June 13, 2011

Page 1 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency 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: Final Rule Addendum to Partia l Update of the TSCA Section 8(b) TSCA Inventory Data Base, Pro duction and Site Reports

EPA ICR No.: 1884.05 OMB Control No.: 2070-0162

1(b) Short Charact erization/Abstract

As part of the Inventory Update Reporti ng (IUR) Modifications final rule, EPA is changing the identification of the regulation fr om IUR to Chemical Data Reporting (CDR). However, EPA is retaining the use of the IU R acronym throughout this document. The reader should recognize that where IUR is used to refer to the 40 CFR 711 regulations or to future IUR submission periods, IUR and CDR are synonymous.

The following information collection request (ICR) addendum addresses the paperwork requirements contained in a final rule (RIN 2070- AJ43) that amends the information collection activities of the TSCA Inventory Update Repor ting (IUR) program under the Toxic Substances Control Act (TSCA) (40 CFR Part 710). U nder TSCA section 8(a) (15 USC 2607), the Environmental Protection Agency (EPA) is authori zed to collect certain information on chemical substances manufactured or pr ocessed in the United States. In addition, under TSCA section 8(b), the Agency is required to compile and keep current, via period ic inquiry, the TSCA Inventory of Chemical Substances (TSCA Inve ntory). 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 Toxics (OPPT) has used the IUR to update the basic chemical substance production informa tion for selected larger volume chemical substances on the TSCA Inventory six times (eve ry four years), beginning in 1986, and to collect additional information relating to the manufacture, processing, and use of those chemical substances, beginning in 2006.

EPA has amended the IUR requirements in or der to clarify the re porting requirements, improve the quality and utility of the data s ubmitted, better match data collected with the Agency’s overall information needs, and wher e possible, reduce the paperwork burden on both regulated entities and EPA. Manuf acturers (including importers) ar e required to use e-IURweb (the Agency-provided reporting tool) to s ubmit a completed Form U (EPA Form 7740-8) electronically via the Internet. The 2012 IUR includes additional manufacturing, processing, and use exposure-related data elements, including the volume of the chemical substance used on the reporting site; the volume of the chemical subs tance directly exported; whether the chemical substance is being recycled, remanufactured, re processed or reused; a nd the production volume for calendar year 2010. Additional amendments to the 2012 IUR incl ude changes to the reporting frequency from every five years to every four years; modifications to the method used toJune 13, 2011

Page 2 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency determine whether a manufacturer (including impor ter) is subject to IU R reporting for reporting cycles subsequent to the 2012 reporting cycle; production volumes for each year since the last principal reporting year (effective after 2012 IU R); modifications to reporting thresholds, including the phasing in of repor ting thresholds for processing and use; elimination of the 25,000 lb reporting threshold for certain chemical substa nces that are the subject to particular TSCA rules and/or orders; revisions to industrial classifications used; revisions to the list of commercial and consumer product categories; an d modifications to situations in which confidentiality may be claimed and to the process for making such claims.

OPPT will use the updated IUR data in its chemical substance risk-management efforts. Individual sites manufacturing (including importing) chemical substances will submit the required information. The information will be st ored electronically for reference by EPA staff

and others. Within the constraints of confidentia lity claims, the information will be made public through the Agency’s IUR website (http://www .epa.gov/iur). Further 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 4,153 respondents at an annual cost of $29 million during the ICR a ddendum period. The details 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, asse ss, and control risks of injury to human health and the environment posed by commercia l chemical substances. Under TSCA section 8(b), EPA is required to compile and keep curr ent 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 maintenanc e and collection of records from manufacturers, importers, and processors of commercial chemical substances. Sections 8(a)(1) and (2) of TSCA also authorize the Agency to collect informa tion on the chemical substance manufacturing and importing industry. EPA possesses broad discreti on in determining the information to be reported under TSCA section 8(a). The IUR ru le was codified at 40 CFR 710. EPA has moved

the IUR rule to a new Part at 40 CFR 711.

EPA modified the IUR rule 1 to meet four primary goals: (1 ) to tailor the information collected to better meet the Agency’s overall info rmation needs; (2) to in crease its ability to effectively provide public access to the informati on; (3) to obtain new and updated information relating to potential exposures to a subset of chem ical substances listed on the TSCA Inventory; and (4) to improve the usefulness of the inform ation reported. EPA believe s requiring electronic reporting; collecting comprehensive information for most reported chemical substances; and adjusting the specific reported information, the frequency the information is reported, and confidential business information (CBI) clai m requirements will accomplish these goals.

1 The final rule is titled “TSCA Inventory Update Reporting Modifications.”June 13, 2011

Page 3 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency The IUR provides basic exposure-related ma nufacturing, processing and use information used by EPA and others in a wide range of Agen cy activities. EPA’s e fforts to use the 2006 IUR

data have identified areas wher e further improvements were needed to improve risk-screening capabilities. Screening level data need not be pr ecise, but should be accurate and reliable enough for the Agency to develop screening-level exposure assessments. The 2012 IUR will provide

more detailed information needed to better understand and interpret the IUR data, further enhancing the Agency’s ability to identify, scre en, and manage potential chemical substance risks. Because exposure is a key component of risk, the IUR exposure-related information will

allow OPPT to screen chemical substances base d on the potential for risk in order to protect human health and the environment, as requi red by TSCA. The exposure-related data on manufacturing, processing, and use will potentially allow the Agency and others to avoid more burdensome regulatory requirements. These enha nced data will allow EPA to conduct a more effective and efficient screening level review of chemical substances to identify candidates for

further evaluation.

2(b) Practical Utilit y/Users of the Data

The modifications associated with reporti ng methods and changes to the reporting tool will ensure the information reported to EPA is accurate and in compliance with the IUR requirements.

e-IURweb Reporting Tool

Beginning with the 2012 submission period, EPA is requiring electronic reporting for all IUR submissions, including joint submissions and amendments. Persons submitting information under the IUR rule are required to use e-IURweb, the Agency-p rovided, web-based tool to complete Form U (the IUR reporting form). The information will be submitted electronically via the Internet, through EPA’s Central Data Exch ange (CDX). Users of CDX are required to register with the system, including submitting an authorized signature agreement to EPA.

The 2012 submission process is similar to th at available for the 2006 IUR, when EPA provided an opportunity for IUR re spondents to send their reports electronically, through CDX, on a voluntary basis. Approximate ly one-third of the 2006 submi ssions were filed through CDX, using the 2006 e-IUR downloadable software. The elimination of paper-based submissions in favor of electronic reporting, including the use of e-IURweb, is expected to greatly improve the reporting process, both for EPA and for manufacturers (including importers).

The 2012 e-IURweb features several impr oved capabilities over the 2006 e-IUR software. These improvements include an enhanced validation system, whic h alerts users when a required field on the form is either missing inform ation or contains certain kinds of potentially incorrect information. Other updates include auto mated chemical identity checks, using EPA’s Substance Registry Services (SRS), automated company and site identity checks, using EPA’s Facility Registry System (FRS), and the facilitation of joint submissions and amendments.

Electronic submission will also ensure that IU R data complete a basic validation check, can be quickly incorporated into a database and ready for immediate Agency use, and willJune 13, 2011

Page 4 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency eliminate subsequent data entry errors which occurred with paper submissions. Furthermore, EPA believes the mandatory use of e-IURweb and CDX will reduce the reporting burden on industry by reducing both the cost and the time re quired to review, edit an d transmit data to the Agency.

CDX Registration

Each IUR submission must have an associated authorized official. The authorized official signs the certification statement and submits the IUR report via CDX. During the 2006 IUR, respondents were required to complete an elec tronic signature agreem ent (ESA) and to submit the agreement in hard copy with a wet ink signa ture to EPA in order to complete the CDX registration. For 2012 IUR reports, EPA modified the 2006 ESA to identify more clearly the individual(s) required to sign th e agreement. To register in CDX, the CDX registrant (also referred to as “Electronic Signature Holder ”) will complete ESA form. For identity authentication, the registrant will complete the ES A, and either submit the form electronically or

mail the form to EPA. Once EPA receives the form, EPA will activate the registrant’s CDX

account and send a notification via email.

A company may need or desire to have more than one individual complete an electronic signature agreement, so that more than one pe rson can add informati on to an original IUR submission. Persons submitting supplemental information for an IUR submission on behalf of a company will also need to register with C DX by signing an ESA. The company official can authorize an unlimited number of support registra nts and support registrants can work with an unlimited number of company officials. A suppor t registrant may be an employee of the company, an outside consultant for the company, or an authorized representative agent for the company. While this individual is not able to sign th e certification statem ent required for the initial IUR submission, he or she will be able to provide additional information, if needed, using CDX. For 2006 and prior IUR submissions, supp ort registrants were not able to provide additional information electronically.

Data Elements for IUR Submissions

The IUR information collection is the onl y mechanism through which EPA can collect

basic information on commercial chemical substan ces listed on the TSCA Inventory, including production volume and other manufacturing (inc luding importing) processing, and use exposurerelated data. This information collection is necessary because these data are not otherwise

available. EPA will use the information it is collecting in the following ways:

(1) U.S. Parent company identification information : Company identification information is collected already by the cu rrent IUR. EPA will require reporting of additional company identification information associated with the location of the company, and will clarify that the company info rmation is to be for the U.S. parent company associated with the reporting plant site. These data will help ensure the company information is consistently provided.June 13, 2011

Page 5 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency (2) Manufacturing-related information :

• The production volume for calendar year 2010 : The one-year snapshot of production volume provided by the 2006 IUR does not provide an accurate picture of the chemical substances in commerce, and may provide an erroneous view of the exposure scenarios associated with a particular chemical substance. The high turnover of reported chemical substances from one submission period to the next indicates a dynamic, changing industry. EP A has received comments from industry concerning the year-to-year changes that occur for chemical substance production that may affect IUR reporting. For the 2012 IUR, manufactures (including importers) will need to report the production volume for calendar year 2010. This is in addition to the full manufacturing, pr ocessing, and use information for the principal reporting year (i.e., 2011). For IUR collecti ons subsequent to the 2012 IUR collection, EPA will require reporting of production volumes for each of the years since the last principal reporting y ear. EPA will 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 (i ncluding imported) chemical substance used at the reporting site: This data element replaces the data element indicating

that a chemical substance is site-limited. This new data element identifies whether a chemical substance is used by the reporti ng site. Either domestically manufactured or imported chemical substances can be re ported as used at th e reporting site. This information is related to potential exposur es associated with the on-site volumes, and will provide the Agency with more accurate information for exposure assessments and other data analyses.

• Whether an imported chemic al substance is physica lly at the reporting site : This data element will enable the Agency a nd others to better assess manufacturingrelated 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 will allow EPA to better identify the completeness of the reported processing and use information, by indi cating the proportion of the production volume potentially covered by the reporte d processing and use information. IUR processing and use information is required on ly for domestic use situations, and is not required for any volum es directly exported.

• Whether a manufactured (including importe d) chemical substance, such as a byproduct, is being recycled, remanu factured, reprocessed, or reused : This data element will provide valuable informa tion for Agency and public programs that encourage industry to find uses for wastes ra ther than disposing of the wastes, such

as in a landfill.June 13, 2011

Page 6 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency These data will also be used in other wa ys, such as in chemical substance exposure and risk screening, testing and/or prior ity setting, and exposure estima tion 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 support the development of TSCA regul ations under section 6; and to measure potential human and environmental exposure under TSCA section 8(e). E ach data element corresponds to a data point necessary for basic risk-screening.

