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Re: Revised EAfor Revocation ofTesting 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 12/11/200905:00 PM Revised EAfor 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) ~-~ c s



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### III . Economic Analysis In the economic analysis conducted for the final rule, the Agency estimated the total cost to industry ofthe 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 amendmentto 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 offurther 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 forthe 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 Reducti 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 anato

### 1324-76-1 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 

### formaldehyde Total 1,511,874 2,481,611 9G9,737 [1] Reduction in Laboratory Costs for each chemical is the sum ofthe laboratory costs of the eliminated tests for that chemical . Laboratory costs were estimated usingthe average cost scenario presented in the Economic Analysis for the Final Section 4Test 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 ofthe 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 4Test 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 oftesting requirements, the sum ofthe estimates of analytical methodology costs ofeach 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 ofthe remainingtesting 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 ofthe reductions in laboratory, administrative, andother testing costs associated with the revocation of testing requirements. [5] Original industry compliance costs oftesting 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 oftesting requirements for these chemicals
. Note that the ieclulced industry compliance total (i .e., $909,737) excludes the industry compliance costs of six HPVchemicals 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; Methanesulfenylchloride, trichloro; 1,3-Propanediol, 2,2-bis[(nitrooxy)methyl]-, dinitrate (ester) ; and 2,4- Hexadienoic acid, (2E,4E)-)
. Therefore, thetotal industry compliance cost of the Section 4Test Rule for HPVChemicals, after removing testing requirements for Coke-Oven Light Oil (Coal) andthe 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.



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