

Revised EA for Revocation of Testing Requirements 

I've made additional changes, primarily in the footnotes, but a few other changes are highlighted . Let me 

know if you concur. 

Economic Analysis2.doc 

Catherine Roman 

USEPA 

1200 Pennsylvania Ave., NW, 7405M 

Washington, DC 20460 

(202) 564-8172 

(202) 564-4765 (Fax) 

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III. Economic Analysis 

In the economic analysis conducted for the final rule, the Agency estimated the total 

cost to industry of the testing to be $4.03 million for all 17 chemicals, with an average of 

approximately $237,000 per chemical (Ref. 45). This total included an additional 25% in 

administrative costs . An amendment to the rule revoking testing requirements for CokeOven Light Oil (Coal) reduced the total cost to industry to an estimated $3.7 million for 

the remaining 16 chemicals, with an average compliance cost of approximately $232,000 

per chemical. This direct final rule would have the effect of further reducing the total 

testing cost by an estimated $1 .5 million or approximately 41 %, by eliminating all the 

testing requirements for acetyl chloride; imidodicarbonic diamide; methane, isocyanato-; 

and urea, reaction products with formaldehyde; as well as some of the testing 

requirements for 9,10-anthracenedione ; 1-chlorododecane ; phenol, 4,4'-

methylenebis[2,6-bis(1,1-dimethylethyl)]-; methanesulfinic acid, hydroxy-, monosodium 

salt ; benzenesulfonic acid, [[4-[[4-(phenylamino)phenyl][4-(phenylmino)-2,5-

cyclohexadien-1-ylidene]methyl]phenyl]amino]- ; and C.I . Solvent Black 7. In addition, 

the 25% administrative costs would be eliminated for these tests . The reduced total cost 

for the remaining 12 chemicals with testing requirements is estimated to be $2.2 million 

(i .e ., $3.7 million - $1 .5 million), with an average compliance cost per chemical of 

approximately $184,000 . 

Table 1 . - Reduced Industry Compliance Costs for 10 Chemicals 

CAS Chemical Redueti Red ucti Rediict Total Original Reduced 

Number Name on in on in ion. in Reduction Industry Industry 

Labora- Admini- Other In Industry Compliance Complitory strative Testing Compliance Costs[51 ance 

Costs[1] Costs[21 Costs Costs[41 Costs[61 

3 

75-36-5 Acetyl chloride 190,435 53,359 24,114 267,908 267,908 0 

84-65-1 9,10-anthra 17,716 4,429 n/a 22,145 115,257 93,112 

cenedione 

108-19-0 Imidodicarbon 214,155 62,289 36,114 312,558 312,558 0 

ic diamide 

112-52-7 1-Chlorodode 1,415 354 n/a 1,769 306,439 304,670 

cane 

118-82-1 Phenol, 4,4'- 83,923 20,981 20,500 125,404 198,980 73,576 

methylenebis 

[2,6-bis(l,l-di 

meth leth l)]- 

149-44-0 Methanesulfini 59,029 14,757 13,000 86,786 274,027 187,241 

c acid, 

hydroxy-, 

monosodium 

salt 

624-83-9 Methane, iso 63,618 17,404 7,114 88,136 88,136 0 

c anato1324-76-1 Benzenesulfon- 79,800 19,950 24,000 123,750 312,558 188,808 

ic acid, [[4-[[4- 

(phenylamino) 

hen 1] 4- 
(phenylimino)- 

2,5-cyclohexa 

dien-l-ylidene] 

methyl]phenyl] 

amino - 

8005-02-5 C.I . Solvent 109,888 27,472 33,500 170,860 293,190 122,330 

Black 7 

68611-64-3 Urea, reaction 214,155 62,289 36,114 312,558 312,558 0 

products with 

formaldeh yde 

Total 1,511,874 2,481,611 9G9,737 

[1] Reduction in Laboratory Costs for each chemical is the sum of the laboratory costs of the eliminated 

tests for that chemical. Laboratory costs were estimated using the average cost scenario presented in the 

Economic Analysis for the Final Section 4 Test Rule for High Production Volume (HPV) Chemicals (Itef. 

45, Table 3-2) : 

[2] The Reduction in Administrative Costs for each chemical is 25 percent (Ref. 45, Section 3.1 .3) of the 

sum of the laboratory costs of the eliminated tests for that chemical. Laboratory costs were estimated using 

the average cost scenario presented in the Economic Analysis for the Final Section 4 Test Rule for High 

Production Volume (HPV) Chemicals (Ref. 45, Table 3-2) . 

[3] Other testing costs include analytical methodology costs as well as export notification costs associated 

with testing requirements . For chemicals m itlh pat-tial elimination of testing requirements, the sum of the 

estimates of analytical methodology costs of each eliminated test were included in this column. However, 

export notification costs were not included in this column because these costs would still be incurred by 

industry as part of the remaining testing requirements associated with these chemicals (See Ref. 45, Section 

3A :`arid'T'aFi1e B-2 for further information) . 

[4] Total reduction in industry compliance costs is equal to the sum of the reductions in laboratory, 

administrative, and other testing costs associated with the revocation of testing requirements . 

[5] Original industry compliance costs of testing requirements for these ten chemicals after accounting for 

the elimination of all Coke-Oven Light Oil (Coal) testing requirements . 

[6] Reduced industry compliance costs reflect the cost reduction due to the elimination of testing 

requirements for these chemicals. Note that the ieclulced industry compliance total (i .e ., $909,737) excludes 

the industry compliance costs of six HPV chemicals in the original test rule that are not included in this 

direct final rule (i.e., Carbonochloridothioic acid, S-ethyl ester; Heptenone, methyl-; Methane, dibromo; 

Methanesulfenyl chloride, trichloro; 1,3-Propanediol, 2,2-bis[(nitrooxy)methyl]-, dinitrate (ester); and 2,4-

Hexadienoic acid, (2E,4E)-). Therefore, the total industry compliance cost of the Section 4 Test Rule for 

HPV Chemicals, after removing testing requirements for Coke-Oven Light Oil (Coal) and the ten HPV 

chemicals associated with this direct final rule, now amounts to $2,203,882 [i .e ., 3.7 million - 1 .5 million], 

with an average compliance cost per chemical of $183,656 for the remaining twelve chemicals with testing 

requirements . 

I80 ON SNId1N0O