Under the 2006 IUR rule, only manufacturer s (including importers) of larger-volume chemical substances were required to report pr ocessing and use information. Under the final rule, the reporting threshold for processing and use information will be phased in, such that the threshold is 100,000 lb for the 2012 IUR and 25,000 lb for the next IUR collection in 2016. For 2012, for example, respondents who manufacture (i ncluding import) a chemical substance in volumes of 100,000 lb or more at a single site are required to repor t processing and use information, unless the chemical substance is partially exempt. This change provides exposurerelated processing and use information to EP A and others for moderate-volume chemical substances, enabling the Agency to address such chemical substances in the same manner as the higher-volume chemical substances.

(3) Industrial processing and use data : The final rule does not add any industrial processing and use data elements. The industria l function categories have been revised to better identify the functions of the chemical substances. The North American Industrial Classification System (NAICS) codes have b een replaced with industrial sector (IS)

codes. The IS codes reduce the number of c hoices available to th e respondent, thus streamlining the reporting process and making the data easier to use.

(4) Consumer and commercial end-use exposure data: EPA added two data elements: an

indication of consumer or commercial use a nd the number of commer cial workers. These data will be used to determine exposure potential 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 e xposure-based screening of the chemical

substance. The number of commercial workers is needed to better a ssess the size of the commercial population reasonably likely to be exposed to a chemical substance. In addition, the product categories have been revise d to better identify th e uses of chemical

substances.

Special Considerations for Joint Submitters

In certain situations IUR submitters are al lowed to report the IUR information jointly with the supplier of the chemical substance fo r which the submitter is reporting. For example, importers may not know the specific chemical identity of the imported TSCA Inventory substance because the foreign suppl ier chooses to keep the inform ation confidential. In addition, a manufacturer may not know the specific chemical identity of the subs tance being manufactured because the supplier of a reactant used to manufacture th e substance chooses to keep the information confidential. In such situations, the manufacturer (including importer) is still responsible for ensuring that the IUR inform ation is submitted to EPA and may do so byJune 13, 2011

Page 7 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency submitting a joint report. For example, in the case of an imported substance, the U.S. importer, as the primary submitter, completes the majority of the required information on Form U, and provides a trade name in Part II.2.A.4 to identif y the chemical substance. The primary submitter then contacts the foreign supplier, who is the sec ondary submitter, to notify them of the need to report the specific chemical identity information directly to EPA in the joint submission section (Part IV) of Form U, using th e reporting tool, e-IURweb. Fo r 2006 and prior IUR submissions, submitters were not able to submit joint reports electronically. EPA has added Part IV to Form U to accommodate joint submissions. Because signat ures are required by each party of a joint submission, they must each register with CDX, complete their own sections on Form U, and submit their own sections of the same report el ectronically to EPA. Th e secondary submitter will not be able to access the information provide d by the primary submitter and vice versa. The reporting tool will match both submissions based upon company and chemical information provided by the manufacturer (including importer) , acting as a primary submitter, and by the supplier, acting as a secondary submitter. The information provided by the primary and secondary respondents will be saved and combin ed as one joint submission. EPA will process the joint submission once all Form Us ar e received and matched by the Agency.

This information collection will allow EPA to connect submissions from the primary submitter and secondary submitter and to request clarification from the secondary submitter if

needed. The data EPA will collect will be utilized in the following ways:

(1) Joint Submission Information (primary registrant only): The primary submitter provides only a trade name or other desi gnation to identify the chemical substance being reported. Therefore, the requested data are needed by the Agency to identify the chemical substance correctly and provide the company name and complete mailing address of the secondary submitter.

(2) Secondary Company Identi fication Information: These data identify the secondary submitter’s company name and the complete mailing address of the company. The information provided will help ensure th at the company information is provided consistently, and will be used to associ ate the secondary submitter’s company with the primary submitter’s company and site plant.

(3) Technical Contact Information: The company’s technical contact information will provide EPA with the name and complete mailing address of the person who will be able to answer questions EPA may have about the reported chemical substance.

(4) Primary Company Information : These data will provide the trade name and Unique

Identifier for Joint Submissions number th e primary submitter sent to the secondary

submitter.

(5) Trade Product Identific ation Information : These data will identify the primary submitters’ company name, site name, and site address, as well as the CAS Registry Number, the appropriate speci fic chemical identities, and product composition. These data are needed by EPA to combine the secondary submitters’ chemical-specificJune 13, 2011

Page 8 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency information with the primary submitters’ in formation to result in a complete IUR

submission.

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 governme nt public health and environment efforts, IUR data have been used by EPA’s Office of Water, Office of Solid Waste and Emergency Re sponse, and Office of Air and Radiation to identify a nd characterize particular chemi cal substances. Non-confidential IUR data are incorporated into a number of data bases and products maintained by organizations including Right-To-Know-Net and INFORM 2 . IUR data were used to identify chemical substances of particular concern for the National Institutes of Health. Non-confidential IUR data were also released to selected states to help them identify facilities manufacturing suspected endocrine disrupters.

Data reported under the 2012 IUR will enhance the capabilities of the Agency and other Federal agencies to ensure risk management act ions are taken on chemical substances posing the most concern. More in-depth reporting of the processing and use data, more careful consideration of the need for confidentiality clai ms, and adjustments to the specific data elements will better support a robust risk assessment and management program. By enhancing the data supplied to Agency risk-screeni ng programs, EPA expects to more effectively and expeditiously identify and address potential risks posed by chemical substances and provide improved access and information to the public.

EPA will also use the information submitte d through the 2012 collection to update the Agency’s comprehensive chemical manufacturing , exposure, and use database, maintained as part of the Manage Toxic Substances (MTS) sy stem. IUR data prior to the 2006 collection are

maintained 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 informa tion about the chemical industry for EPA, as well as other Federal Agencies. The MTS IUR data provide information about the chemical substances used, where they are produced, how mu ch is produced or imported, and how they are processed and used. The chemical industry is d ynamic, as demonstrated by the approximately 30 percent change in chemical substances repor ted 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 included in this information collection (i.e., production volume, chemical manufacture, exposure, and processing and us e data) are not collected comprehensively or systematically at the national level. There are a variety of sources for certain data elements, but the sources are either incomplete or incompatible.

2 INFORM is a nonprofit environmental research organization.June 13, 2011

Page 9 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency 3(b) Public Notice Required Prio r to ICR submission to OMB

The final rulemaking serves as the public notice for this ICR.

3(c) Consultations

In addition to the public notice and co mment period, OMB regulations, at 5 CFR 1320.8(d)(1), require agencies to consult with potential ICR respondents and data users about specific aspects of an ICR before the agency su bmits the ICR to OMB for review and approval. In accordance with this regulati on, EPA solicited consultation f eedback from nine potential respondents and data users with re spect to this final rule ICR

3(d) Effects of Less Frequent Collection

EPA has returned the reporting frequency to ev ery four years, which was the frequency in

effect from 1986 to 2006. In an effort to redu ce the reporting burden a ssociated with the 2003 amendments, EPA had changed the reporting fre quency to every five years. While the less frequent reporting does reduce burden, a revi ew of the 2006 IUR reporting has revealed an approximately 30 percent change in the chemi cal substances that are reported from one submission period to the next. EPA now believes th at reporting every five years does not provide data sufficiently current to meet Agency and pub lic needs and now consider s every four years to be the minimum acceptable frequency. In addi tion, the IUR Modifications proposed rule requested comment on even more frequent report ing. Comments from industry representatives

led EPA to believe that more fr equent reporting creates efficien cies, both for the respondent and for EPA. With more frequent reporting, companies will be able to establish standard systems and practices to collect th e required information.

The Agency needs to be able to make accurate chemical substance risk management decisions in a timely and cost effective manner, especially because alternative data sources do

not exist for these data. The effect of less fre quent collection of these data is to diminish significantly the Agency’s ability to unders tand the chemical industry and monitor the production levels of chemical substances ma nufactured (including im ported) in the United States. As described above, the IUR data dem onstrate 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 or der 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 potentiall y six or more years old, and therefore, cannot

be considered current.

Less frequent collection could result in EP A using outdated informa tion in its decision making. For example, changing market conditions, batch processing, or the development of new uses for the chemical substance can cause produ ction volumes or chemical substance uses to change from one year to the next. Companies buy and sell plant sites, and the chemical substances produced at a site can change. Ba sed on past IUR reporting, the Agency would be working with the IUR data which approximately 30 percent of the chemical substances known toJune 13, 2011

Page 10 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency be in commerce at volumes of 25,000 lb or mo re may not actually be in commerce at those

levels.

3(e) General Guidelines

This collection does not exceed any of the Paperwork Reduction Act guidelines at 5 CFR 1320.6, with the exceptio ns listed below.

The record retention period of this collection is five year s, as specified in 40 CFR 710.57, exceeding the PRA maximum of three years. This is necessary to ensure companies retain records long enough to facilita te completion of Form U (EPA Form 7740-8) in the next collection, which is in four year s and to allow EPA’s enforcemen t activities to overlap two IUR reporting cycles.

Confidential Business Information (CBI) clai ms limit access to the IUR data, especially by the public. EPA recognizes that some informa tion submitted to the Agency is legitimately confidential business information; because of this , EPA’s review of CBI data is an inherently governmental function that EPA must perform to protect human health and the environment.

3(f) Confidentiality

Submitters may claim information reported to EPA under this rule as confidential if such information reveals the submitter’s trade secrets or proprietary information as defined by TSCA section 14 and existing TSCA regulations. EPA has long-established procedures for handling, storing, processing, and disposi ng of TSCA confidential information. Transfers of this information to other governmental agencies 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 informa tion from disclosure in accordance with EPA’s confidentiality regula tion, 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 consists of comp anies manufacturing or importing chemical

substances listed on the TSCA I nventory 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 chemical substa nces. Most respondents previously reported information under the IUR. The Agency’s previous experience with IUR collections has shown that the majority of the respondents affected by this collection activity are from the following

North American Industrial Classificati on System (NAICS) code categories:June 13, 2011

Page 11 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency 325 - Chemical Manufactu ring (including importing)

324 - Petroleum and Coal Product Ma nufacturing (including importing)

The subsectors identified above represent the designation of sites that likely would be subject to IUR reporting. However, activities at th ese sites may vary, maki ng identification of the regulated community more difficult. For example, NAICS codes reflect a site’s primary activity, omitting substantial participation a company ma y have in other industry activities. Second, NAICS codes selected by U.S. parent companie s reflect the parent company’s primary activity, even though many U.S. parent companies ar e primarily holding companies with small

subsidiaries. Each of these small subsidiaries may belong in a completely different industry classification based on its own primary activit y. Information on U.S. parent company NAICS codes does not provide a very accurate characteriza tion of the types of sites subject to reporting,

and facilities that do not fall unde r these categories must still re port if they meet the reporting

criteria.

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

In addition to the anticipated responden ts listed above, manu facturers (including importers) of byproducts are required to report under the IUR rule. B yproduct manufacturers (including importers) may be listed under a differe nt 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 byproduct is a chemical substan ce 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 (including importer) th at uses a chemical substance in the production of an article may produce a byproduct s ubstance that is chemically different from the starting substance; the manufacturer (inc luding importer) therefore may incur reporting obligations under the IUR for th at byproduct. While some manuf acturers (including importers) of byproducts may not have reported to the IUR in the past, they should be aware now of their reporting obligations un der the IUR rule.

4(b) Information Requested

(i) Reporting Threshold for Certain Regulated Chemicals

Under the final rule, EPA eliminated the 25,000 lb threshold for certain chemical

substances that are: • The subject of a rule proposed or promulgate d under TSCA section 5(a)(2), 5(b)(4), or
6, • The subject of an order issued under TSCA section 5(e), orJune 13, 2011

Page 12 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency • The subject of relief that has been granted under a civil action under TSCA section 5 or

7.

Respondents who manufacture (including import) a chemical substance in volumes of 2,500 lb or more at a site are required to repor t manufacturing information on these chemical

substances. Chemical substances that are the su bject of these particular TSCA actions are of demonstrated high interest to the Agency. This change will help to ensure the availability of current information when the Agency has expres sed a concern in the form of regulatory action on those chemical substances manufactured below 25,000 lb EPA will use the IUR data associated with these regulated chemical subs tances to monitor chemical substance production and compliance with the rules.

(ii) 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 ecosyst ems or size of human populations potentially exposed, (2) the potential human or environm ental exposure concentr ations, and (3) the frequency and duration of potentia l exposures. The data enhances EPA’s ability to evaluate each of these components of exposure. Respondent s are required to submit certain known or reasonably ascertainable manuf acturing, processing, and use exposure-related information. For the 2006 IUR, respondents were required to subm it the processing and use information to the extent it was readily obtainable; the IUR Modifi cations rule standardizes all of the submitted information to the single “known to or reason ably ascertainable by” reporting standard.

Using e-IURweb, individuals report the data elements as follows (the following list

identifies new or revised data elements and does not address 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.

• U.S. Parent Company Name and Address . The name and mailing address of the U. S. parent company, the requirement that the pa rent company reported be the U.S. parent company is part of the IUR Modifications rule. 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. The production volume for 2010 only for the 2012 reporting cycle. For subsequent reporting cycles (e.g., the 2016 reporting cycle), the production volume for each of the years sin ce the last principal reporting year; the volume of the reported chemical substance used at the reporti ng site; whether an imported chemical substance is physically at the reporting site; th e production volume directly exported and not domestically processed or used; and whether a manufactured (including importe d) chemical substance, su ch as a byproduct, is being recycled, reused, reproce ssed, or remanufactured.June 13, 2011

Page 13 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency • Processing and Use Information. For the 2006 IUR, only those manufacturers (including importers) of chemical substa nces with production volumes of 300,000 lb or more were required to report proc essing and use information. For the IUR Modifications final rule, the reporting threshold for pro cessing and use information will be phased in, such that the threshold is 100,000 lb for the 2012 IUR collection and 25,000 lb for subsequent IUR collecti ons (e.g. 2016 IUR). Respondents are to report this information for all reported chemical substances, unless the chemical substance is specifically partially exempted.

• Industrial Processing and Use Data. For the 2006 IUR, respondents were able to select up to 10 unique combinations of the t ype of process or use (code), NAICS code associated with the industrial use, and industrial functi on category. The IUR

Modifications rule revised the list of i ndustrial function catego ries and replaced the

NAICS codes with Industrial Sectors.

• Consumer and Commercial Use Data. For the 2006 IUR, respondents were able to select up to 10 consumer and commercial pr oduct categories. The IUR Modifications

rule revised 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 will not disclose to the respondent the specific chemi cal name of the imported TSCA Inventory chemical substance

or of a reactant used to ma nufacture the TSCA Inventory substance. This may happen, for instance, when a company is importing a mi xture under a trade name, and the foreign

manufacturer does not want to reveal the components in the mixture. (See Special Considerations for Joint Submitters in section 2b, above.) Change s to the IUR make it easier for respondents to use electronic repo rting for both the primary and the secondary portions of a joint submission. In addition to signing the certification statement and completing Parts I, II, and III, primary respondents will report on data elemen ts in Part II, Blocks 2.A.5 through 2.A.12, on

Form U as follows:

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

Secondary submitters will register with CDX as secondary authorized submitter or a secondary support registrant. . They will provid e the primary company’s information and the trade product name, supplied to them by the prim ary submitter, to gain access to the Form U containing information specific to the trade product name. After the secondary submitter is granted access to the form, they will report on data elements in Part IV on Form U as follows:June 13, 2011

Page 14 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency • Certification. The company official 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 regulatory requirements; and 2) any confidentiality

claims are true and correct as to that info rmation for which they have been asserted.

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

• Secondary Technical Contact Information. The technical contact name, phone number, complete mailing address (city/town, state/province, zip c ode, and country (if applicable)), and email address.

• Primary Company Information. Trade name and Unique Identifier for Joint Submissions number provided the primary su bmitter sent to the secondary submitter.

• Trade Product Information. The trade product name, chemical name, CAS Registry Number, ID code, and percentage of each chemical substance component of a trade product.

(ii) Submitter Activities/Inf ormation Collections (ICs)

EPA identified the following ICs in the cu rrently-approved ICR (EPA ICR No. 1884.04) for activities that submitters would comp lete when complying with the rule:

• Compliance Determination;

• Rule Familiarization;

• Report Preparation and Subm ission – Partial Reports;

• Report Preparation and Submission - Full Reports; and

• Recordkeeping.

As a result of the final rule, EPA will incl ude a new IC addressing the initial paperwork activities a company needs to complete in orde r to be able to submit reports electronically through CDX. EPA also will incorporate recordkeep ing activities into the ICs that address the preparation and submission of partial and full repor ts, rather than include them as a stand-alone IC (see Table 1).

Table 1: Information Collections (ICs) for IUR Reporting

Information

Collection Description

Compliance

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

The 2012 rule modifies the method used to determine whether a manufacturer (including importer) is subject to IUR reporting. ReportingJune 13, 2011

Page 15 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency is required if the production volume of a chemical substance met or exceeded the 25,000 lb threshold in th e 2011 principal reporting year for the 2012 submission period, and in a ny calendar year since the last principal reporting year in future reporting cycles

Rule Familiarization Become fam iliar with the full requirement s of the rule, which entails reading the rule, understanding the va rious reporting and administrative requirements, and determining the manner in which reporting requirements will be met for each chemical substance. CDX Registration

Activities The 2012 rule requires electronic repor ting, and therefore re quires that all submitters complete the CDX registration process. As part of registering with CDX, each submitter will provide identifying information that will comprise all or most of the informa tion requested in Part I of Form U (EPA Form 7740-8). This information will then be pre-populated whenever the submitter prepares a partial or full report.

In order to submit electronically to EP A via CDX, the authorized official, who will be signing and submitting the si te’s IUR Form U, must register with CDX and must submit an ESA. This is the same process required

for electronic submissions for the 2006 IUR.

Once the registration process is comple te, the registered individual will

be able to access the e-IURweb reporting tool. Prepare and Submit Report, and Maintain

Records- Partial Report Compile the required information, determine the CBI status ofinformation and fulfill appropriate substantiation measures, and use eIURweb to complete and submit only Part s I and II (and Part IV, if a joint submission) of Form U (EPA Form 7740-8) for chemical substances specifically listed in the regulation for which there is a partial reporting exemption. Retain all records relate d to the submission for five years after the submission period. Prepare and Submit Report, and Maintain Records- Full Report Compile the required information, determine the CBI status of information and fulfill appropriate substantiation requirements, and use e-IURweb to complete and submit Parts I and II for chemical substances manufactured (including imported) in volumes of 25,000 lb or more (or 2,500 lb or more, if applicable), and Part IV, if a joint submission, of Form U (EPA Form 7740-8). Complete part III for chemical substances manufactured (including imported) in volumes of 100,000 lb or more (and Part IV, if a joint submission) of Form U (EPA Form 7740-8). Retain all records related to the submission for five years after the submission period.June 13, 2011

Page 16 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency 5. The Information Collected–Agency Activiti es, Collection Methodology, and Information Management

5(a) Agency Activities

The activities routinel y conducted by EPA related to the processing, analysis and storage

of the information collected under this rule include the following:

• Review and verify forms as they are received;

• Answer submitter questions and provide any necessary assistance;

• Process submissions for inclusion in IUR database;

• Review requests for confiden tiality in the submissions;

• Maintain the database; and

• Distribute the data.

5(b) Collection Methodology and Management

The next IUR collection will occur in 2012. All manufacturers (including importers), except for those defined as “small manufacturers” by EPA’s regulations, are required to submit information on every substance subject to the 2012 rule that they manufacture (including import) in quantities that meet or exceed the IUR threshol ds. The collection will occur every four years.

(i) Collection Methodology

Submitters are required to submit informa tion associated with this data collection electronically via the Internet using e-IURweb and CDX. The 2006 IUR allowed and encouraged electronic reporting, thus providing both submitters and the Agency the opportunity to test an electronic reporting system. Comments from submitte rs and lessons learned from the collection of paper, CD, and electronic submissions were used to develop the 2012 collection methodology. Some of the changes to this methodology ar e regulatory and are included in the IUR Modifications Final rule; others are process-oriented or inte rnal to EPA or the respondent.

Potential submitters were notified of the n eed to report in three ways: (1) EPA published a Federal Register notice, (2) email notices were sent to previous IUR submitters, and (3) articles were published in the trade press. Reporting mate rials, including a non-submission version of the e-IURweb reporting tool and a variety of guida nce documents (Instruction Manual, Q&As, Case Studies), are available on EPA’s IUR website. Su bmitters also can obtain these materials from

the TSCA Hotline. Submitters obta in the submission version of the e-IURweb reporting tool as part of the CDX registration process, as described in section 4 of this document.

EPA will receive all IUR submissions electronically. The CDX registration process, required for all submitters, will provide a user ID which the submitter will use to access eIURweb.

Information quality and validation begins w ith the e-IURweb reporting tool, which is programmed to help the submitter provide the information require d, in the correct format asJune 13, 2011

Page 17 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency required by the IUR rule. Use of e-IURweb will el iminate many of the problems with incorrect chemical substance identifications experienced in the past by providing a current listing of the TSCA Inventory chemicals and their associat ed identification numbers. Other respondentgenerated errors, such as incorrect codes, have also been eliminat ed due to the use of techniques such as drop-down menus, restrictions on the specific information that can be entered, and errorchecking algorithms.

Mandatory IUR reporting via the Internet is the most efficient collection method for

submitters and EPA. Submitters 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 data re ceipt 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 have been programmed into the data-entry system to further ensure the quality of the data.

To aid persons subject to this informa tion collection, the Agency’s TSCA and CDX Hotlines are available to answer questions regarding the IUR requirements or submission process. When Hotline staff is unable to answer questions, the submitter is referred to OPPT’s Information Management Division (IMD) or Chem ical Control Division (CCD), as appropriate.

Other Divisions within OPPT or OEI are used as necessary.

(ii) Data Management

This section describes the Agency tasks re quired for efficiently processing submissions under the IUR. The tasks for which the Agency is responsible are presented under four main categories: database systems development, gui dance document development, Form U processing, and additional 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 re viewers to search or e xport into their various analytical modeling systems and databases. Th e IUR database is also available for quick screening and other direct uses. The Agency ma kes publicly available as much information as possible, within the confines of protecting CBI.

• Database 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 collectio ns. 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, stor ing it in a larger Mana ge Toxic Substances (MTS) database. In addition, IUR data ar e tracked via the correspondence tracking system utilized by the Confidential Business Information Tracking System (CBITS)

located within the Confidential Bu siness Information Center (CBIC).June 13, 2011

Page 18 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency • Guidance Document Development -- The Agency is responsible for developing guidance to assist submitters in complying with IUR requirements. The guidance documents usually are developed by a contractor with oversig ht by Agency personnel.

• Form U Processing -- The Agency is responsible for processing IUR Form U submissions. This includes developing sta ndard operating procedures and documentation for all stages in the IUR document life cycle, document receipt and tracking, data input, quality control, file and database maintena nce, information security, CBI aggregation policy, data dissemination, and staff trai ning. For the 2012 IUR submission period, EPA developed new processes to receive IUR su bmissions over the Internet, using CDX.

• Additional Activities -- The Agency develops various supporting documents associated with the reporting tool and ma kes them available on the Internet. In addition, the Agency is responsible for providing the TSCA Hotline w ith standardized responses for frequently asked questions; preparing mailings, mailing li sts, and labels; and developing outgoing

information materials.

5(c) Small Entity Flexibility

The final IUR regulation provides ample flex ibility to small entities. This regulation affects only businesses -- governmental jurisdic tions 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 recordk eeping requirements. A ma nufacturer (including importer) is considered a small business if (1) th e firm’s total annual sales when combined with those of its U.S. parent company (if any) ar e 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 Final Inventory Update Reporting Modifications Rule determined that the impact on these companies is, on average, significantly less than one percent of revenues (EPA, 2011).

5(d) Collection Schedule

The submission period shall be from February 1, 2012 to June 30, 2012. . The submission period/schedule follows the requirements of 40 CFR 711.20.

Federal Register Notice published Send out e-mail to 2006 IUR e-mailing list

with instructions desc ribing how to obtain the reporting form Public Outreach efforts: articles in industry press, meetings with regulated community, and

information on the IUR website __May_2011

Open period for submitting 2012 IUR Forms February 1, 2012 to June 30, 2012June 13, 2011

Page 19 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency 6. Estimating the Burden and Cost of the Collection

This section presents the burden and cost estim ates incurred by all affected entities as a

result of the final IUR rule amendments. This addendum to the supporting statement covers the years 2011, 2012, and 2013. Therefore, it provides burde n and cost estimates for the information collection corresponding to the 201 2 reporting cycle (which is the first submission after the 2011 final IUR rule amendments to the IUR rule are finalized), and also for the information collection corresponding to the next reporti ng cycle, for which respondent s will be preparing during 2013. Even though reporting occurs only once per repor ting cycle (once every six years for the 2012 cycle and once every four years in the future), EPA believes that rule compliance and data collection activities, and thus, costs and burdens, are incurred 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 repo rting cycle and are presented here as average annual figures. All costs are presented in year 2008 dollars. The IUR requi res reporting on a “per site” basis rather than a “per company” basis. Th erefore, each site whic h is subject to the IUR rule is considered a respondent and will submit one Form U containing one or more chemicalspecific reports. EPA estimates that a total of 4,085 respondents will respond to this information collection in the 2012 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 20,718 full reports a nd 5,135 partial reports during the first reporting cycle, and 30,287 full reports and 648 partial repor ts in future reporting cycles. Each report is for a single chemical/site combination. Each site is expected to submit an average of 5.07 full reports and 1.26 partial reports in the first reporting cycle and 7.06 full reports and 0.15 partial reports in the subsequent reporting cycles. The average burden per respondent, wh ich is one site, is estimated to be 572 hours for the 2012 reporting cycle, or 95 hours annually over a six-year cycle. For future four-year reporting cycles , the average burden per respondent is estimated to be 600 hours per cycle, or 150 hours annually. Given that this ICR addendum covers a period that spans both the first and a future reporti ng cycle, the average annual burde n over the three year period of 2011 through 2013 is 114 hours. This is higher than the burden estimated for the currently approved ICR (EPA ICR No. 1884.04), due to both program changes and an adjustment in reporting requirement criteria, in cluding additional data requirements and modifications to reporting thresholds.

6(a) Estimating Respondent Burden

For the 2012 reporting cycle, each manufactur ing site (including im porters) must submit

a Form U if the site meets or exceeds the 25,000 lb threshold for at least one chemical substance in the 2011 principal reporting year. In future cycles, this reporting threshold will apply for any calendar year since the last pr incipal reporting year. For purpose s of the ICR, one manufacturing site is equivalent to one res pondent. Form U contains four Part s. Part I contains basic site identification information and must be completed by all sites. Part II contains manufacturing data (production volumes, etc.) specific to each chemical substance, which also must be completed by all sites. Together, Part I and Pa rt II are considered a “partial repor t.” Part III contains processing and use information. Under the final amendments, in future cycles Part III would be completedJune 13, 2011

Page 20 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency for all chemical substances unless the chemical substance is specifically exempted from the requirement to do so. Part IV contains sec ondary company identification information and specific information identifying a chemical substa nce. Part IV is completed only by a secondary respondent (see Section 2(b)). For purposes of th is analysis, burden and costs associated with Part IV are considered part of the burden and cost s estimates of Part I (r espondent identification) and the beginning of Part II (c hemical identification), and th erefore were not separately

calculated. Together, Parts I, II, and III (and Part IV, when applicable) are considered a “full report.” One report is submitted for each unique chem ical substance/site combination; that is, a site must complete a separate report for each app licable chemical substance, but Part I of Form U is completed and submitted only once per site. EPA anticipates that Part I will be completed automatically when respondents register with CDX.

To comply with the regulation, manufactur ers (including importers) must complete the activities listed in Table 2. Table 2 also provi des a cross-walk of th e related Information Collection that corresponds to each activity.

Table 2: Cross-Walk between Industry Activiti es and Related Information Collections (ICs)
Activity Description Related IC(s) Compliance

Determination Site staff must determine whether reporting is required for a chemical substance manufactured (including imported) at a particular site, based on the chemical substance’s pr oduction volume and the applicability of certain reporting exemptions. Submitters would report all data from 2011 and only production volume from 2010. This involves determining whether the production volume of a

chemical substance met or exceeded the 25,000 lb threshold in the 2011 principal reporting year. Compliance Determination

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 respondents must register with CDX. In addition, respondents must complete an Electronic Si gnature Agreement form, which is signed, dated. and either submitted electronically or mail ed 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 chemical

substances at that site. The information must be reviewed, and submitted to EPA. This task involves any research necessary to identify the correct information to report, the act of completing Form U (technical and clerical bu rden), and managerial review. Once Form U is completed, company staff

must submit it electroni cally to EPA via CDX. Prepare and Submit Report, and

Maintain RecordsPartial Report

Prepare and Submit Report, and

Maintain Records – Full ReportJune 13, 2011

Page 21 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency Recordkeeping Respondents must keep records supporting their submissions for five years. Prepare and Submit Report, and

Maintain Records - Partial Report

Prepare and Submit Report, and

Maintain RecordsFull Report

Burden estimates were derived originally from a survey conducted by EPA in 1996 (under OMB Control No. 2070-0034) to assess the poten tial burden associated with the IUR, as amended at that time. The survey was distributed to previous IUR respondents 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 final rule were derived as described in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011).

Table 3 and Table 4 illustrate the burden fo r a typical respondent on a per-activity basis, including time required to complete each sec tion of Form U. Because IUR reporting for all respondents occurs within a re quired timeframe, which EPA has changed from once every five years to once every four years, the Agency e xpects only one collection to occur, in 2012, during the three-year period covered by this ICR adde ndum. Therefore, burden hour estimates for 2011 and 2012 (Table 3) are based on the fi rst reporting cycle burdens in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011). Burden hour estimates for 2013 (Table 4) are based on the future reporting cycle burdens as also described in the economic analysis (EPA, 2011). 4 The section-by-section industry burden estimates for report preparation also include the burden of complia nce determination and rule familiarization. EPA estimates the total industry burden for completing and submitting one partial report to be 53.56 hours, and the estimated burden for completi ng and submitting one full report, to be 136.58 hours in the first reportin g cycle. Each site is expected to submit an average of 5.07 full reports and 1.26 partial reports in th e first reporting cycle.

EPA calculated burden estimates for each elem ent of Form U individually using the 1996 survey results, economic analyses for other rules with similar requi rements (such as the Premanufacture Notification Electronic Reporting final rule), and EPA’ s best professional judgment. More detailed information on the derivation of these estimates is found in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011).

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

exports.

4 EPA believes that the burden for futu re reporting cycles will be reduced becau se of efficiencies achieved through the establishment of compliance processes; as described in the IUR EA (EPA, 2011). After a site’s first reporting 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.June 13, 2011Page 22 of 54Office of Pollution Prevention and ToxicsU.S. Environmental Protection AgencyTable 3: Total Industry Burden, by Activity, First Reporting CycleActivityClerical Burden(hours)Technical Burden(hours)ManagerialBurden(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 InformationCertification 0.00 0.85 1.01 1.86Company Information (U.S. Parent Company Name, D&B Number,Mailing Address, Technical Contact, Technical Contact MailingAddress)0.00 0.04 0.02 0.06Plant Site Identification (Site Name, D&B Number, Mailing Address) 0.00 0.06 0.02 0.08Information for Joint Submissions (First Reporting Cycle Only) 0.00 0.005 0.01 0.01Total for Part I0.00 0.95 1.06 2.01Part II.Manufacturing InformationSite-Limited, Activity, Production Volume (lb) (2011) 0.00 2.28 0.56 2.84Chemical Substance Identification Upfront CBI Substantiation0.00 1.45 0.77 2.22Accession Number Requests0.000.010.000.01Plant Site Upfront Substantiation 0.00 0.83 0.51 1.34Total Number of Workers0.00 1.43 0.59 2.02Maximum Concentration, Physical Form, Percent Volume ofProduction 0.00 2.79 1.07 3.86Production Volume for 20100.00 1.03 0.25 1.28Production Volume Used On-Site0.00 0.20 0.05 0.25Whether Imported Chemical Substance is Physically at ReportingSite0.00 0.11 0.03 0.14Volume Exported0.00 1.03 0.25 1.28Whether a Chemical Substance isto be Recycled, Remanufactured,Reprocessed, or Reused. 0.00 0.11 0.03 0.14Total for Part II0.0011.27 4.10 15.37Part III. Processing and Use InformationUpfront Substantiation for Processing and Use InformationCBI Claims0.00 0.43 0.26 0.69Industrial Processing andUse Exposure-Related DataDetermination of Applicability 0.00 1.01 0.28 1.29Industrial Function Category 0.00 4.67 2.07 6.73June 13, 2011Page 23 of 54Office of Pollution Prevention and ToxicsU.S. Environmental Protection AgencyActivityClerical Burden(hours)Technical Burden(hours)ManagerialBurden(hours)Total Burden(hours)(a) (b) (c) (d) = (a)+(b)+(c)Sector 0.00 0.94 0.40 1.33Percent of Production Volume 0.00 10.00 5.27 15.27Total Number of Processing and Use Sites 0.00 9.14 3.52 12.67Total Number of Potentially Exposed Workers 0.00 15.43 3.83 19.26Consumer and Commercial Use Exposure-Related DataDetermination of Applicability 0.00 0.94 0.25 1.19Identification of Production Category/Use by Children 0.001.68 0.25 1.92Percent of Production Volume 0.00 1.26 0.45 1.71Maximum Concentration by Category 0.00 1.36 0.34 1.70Number of Commercial Workers Reasonably Likely to beExposed0.00 15.43 3.83 19.26Total for Part III0.0062.26 20.76 83.02COMPLIANCE DETERMINATIONCompliance Determination0.002.500.002.50RULE FAMILIARIZATIONRule Familiarization0.0019.009.0028.00CDX REGISTRATION ACTIVITIESCDX Registration 0.00 0.73 0.18 0.92CDX Electronic Signature Agreement 0.00 1.00 0.75 1.75Total for CDX Registration Activities 0.001,730.932.67RECORDKEEPINGRecordkeeping0.75 1.50 0.75 3.00TOTAL BURDENBurden for one PartialReport (Parts I, II, Compliance Determination,Rule Familiarization, Recordkeepingand CDX Registration Activities)0.75 36.96 15.84 53.55Burden for one FullReport (Parts I, II, III, Compliance Determination,Rule Familiarization, Recordkeepingand CDX Registration Activities)0.75 99.22 36.60 136.57Note:Totals may not sum due to rounding.Source:Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule(EPA, 2011).June 13, 2011Page 24 of 54Office of Pollution Prevention and ToxicsU.S. Environmental Protection AgencyTable 4: Total Industry Burden, byActivity, Future Reporting CyclesActivityClerical Burden(hours)Technical Burden(hours)ManagerialBurden(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 InformationCertification 0.00 0.85 1.011.86Company Information (U.S. Parent Company Name, D&B Number,Mailing Address, Technical Contact, Technical Contact MailingAddress)0.00 0.01 0.004 0.01Plant Site Identification (Site Name, D&B Number, Mailing Address) 0.00 0.01 0.004 0.02Total for Part I 0.00 0.87 1.02 1.89Part II.Manufacturing InformationSite-Limited, Activity, Production Volume (lb) (2015) 0.00 1.82 0.45 2.27Chemical Substance Identification Upfront CBI Substantiation 0.00 1.16 0.61 1.77Plant Site Upfront Substantiation 0.00 0.66 0.41 1.07Total Number of Workers 0.00 1.14 0.47 1.61Maximum Concentration, Physical Form, Percent Volume ofProduction0.00 2.23 0.86 3.09Production Volume for Each ofthe Years since Last PrincipalReporting Year (2012 - 2014)0.00 2.46 0.60 3.07Production Volume Used On-Site 0.00 0.16 0.04 0.20Whether Imported Chemical Substance is Physically at ReportingSite0.00 0.09 0.02 0.11Volume Exported 0.00 0.82 0.20 1.02Whether a Chemical Substance isto be Recycled, Remanufactured,Reprocessed or Reused.0.00 0.09 0.02 0.11Total for Part II 0.00 10.65 3.68 14.33Part III. Processing and Use InformationUpfront Substantiation for Processing and Use InformationCBI Claims0.00 0.43 0.21 0.64Industrial Processing andUse Exposure-Related DataDetermination of Applicability 0.00 0.81 0.23 1.03Industrial Function Category 0.00 3.53 1.65 5.18Sector 0.00 0.75 0.32 1.06June 13, 2011Page 25 of 54Office of Pollution Prevention and ToxicsU.S. Environmental Protection AgencyActivityClerical Burden(hours)Technical Burden(hours)ManagerialBurden(hours)Total Burden(hours)(a) (b) (c) (d) = (a)+(b)+(c)Percent of Production Volume 0.00 8.00 4.22 12.22Total Number of Processing and Use Sites 0.00 7.31 2.82 10.13Total Number of Potentially Exposed Workers 0.00 12.34 3.06 15.41Consumer and Commercial Use Exposure-Related DataDetermination of Applicability 0.00 0.75 0.20 0.95Identification of Production Category/Use by Children 0.00 0.67 0.20 0.87Percent of Production Volume 0.00 1.01 0.36 1.37Maximum Concentration by Category 0.00 1.09 0.28 1.36Number of Commercial Workers Reasonably Likely to beExposed0.00 12.34 3.06 15.41Total for Part III0.0049.03 16.60 65.63COMPLIANCE DETERMINATIONCompliance Determination0.002.500.002.50RULE FAMILIARIZATIONRule Familiarization0.002.002.004.00CDX REGISTRATION ACTIVITIESCDX Registration 0.00 0.73 0.18 0.92CDX Electronic Signature Agreement 0.00 1.00 0.75 1.75Total for CDX Registration Activities 0.001.730.932.67RECORDKEEPINGRecordkeeping0.75 1.50 0.75 3.00TOTAL BURDENBurden for one PartialReport (Parts I, II, Compliance Determination,Rule Familiarization, Recordkeepingand CDX Registration Activities)0.75 17.52 7.45 28.39Burden for one FullReport (Parts I, II, III, Compliance Determination,Rule Familiarization, Recordkeepingand CDX Registration Activities)0.75 66.54 24.05 94.02Note:Totals may not sum due to rounding.Source:Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule(EPA, 2011).June 13, 2011

Page 26 of 54 Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency 6(b) Estimating Submitter Cost

EPA multiplied burden estimates by standard wa ge rates for managerial, technical, and clerical levels developed from information pub lished by the Bureau of Labor 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 health insurance and vacation, is taken for each labor category from the same ECEC series. Fo llowing the methodology outlined in (EPA, 2002b), fringe benefits are calculated as a percenta ge of total wages for each category. EPA added 17 percent to the wages in each category to accoun t for overhead, based on information provided by the chemical industry and chemical 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 salaries in year 2008 dollars. Tabl e 5 contains the loaded wage rates for the managerial, technical and clerical occupa tion 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 45.03% 17% 1.65 $28.48

1 Employer Costs for Employ ee Compensation Supplem entary 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, 2002a).

Table 6 contains the cost pe r activity of completing Form U for one respondent in the first reporting cycle. Burden hours presented in Table 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 $3,305 and the cost for completing and submitting one full report is $8,422. More information on the deriva tion of these costs is found in the IUR EA (EPA, 2011).

Similarly, Table 7 contains the cost per activ ity of completing Form U for one respondent in future reporting cycles. Burden hours pr esented in Table 4 were multiplied by the corresponding loaded wage rage in Table 5. EP A estimates the total cost for completing and submitting one partial report in future reporting cy cles is $1,574 and the cost for completing and submitting one full report is $5,621. More informati on on the derivation of these costs is found in the IUR EA (EPA, 2011).June 13, 2011Page 27 of 54Office of Pollution Prevention and ToxicsU.S. Environmental Protection AgencyTable 6: Total Industry Cost, by Activity, First Reporting CycleActivityClerical Cost(2008$)Technical Cost(2008$)ManagerialCost(2008$)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 InformationCertification $0.00 $50.01 $70.73 $120.74Company Information (U.S. Parent Company Name, D&B Number,Mailing Address, Technical Contact, Technical Contact MailingAddress)$0.00 $2.35 $1.40 $3.75Plant Site Identification (Site Name, D&BNumber, Mailing Address) $0.00 $3.53 $1.40 $4.93Information for Joint Submissions (First Reporting Cycle Only) $0.00 $0.27 $0.59 $0.86Total for Part I $0.00 $56.17 $74.12 $130.29Part II.Manufacturing InformationSite-Limited, Activity, Production Volume (lb) (2011) $0.00 $134.15 $39.22 $173.37Chemical Identification Upfront CBI Substantiation $0.00 $85.32 $53.57 $138.89Accession Number Requests $0.00 $0.78 $0.00 $0.78Plant Site Upfront Substantiation $0.00 $48.84 $35.71 $84.55Total Number of Workers $0.00 $84.14 $40.97 $125.11Maximum Concentration, Physical Form, Percent Volume ofProduction$0.00 $164.16 $74.93 $239.09Production Volume for 2010 $0.00 $60.37 $17.65 $78.02Production Volume Used On-Site $0.00 $11.71 $3.42 $15.14Whether Imported Chemical Substance is Physically at ReportingSite$0.00 $6.71 $1.96 $8.67Volume Exported $0.00 $60.37 $17.65 $78.02Whether a Chemical Substance isto be Recycled, Remanufactured,Reprocessed or Reused.$0.00 $6.71 $1.96 $8.67Total for Part II $0.00 $663.25 $287.03 $950.29Part III. Processing and Use InformationUpfront Substantiation for Processing and Use InformationCBI Claims$0.00 $25.12 $18.37 $43.49Industrial Processing andUse Exposure-Related DataDetermination of Applicability $0.00 $59.27 $19.94 $79.21Industrial Function Category $0.00 $274.49 $144.64 $419.13June 13, 2011Page 28 of 54Office of Pollution Prevention and ToxicsU.S. Environmental Protection AgencyActivityClerical Cost(2008$)Technical Cost(2008$)ManagerialCost(2008$)Total Cost(2008$)(a) (b) (c) (d) = (a)+(b)+(c)Sector $0.00 $55.01 $27.68 $82.69Percent of Production Volume $0.00 $588.41 $369.34 $957.75Total Number of Processing and Use Sites $0.00 $537.89 $246.72 $784.62Total Number of Potentially Exposed Workers $0.00 $907.74 $268.15 $1,175.90Consumer and Commercial Use Exposure-Related DataDetermination of Applicability $0.00 $55.01 $17.56 $72.57Identification of Production Category/Use by Children $0.00 $98.73 $17.26 $116.00Percent of Production Volume $0.00 $74.02 $31.55 $105.57Maximum Concentration by Category $0.00 $80.02 $24.11 $104.13Number of Commercial Workers Reasonably Likely to beExposed$0.00 $907.74 $268.15 $1,175.90Total for Part III$0.00 $3,663.47 $1,453.48 $5,116.95COMPLIANCE DETERMINATIONCompliance Determination$0.00$147.10$0.00$147.10RULE FAMILIARIZATIONRule Familiarization$0.00$1,117.95$630.25$1,748.19CDX REGISTRATION ACTIVITIESCDX Registration $0.00$43.15$12.84$55.99CDX Electronic Signature Agreement $0.00$58.84$52.52$111.36Total for CDX Registration Activities $0.00 $101.99 $65.36 $167.35RECORDKEEPINGRecordkeeping$21.36 $88.26 $52.52 $162.14TOTAL COSTCost for one PartialReport (Parts I, II, Compliance Determination,Rule Familiarization, Recordkeepingand CDX Registration Activities)$21.36 $2,174.71 $1,109.28 $3,305.35Cost for one FullReport (Parts I, II, III, Compliance Determination,Rule Familiarization, Recordkeepingand CDX Registration Activities)$21.36 $5,838.18 $2,562.76 $8,422.30Note:Totals may not sum due to rounding.Source:Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule(EPA, 2011).June 13, 2011Page 29 of 54Office of Pollution Prevention and ToxicsU.S. Environmental Protection AgencyTable 7: Total Industry Cost, by Activity, Future Reporting CyclesActivityClerical Cost(2008$)Technical Cost(2008$)ManagerialCost(2008$)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 InformationCertification $0.00 $50.01 $70.73 $120.74Company Information (U.S. Parent Company Name, D&B Number,Mailing Address, Technical Contact, Technical Contact MailingAddress)$0.00 $0.47 $0.28 $0.75Plant Site Identification (Site Name, D&B Number, Mailing Address) $0.00 $0.71 $0.28 $0.99Total for Part I $0.00 $51.19 $71.29 $122.48Part II.Manufacturing InformationSite-Limited, Activity, Production Volume (lb) (2015) $0.00 $107.32 $31.37 $138.70Chemical Identification Upfront CBI Substantiation $0.00 $68.25 $42.86 $111.11Plant Site Upfront Substantiation $0.00 $39.07 $28.57 $67.64Total Number of Workers $0.00 $67.31 $32.77 $100.08Maximum Concentration, Physical Form, Percent Volume ofProduction$0.00 $131.33 $59.94 $191.27Production Volume for Each ofthe Years since Last PrincipalReporting Year (2012 - 2014)$0.00 $144.89 $42.35 $187.24Production Volume Used On-Site $0.00 $9.37 $2.74 $12.11Whether Imported Chemical Substance is Physically at ReportingSite$0.00 $5.37 $1.57 $6.93Volume Exported $0.00 $48.30 $14.12 $62.41Whether a Chemical Substance isto be Recycled, Remanufactured,Reprocessed or Reused$0.00 $5.37 $1.57 $6.93Total for Part II $0.00 $626.57 $257.86 $884.43Part III. Processing and Use InformationUpfront Substantiation for Processing and Use InformationCBI Claims$0.00 $25.12 $14.70 $39.82Industrial Processing andUse Exposure-Related DataDetermination of Applicability $0.00 $25.12 $15.95 $41.07Industrial Function Category $0.00 $0.00 $115.71 $115.71Sector $0.00 $47.41 $22.14 $69.56Percent of Production Volume $0.00 $207.82 $295.47 $503.30June 13, 2011Page 30 of 54Office of Pollution Prevention and ToxicsU.S. Environmental Protection AgencyActivityClerical Cost(2008$)Technical Cost(2008$)ManagerialCost(2008$)Total Cost(2008$)(a) (b) (c) (d) = (a)+(b)+(c)Total Number of Processing and Use Sites $0.00 $44.01 $197.38 $241.39Total Number of Potentially Exposed Workers $0.00 $470.73 $214.52 $685.25Consumer and Commercial Use Exposure-Related DataDetermination of Applicability $0.00 $47.41 $14.05 $61.46Identification of Production Category/Use by Children $0.00 $207.82 $13.81 $221.63Percent of Production Volume $0.00 $44.01 $25.24 $69.25Maximum Concentration by Category $0.00 $470.73 $19.29 $490.01Number of Commercial Workers Reasonably Likely to beExposed$0.00 $430.32 $214.52 $644.84Total for Part III$0.00 $2,884.62 $1,162.78 $4,047.40COMPLIANCE DETERMINATIONCompliance Determination$0.00$147.10$0.00$147.10RULE FAMILIARIZATIONRule Familiarization$0.00$117.68$140.05$257.73CDX REGISTRATION ACTIVITIESCDX Registration $0.00$43.15$12.84$55.99CDX Electronic Signature Agreement $0.00$58.84$52.52$111.36Total for CDX Registration Activities $0.00 $101.99 $65.36 $167.35RECORDKEEPINGRecordkeeping$21.36 $88.26 $52.52 $162.14TOTAL COSTCost for one PartialReport (Parts I, II, Compliance Determination,Rule Familiarization, Recordkeepingand CDX Registration Activities)$21.36 $1,132.78 $587.08 $1,741.23Cost for one FullReport (Parts I, II, III, Compliance Determination,Rule Familiarization, Recordkeepingand CDX Registration Activities)$21.36 $4,017.41 $1,749.87 $5,788.63Note:Totals may not sum due to rounding.Source:Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule(EPA, 2011).Page 31 of 54 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 activit ies that involve using the data are not included.

EPA Staff Activities

Of the tasks listed above, Agency personnel are responsible for 1) qual ity control of data entry; and 2) data processing, systems developm ent, and contract oversight and management. Contractors perform the other ac tivities, as described below.

EPA estimates the total burden of completing Ag ency tasks to be one full-time equivalent at the GS 13 level for data processing, syst ems development, and contract oversight and management, per-reporting cycle. An estimated 0.548 FTEs are needed at the GS 12 level for quality control of data entry in the first repo rting cycle and 0.193 FTEs are needed in future reporting cycles. Calculations of th e Agency burden are presented in Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011).

EPA labor costs are based on annual federa l wage rates published by the Office of Personnel Management for the Washington-Balt imore-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 Inventory Update Rule: Final Report (EPA, 2002a), EPA added 58 percent to the wage rate to account for fringe benefits and overhead costs.

Error! Reference source not found. 8 shows the loaded wage rates for Agency staff at the GS-12 Step 3, and GS-13 Step 3 levels.Page 32 of 54 Table 8: Derivation of Loaded Agency Wage Rates (2008$)

Pay Grade Annual Salary Overhead and Fringe

Benefits (% of wages) Overhead and Fringe

Benefit Cost Total

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

GS 13 Step 3 $88,493 58% $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).

Error! Reference source not found. 9 and Table 10 contains the burden and cost per report for all EPA staff activities in the first a nd future reporting cycles. The activities performed by the GS-13 level staff member, including system s development, and contract oversight and management, are fixed costs and are not dependent on the number of reports submitted to EPA. Therefore, the total burden for systems developm ent and contract oversight is one FTE at the GS-13 level, with a cost of $139,819 in both the first and future re porting cycles. Quality control of data entry is performed by the GS-12 level st aff member and is dependent on the number of reports received. The burden for quality cont rol of data is approximately 0.000091 FTE per report in the first reporting cycle and 0.000011 FTE in future reporting cycles. The total cost perreport is approximately $15.08 in the first reporting cy cle and $1.38 in future reporting cycles. The burden and cost of processing each data element in Form U are derived in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011). EPA multiplied the burdens by the number of data elem ents 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 the IUR EA (EPA, 2011).

Table 9: EPA Staff Burden and Cost of Pro cessing One Report (First Reporting Cycle)

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 for Part I 0.0000827 0.1720 $11.55
Quality Control of Data for Part II 0.0000057 0.0118 $3.14

Quality Control of Data for Part III 0.0000030 0.0063 $0.39

Total GS-12 Burd en, per report 0.0000914 0.1901 $15.08
GS-13 Step 3 Fixed Cost Burden Systems development, and contract oversight and

management 1 2,080 $139,819

Total GS-13 Burden, per reporting cycle 1 2,080 $139,819Page 33 of 54 Table 10: EPA Staff Burden and Cost of Pro cessing One Report (Future Reporting Cycles)

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 for Part I 0.0000048 0.0100 $0.66
Quality Control of Data for Part II 0.0000026 0.0054 $0.33
Quality Control of Data for Part III 0.0000030 0.0063 $0.39

Total GS-12 Burd en, per report 0.0000105 0.0218 $1.38 GS-13 Step 3 Fixed Cost Burden Systems development, 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 extr amural tasks completed by contractors (this category includes costs to EPA, but not burden h ours). Contractor activit ies include document receipt, tracking, data entry, maintaining bac kup systems, printing and publishing forms and materials, and managing the TSCA Hotline, as pr esented in Tables 11 and 12. 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 cost s are taken from the last published ICR and were

inflated from 2007 to 2008 dollars with an inflati on factor calculated using the Employment Cost Index (ECI), seasonally adjusted, for white-colla r occupations in privat e industry (BLS, 2009).

EPA calculated the cost estimate per report for document receipt, tracking, and data entry, $0.64 in the first reporting cycle and $0.65 in future reporting cycles, by starting with the cost estimated in the 2007 ICR, and updating it to reflect the new data elements and the electronic submission requirement in the final amendments. The reduction in burden caused by the electronic submission requirement is based on a study conducted by EPA, “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 system. For more information, see the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011).Page 34 of 54 Table 11: Cost of Contractor Activities (First Reporting Cycle)

Activity Annual Cost (2007$) 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 $0.30

Total Cost of Document receipt, tracking, and data entry, per full
report $5.14 n/a $0.64

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

Table 12: Cost of Contractor Activities (Future Reporting Cycles)

Activity Annual Cost 2007$ 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 $0.26

Document receipt, tracking, and data entry for Part III $2.45 n/a $0.30

Total Cost of Document receipt, tracking, and data entry, per full
report $5.14 n/a $0.65

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 $109,365

6(d) Bottom-Line Industry Bu rden and Cost Estimates

This section describes the estimated total so cial paperwork burden and cost of the IUR rule, including the final amendments. The next IUR submission period will occur in 2012 for chemical substances manufactured (including im ported) during the calendar year 2011. Even though reporting occurs only once per reporting cycle (once every six years for the 2012 cycle and once every four years in the future), EPA believes rule compliance and data collectionPage 35 of 54 activities, and thus, costs and burdens, are incurred over the c ourse of the reporting cycle. Therefore, for purposes of this analysis, the burd en 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 fo r 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 the numbers of sites and reports submitted based on submission

information from the December 2008 version of th e IUR database, which includes data from the most recent (2006) IUR collection. The EPA IUR da tabase contains information collected under the IUR for previous submission periods and was us ed to generate estimates of expected reports for the 2012 reporting cycle. In the 2011 and 2012, EPA expects a total of 4,085 sites to submit 20,718 full reports (80 percent of all reports) and 5,135 partial reports (20 pe rcent of all reports) for a total of 25,853 reports. In future reporting cycles, EPA expects 4,289 sites to submit 30,287 full reports and 648 partial reports for a total of 30,935 reports (98 percent and two percent of all reports, respectively).

Total Industry Burden/Cost for First Reporting Cycle . EPA estimates the total industry burden for the first reporting cycle, including both current baseline burden and the burden resulting from the final amendments, to be 2.34 million hours. Given that this data collection is part of a six-y ear reporting cycle, EPA estimates the annual industry burden for 2011 and 2012 to be 389,771 hours. As presented in Table 13, EPA estimates the total cost to industry would be $144 million, or an annual cost of $24.0 million.Page 36 of 54Table 13: Estimated Respondent Burden and Cost Associated with the First Reporting Cycle (2011 and 2012)ActivityTotal Burden perActivity (hours)TotalNumber ofUnitsTotal Cost perActivity(2008$)Total Burden perReporting Cycle (hours)Total CostperReportingCycle(2008$)AnnualBurden(hours)Annual Cost (2008$)ComplianceDetermination(per Site)2.50 4,085 Sites $147.10 10,213 $600,8961,702 $100,149RuleFamiliarization(per Site)28.00 4,085 Sites $1,748.19 114,380 $7,141,37019,063 $1,190,228CDXRegistrationActivities (perSite)2.67 4,085 Sites $167.35 10,893 $683,6131,816 $113,935Part IPreparation(per site)2.01 4,085 Sites $130.29 8,223 $532,2321,371 $88,705Partial ReportPreparation(Part II, perReport)15.375,135 PartialReports$950.29 78,931 $4,879,72913,155 $813,288Full ReportPreparation(Part II andPart III,per Report)98.3920,718 FullReports$6,067.24 2,038,430 $125,700,980339,738 $20,950,163Recordkeeping(per Report)3.0025,853Reports$162.14 77,559 $4,191,74212,927 $698,624Total Industry Burden and Cost for the First Reporting Cycle 2,338,629 $143,730,561 389,771 $23,955,094Note:Totals may not sum due to roundingPage 37 of 54 Total Industry Burden and Cost for Future Reporting Cycles . EPA estimates the total industry burden for future reporting cycles, in cluding both current ba seline burden and the burden resulting from the final amendments, to be 2.57 million hours. Given that this data collection will occur every four years, EPA estimat es the annual industry burden for future years to be 642,823 hours. As presented in Table 14, EPA es timates the total cost to industry would be $158 million, or an annual cost of $39.5 million.Page 38 of 54Table 14: Estimated Annual Respondent Burden andCost Associated with Future Reporting Cycles (2013)ActivityTotalBurden perActivity(hours)Total Numberof UnitsTotal CostperActivity(2008$)Total Burden(hours)Total Cost perReportingCycle (2008$)Annual Burden(hours)Annual Cost (hours)ComplianceDetermination(per Site)2.50 4,289 Sites $147.10 10,723 $630,9042,681 $157,726RuleFamiliarization(per Site)4.00 4,289 Sites $257.73 17,156 $1,105,4194,289 $276,355CDXRegistrationActivities (perSite)2.67 4,289 Sites $167.35 11,437 $717,7512,859 $179,438Part IPreparation(per Site)1.89 4,289 Sites $122.48 8,098 $525,3092,024 $131,327Partial ReportPreparation(Part II, perReport)14.33648 PartialReports$884.43 9,287 $573,1122,322 $143,278Full ReportPreparation(Part II and PartIII, per Report)79.9630,287 FullReports$4,931.84 2,421,786 $149,370,529605,447 $37,342,632Recordkeeping(per Report)3.00 30,935 Reports $162.14 92,829 $5,017,02223,207 $1,254,256Total Industry Burden and Cost forFuture Reporting Cycles2,571,291 $157,938,749 642,823 $39,484,687Note:Totals may not sum due to roundingPage 39 of 54 Annual Industry Burden and Cost for 2011 to 2013. As shown in Table 15, EPA

calculated the estimated total a nnual respondent burden and cost associated with this ICR addendum by taking a weighted average of the first and future reporting cycles , to reflect that the period covered by this ICR, 2011 through 2013, sp ans two reporting cycles with different

burdens and costs. The total a nnual burden associated with this ICR addendum is 474,122 hours. The total annual cost is $29.1 million.

Table 15: Estimated Annual Average Burden a nd 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$) Total

Annual

Burden (hours) Total

Annual

Cost (2008$) Compliance

Determination (per Site) 1,702 $100,149 1,702 $100,149 2,681 $157,726 2,028 $119,342

Rule

Familiarization (per Site) 19,063 $1,190,228 19,063 $1,190,228 4,289 $276,355 14,139 $885,604

CDX Registration

Activities (per Site) 1,816 $113,935 1,816 $113,935 2,859 $179,438 2,163 $135,770

Part I Preparation (per Site) 1,371 $88,705 1,371 $88,705 2,024 $131,327 1,589 $102,913

Partial Report Preparation (Part II, per Report) 13,155 $813,288 13,155 $813,288 2,322 $143,278 9,544 $589,952

Full Report Preparation (Part II and Part III, per Report) 339,738 $20,950,163 339,738 $20, 950,163 605,447 $37,342,632 428,308 $26,414,320

Recordkeeping (per Report) 12,927 $698,624 12,927 $698,624 23,201 $1,253,931 16,351 $883,726

Total 474,122 $29,131,625

Average Burden and Cost per Site. As shown in Table 16, the Agency estimates the typical respondent burden for this information collection activity to be 572 hours in the first reporting cycle and 600 hours in fu ture reporting cycles. Given that the 2011 and 2012 (first) collection is based on a six-year reporting cycle, the average a nnual burden for the first reporting cycle would be 95 hours. Given th at a collection would occur on ce every four years under the final rule, the average annual burden for future cycles would be 150 hours. These burden

estimates assume each site will submit an aver age of 5.07 full reports and 1.26 partial reports in both the next reporting cycle, and 7.06 full repor ts and 0.15 partial reports in future reporting cycles. This is a decrease of 2.04 partial reports per site and an increase of 1.67 full reports per site in the first cycle compared to the average nu mber of reports completed per site presented in the currently approved ICR (EPA ICR No. 1884.04).Page 40 of 54 Table 16: Average Burden per Site

Activity Burden Hours
Total Hours per

Activity Reports

per Average

Site Total

Burden (hours 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 Site) 10.99 24.19 0.00 35.18 1.00 35.18 5.86

Partial Report Preparation (Part II, per Report) 4.10 11.27 0.00 15.37 1.26 19.32 3.22

Full Report Preparation (Part II and Part III, per Report) 24.85 73.53 0.00 98.39 5.07 499.00 83.17

Recordkeeping (per Report) 0.75 1.50 0.75 3.00 6.33 18.99 3.16

Total Hours 572 95.42

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) 3.68 10.65 0.00 14.33 0.15 2.17 0.54

Full Report Preparation (Part II and Part III, per Report) 20.29 59.67 0.00 79.96 7.06 564.65 141.16

Recordkeeping (per Report) 0.75 1.50 0.75 3.00 7.21 21.64 5.41

Total Hours 600 150Page 41 of 54 Table 17 presents the average cost per s ite, by activity, for an IUR respondent. EPA estimates the average site will submit 5.07 full re ports and 1.26 partial reports in the first reporting cycle and 7.06 full reports and 0.15 partial re ports in future report ing cycles and incur a total cost of $35,185 during the first reporting cycle ($5,864 annually), and $36,824 during future reporting cycles ($9,206 annually) for Form U completion and submission.

Table 17: Average Cost per Site

Activity Cost (2008$) Total Cost per Activity Reports

per Average

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) $770 $1,423 $0.00 $2,193 1.00 $2,193 $365

Partial Report Preparation (Part II, per Report) $287 $663 $0.00 $950 1.26 $1,195 $199

Full Report Preparation (Part II and Part III, per Report) $1,741 $4,327 $0.00 $6,067 5.07 $30,771 $5,129

Recordkeeping (per Report) $52.52 $88.26 $21.36 $162 6.33 $1,026 $171

Total Cost $35,185 $5,864
Future Reporting Cycles

Rule

Familiarization. Compliance Determination, CDX Registration

Activities and Part I Preparation (per site) $277 $418 $0.00 $695 1.00 $695 $174

Partial Report Preparation (Part II, per Report) $258 $627 $0.00 $884 0.15 $134 $33.41

Full Report Preparation (Part II and Part III, per Report) $1,421 $3,511 $0.00 $4,932 7.06 $34,826 $8,707

Recordkeeping (per Report) $52.52 $88.26 $21.36 $162 7.21 $1,169 $292

Total Cost $36,824 $9,206Page 42 of 54 As shown in Table 18, EPA calculated the estim ated burden and cost per site associated with this ICR addendum by taking a weighted averag e of the first and future reporting cycles to reflect that the period cove red by this ICR addendum, 2011 through 2013, spans two reporting cycles with different burdens and costs. The av erage annual burden per site is 114 hours and the average annual cost per site is $6,978.

Table 18: Estimated Annual Burden and Cost p er 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) 5.86 $365 5.86 $365 2.76 $174 4.83 $302

Partial Report Preparation (Part II, per Report) 3.22 $199 3.22 $199 0.54 $33 2.33 $144

Full Report Preparation (Part II and Part III, per Report) 83.17 $5,129 83.17 $5,129 141.16 $8,707 102.50 $6,321

Recordkeeping (per Report) 3.16 $171 3.16 $171 5.41 $292 3.91 $211

Total 114 $6,978

Table 19 presents the annual burden hours, or ganized by information collection, for both the first and future reporting cycle, and weighted, annual aver ages for the ICR addendum period, for IUR respondents.Page 43 of 54 Table 19: Annual Information Collection Ta lly for First and Future Reporting Cycles

Information Collection No. of Respondents No. of Responses / Respondent Responses

Subtotal Annual

Burden Hours per Response Annual

Burden Hours

Subtotal First Reporting Cycle (2011 and 2012) Compliance

Determination 4,085 1 4,085 0.42 1,702

Rule Familiarization 4,085 1 4,085 4.67 19,063 CDX Registration

Activities 4,085 1 4,085 0.44 1,816

− CDX Registration 4,085 1 4,085 0.15 624

− ESA 4,085 1 4,085 0.29 1,191 Prepare Part I of Form U 4,085 1 4,085 0.34 1,371 Prepare and Submit Report, and Maintain Records – Partial Report 4,085 1.26 5,135 3.06 15,723

− Part II of Form U 4,085 1.26 5,135 2.56 13,155

− Recordkeeping 4,085 1.26 5,135 0.50 2,568 Prepare and Submit Report, and Maintain Records - Full Report 4,085 5.07 20,718 16.90 350,097

− Part II and III of

Form U 4,085 5.07 20,718 16.40 339,738

− Recordkeeping 4,085 5.07 20,718 0.50 10,359
Future Reporting Cycles (2013) Compliance

Determination 4,289 1.00 4,289 0.63 2,681

Rule Familiarization 4,289 1 4,289 1.00 4,289 CDX Registration

Activities 4,289 1 4,289 0.67 2,859

− CDX Registration 4,289 1 4,289 0.23 983

− ESA 4,289 1 4,289 0.44 1,876 Prepare Part I of Form U 4,289 1 4,289 0.47 2,024 Prepare and Submit Report, and Maintain Records – Partial Report 4,289 0.15 648 4.33 2,808

− Part II of Form U 4,289 0.15 648 3.58 2,322

− Recordkeeping 4,289 0.15 648 0.75 486 Prepare and Submit Report, and Maintain Records - Full Report 4,289 7.06 30,287 20.74 628,162

− Part II and III of

Form U 4,289 7.06 30,287 19.99 605,447

− Recordkeeping 4,289 7.06 30,287 0.75 22,715
Average Burden for ICR Addendum Period

Compliance

Determination 4,153 1 4,153 0.49 2,028

Rule Familiarization 4,153 1 4,153 3.40 14,139 CDX Registration

Activities 4,153 1 4,153 0.52 2,163

Prepare Part I of Form

U 4,153 1 4,153 0.38 1,589

Prepare and Submit Report, and Maintain 4,153 0.89 3,639 3.14 11,418Page 44 of 54 Information Collection No. of Respondents No. of Responses / Respondent Responses

Subtotal Annual

Burden Hours per Response Annual

Burden Hours

Subtotal

Records – Partial Report -- Part II of Form U 4,153 0.89 3,639 2.62 9,544 -- Recordkeeping 4,153 0.89 3,639 0.51 1,874 Prepare and Submit Report, and Maintain Records - Full Report 4,153 5.74 23,908 18.52 442,785

--Part II and III of

Form U 4,153 5.74 23,908 17.92 428,308

--Recordkeeping 4,153 5.74 23,908 0.61 14,478
Some burden estimate subtotals may not calcula te due to rounding of unit burden estimates

Table 20 presents the total burden hours for the ICR period (2011 – 2013), organized by information collection, for both the first and futu re reporting cycles, fo r IUR respondents.Page 45 of 54 Table 20: Information Collection Tally fo r ICR Reporting Period (2011- 2013)

Information Collection No. of Respondents No. of Responses / Respondent Responses

Subtotal Total Burden Hours per Response Total Burden

Hours Subtotal

First Reporting Cycle (2011 and 2012) Compliance

Determination 4,085 1 4,085 0.83 3,404

Rule Familiarization 4,085 1 4,085 9.33 38,127 CDX Registration

Activities 4,085 1 4,085 0.89 3,631

− CDX Registration 4,085 1 4,085 0.31 1,248

− ESA 4,085 1 4,085 0.58 2,383 Prepare Part I of Form U 4,085 1 4,085 0.67 2,741 Prepare and Submit Report, and Maintain Records – Partial Report 4,085 1.26 5,135 6.12 31,445

− Part II of Form U 4,085 1.26 5,135 5.12 26,310

− Recordkeeping 4,085 1.26 5,135 1.00 5,135 Prepare and Submit Report, and Maintain Records - Full Report 4,085 5.07 20,718 33.80 700,195

− Part II and III of

Form U 4,085 5.07 20,718 32.80 679,477

− Recordkeeping 4,085 5.07 20,718 1.00 20,718
Future Reporting Cycles (2013) Compliance

Determination 4,289 1.00 4,289 0.63 2,681

Rule Familiarization 4,289 1 4,289 1.00 4,289 CDX Registration

Activities 4,289 1 4,289 0.67 2,859

− CDX Registration 4,289 1 4,289 0.23 983

− ESA 4,289 1 4,289 0.44 1,876 Prepare Part I of Form U 4,289 1 4,289 0.47 2,024 Prepare and Submit Report, and Maintain Records – Partial Report 4,289 0.15 648 4.33 2,808

− Part II of Form U 4,289 0.15 648 3.58 2,322

− Recordkeeping 4,289 0.15 648 0.75 486 Prepare and Submit Report, and Maintain Records - Full Report 4,289 7.06 30,287 20.74 628,162

− Part II and III of

Form U 4,289 7.06 30,287 19.99 605,447

− Recordkeeping 4,289 7.06 30,287 0.75 22,715
Burden for ICR Addendum Period

Compliance

Determination 4,153 1 4,153 1.47 6,085

Rule Familiarization 4,153 1 4,153 10.21 42,416 CDX Registration

Activities 4,153 1 4,153 1.56 6,490

Prepare Part I of Form

U 4,153 1 4,153 1.15 4,766

Prepare and Submit Report, and Maintain 4,153 0.89 3,639 9.41 34,253Page 46 of 54 Information Collection No. of Respondents No. of Responses / Respondent Responses

Subtotal Total Burden Hours per Response Total Burden

Hours Subtotal

Records – Partial Report -- Part II of Form U 4,153 0.89 3,639 7.87 28,632 -- Recordkeeping 4,153 0.89 3,639 1.54 5,621 Prepare and Submit Report, and Maintain Records - Full Report 4,153 5.74 23,908 55.56 1,328,356

--Part II and III of

Form U 4,153 5.74 23,908 53.75 1,284,923

--Recordkeeping 4,153 5.74 23,908 1.82 43,433

Agency Tally

Tables 21 and 22 present the Agency costs as sociated with the IUR rule for the first reporting cycle and future reporting cycles, respectively. EPA multiplied the costs per report by the total number of Parts I, II, and III to calculate the total burden and cost associated with the number of reports EPA expects to be submitted. In the first reporting cycle, the total burden is 0.548 FTEs and the total cost is $149,387 for variable cost activities. In future reporting cycles the burden is 0.193 FTE and the cost is $42,331 for va riable 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 total Agency burden is 1.548 FTEs in the first reporting cycle and 1.193 FTEs in future reporting cycles. The estimated total cost incurred by the Agency for the fi rst reporting cycle, $398,571, and $291,515 in future reporting cycles was calculated by summing the Agency staff and contractor activities.Page 47 of 54 Table 21: Total Cost and Burden of Agen cy 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

data entry Contractor Part I N/A 4,085

Sites $0.09 N/A $377

Part II N/A 25,853

Part IIs $0.25 N/A $6,370

Part III N/A 20,718

Part IIIs $0.30 N/A $6,222

Quality

Control of

Data EPA Employee

(GS-12 Step 3) Part I 0.0000827 4,085

Sites $11.55 0.338 $47,170

Part II 0.0000057 25,853

Part IIs $3.14 0.147 $81,200

Part III 0.0000030 20,718

Part IIIs $0.39 0.063 $8,048

Total Variable Cost and Burden 0.548 $149,387

Fixed Burdens and Costs

Data Processing,

Systems Development,

and Contract Oversight 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 the

TSCA

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

Total Fixed Cost and Burden 1 $249,184 Total Agency Cost and Burden 1.55 $398,571Page 48 of 54 Table 22: Total Cost and Burden of Agency Activities (Future 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 data

entry Contractor Part I N/A 4,289 Sites $0.09 N/A $396

Part II N/A 30,935 Part

IIs $0.26 N/A $7,965

Part III N/A 30,287 Part

IIIs $0.30 N/A $9,079

Quality Control of

Data EPA Employee

(GS-12 Step 3) Part I 0.0000048 4,289 Sites $0.66 0.021 $2,843

Part II 0.0000026 30,935 Part

IIs $0.33 0.081 $10,304

Part III 0.0000030 30,287 Part

IIIs $0.39 0.092 $11,744

Total Variable Cost and Burden 0.193 $42,331

Fixed Burdens and Costs

Data Processing, Systems Development, and Contract Oversight 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 the

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

Total Fixed Cost and Burden 1 $249,184 Total Agency Cost and Burden 1.19 $291,515

6(e) Reasons for Change in Burden

EPA estimates industry will incur an increase of 63,637hours in annual burden compared

to the estimate in the information collection request most recently approved by OMB (from 410,485 hours as reported in the currently approv ed ICR (EPA ICR No. 1884.04) (EPA, 2008a), to 474,122hours as estimated in Section 6(d) above). Differences in burden and costs from the previous ICR are attributed to both adjustme nts and program changes. Adjustments capture changes in the baseline burde n not included in the currently approved ICR (EPA ICR No. 1884.04) (EPA, 2008a). These changes result from upda tes to the number of affected sites and wages, capturing effects of rule amendments th at were not included in the currently approved ICR, and the correction of estimates in the previous ICR. Program changes reflect the

amendments of the final IUR modifications rule , which affect per-site costs, the number of affected sites, and the number of final and pa rtial reports submitted. As shown in Table 22, EPA estimates an annual 66,250 hour burden decrease as a result of adjustment changes and an annualPage 49 of 54 increase of 105,534 hours as a result of program ch anges. More details on the adjustments and program changes are outlined below.

Adjustment Changes

The previous currently approved ICR (EPA ICR No. 1884.04) used data from the 2006 IUR database that had not gone through quality c ontrol to estimate the number of sites, and partial and full reports submitted to EPA. EP A ICR No. 1884.04 estimated that a total of 4,190 sites would submit 13,989 partial re ports and 14,409 full reports. EPA has adjusted the number of sites and reports using the qua lity-controlled data and estimates that a total of 4,085 sites will submit 8,821 partial reports and 17,075 full reports in the baseline.

The previous ICR did not take into a ccount the amendment in the 2006 Final IUR Revisions Rule that removed the requirement of reporting processing and use information for exports. This amendment reduced the burden associated with submitting and completing a final report by 15 percent.

The previous ICR used high-end burden esti mates, while the current ICR uses midpoint

estimates to be consistent with the Economic Analysis for the Fi nal Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011). EPA adjusted the burden estimates from the previous ICR using midpoint estimates to provide a consistent compar ison across ICRs. This change reduces the per-site burden associated complia nce determination, recordkeeping and submitting a

report.

The previous ICR used first-year burden for each burden activity, w ith the exception of rule familiarization which was estimated at 4 hours per site. The first-year range for this activity is 26-30 hours. EPA adjusted the rule familiarizat ion to the midpoint estimate (see above) of 28 hours to reflect the first-year burden.

The total of all of the adjustments results in a decrease in the base line total burden of 149,400 hours from 2,052,423 hours to 1,903,023 and a decr ease in the baseline annual burden of 29,880 hours from 41 0,485 hours to 380,605 hours.

All costs were inflated from 2007$ to 2008$, which slightly increased the costs associated with the rule. However, even after adjusting for inflation the total of all of the adjustments decreased the annual baselin e cost from $22,628,227 to $22,041,964; a decrease of $586,263.

Program Changes

The per-site costs, the number of affected site s, and the number of fi nal and partial reports submitted, will be impacted by several of the final modifications including:

• For the reporting cycles subsequent to the 2012 reporting cycle, a requirement was added to report whether, for any calendar year since th e previous IUR principal reporting year, the subject chemical was manufactured in productio n volumes of 25,000 lb or greater per year;Page 50 of 54 • Replace the 300,000 lb reporting threshold for pro cessing and use information by phasing in a lower reporting threshold. For the 2012 IUR manufactur ers (including importers) of non-excluded substances with production volumes greater than 100,000 lb are required to report processing and use information. Subsequent to the 2012 reporting cy cle, the reporting threshold for processing and use information will be 25,000 lb;

• Reduce the 25,000 lb threshold for reporting to 2,5 00 lb for specific regulated chemical substances and require manufacturers (including importers) of such chemical substances to report under the IUR rule, if production volume is greater than 2,500 lb beginning with the 2016 reporting cycle,

• Chemical substances subject to Enforceable Consent Agreements (ECAs) were made ineligible for exemptions;

• Manufactured water was fully exempt ed from reporting requirements;

• Certain reportable data elements, such as the company identification number, technical contact, and chemical identity, were amended;

• Submitters are required to report the ch emical substance’s production volume for both 2010 and 2011. For the reporting cycles subsequent to th e 2012 reporting cycle, submitters are required to report the chemical substance’s production volume for each year since the last principal reporting

year ;

• Submitters are required to report separa tely production volume used on-site;

• Submitters of imported chemical substances ar e required to indicate whether the chemical substance is physically at the report ing site;

• Submitters are required to report production volume exported;

• Submitters are required to indicate whether the chemical substance is to be recycled, remanufactured, reprocessed, or reused;

• For downstream processing and use information: the set of industrial function categories was revised, industrial sectors were provided instead of NAICS c odes, and the set of consumer and commercial product categories was revised;

• Submitters are required to identify whether a use is a consumer use, a commercial use, or both;

• Submitters are required to report the total numbe r of commercial workers, including those at sites not under the submitter’s control, that ar e reasonably likely to be exposed while using the reportable chemical substance, with respect to each commercial use;

• The reporting standard for processing and use information was changed from “readily

obtainable” to “known to or r easonably ascertainable by”;

• Upfront substantiation is required for claims that processing and use data are confidential business information (CBI);

• Submitters are restricted from being able to cl aim not “known to or reasonably ascertainable by” data as CBI;

• Submitters are required to submit forms elect ronically using the reporting tool, e-IURweb and EPA’s CDX; and

• The frequency of reporting was changed from every five years to every four years.

Details on the final amendments and the burde n and cost impacts of each amendment when taken individually and considered together (i .e., one amendment may change the impact of another, are described in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011).Page 51 of 54 Table 23: Total Estimate of Annual Burden Hours and Annualized Cost Comparisons

Annual Burden Hours Annual Cost Current OMB Inventory 410,485 $22,628,227 Change in Burden due to Adjustments -29,880 -$586,263

Change in Burden due to Program Changes 93,517 $7,089,661

Total Change in Burden 63,637 $6,503,398 Total Burden 474,122 $29,131,625

6(f) Burden Statement

The annual public burden for this collection of information is estimated to average 114 hours per respondent. According to the Paperwork 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. Fo r this collection it includes the time needed to determine whether a site is subject to the rule (Compliance Determination); review and understand instructions; prepare a nd submit reports (including sear ching data sources); complete

and review the collection of in formation; transmit the inform ation; and keep records.

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 control numbers for EPA's regulations in title 40 of the CFR, after appearing in the Federal Register when approved, are listed in 40 CFR Part 9, are di splayed either by publication in the Federal Register or by other appropriate means, such as on the related colle ction instrument or form, if applicable. The display of OMB control numbers in certain EPA regulations is consolidated in 40 CFR Part 9.

EPA has established a docket for this ICR addendum under Docket ID No. EPA-HQOPPT-2009-0187 which is available for public view ing at the Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC) , EPA West, Room B102, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Pub lic Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding lega l holidays. The telephone number for the Reading Room is (202) 566-1544 and the teleph one number for the Pollution Prevention and Toxics Docket is (202) 566-0280.

An electronic version of this docket is avai lable at http://www.re gulations.gov/. Use the federal government-wide electronic docket system at http://www.regulations.gov to view public comments, access the index listing of the docket c ontents, and to access those documents in the

docket that are available electroni cally. Once in the system, select “advance search,” then key in

the docket ID number identified above for EPA.Page 52 of 54 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, Office of Pollution Pr evention 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

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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 Modifica tions Final Rule (EPA-HQ OPPT 2004-0106-

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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-HQOPPT-2008-0504-0002.

EPA, 2008b. 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, 2009a. U.S. EPA, Office of Pollution Prevention and Toxics. TSCA Section 4 Federal Register Enforceable Consent Agreements. http://www.epa.gov/oppt/chemtest/pubs/4eca.ht ml. Washington, DC. Updated October 1,

2009.

EPA, 2009b. 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.htm l. Washington, DC. Updated September 1,

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EPA, 2010. TSCA Section 5 Premanufacture and Significant New Use Notification Electronic Reporting; Revisions to Notification Regulations; Final rule. Federal Register (75 FR 773- 790), January 6, 2010)Page 53 of 54 EPA, 2011. U.S. EPA, Offi ce of Pollution Prevention and Toxics, Economic and Policy Analysis Branch . Economic Analysis for the Fina l Inventory Update Reporting (IUR) Modifications Rule . June, 2011.

OPM, 2008. Office of Personnel 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.