# Ec onomic Analysis of the Proposed Significant New Use
Rule for Trichloroethylene (TCE)

(EPA DOCKET EPA

- HQ

- OPPT

- 2014

- 0697 ; RIN 2070

- A K05 )

July 30 , 2015

TCE SNUR_NPRM_EA_2015

- 07

- 30 .docx

-- Does not contain TSCA CBI

--

Prepared for: Economic and Policy Analysis Branch Chemistry, Economics, and Sustainable Strategies Division Office of Pollution, Prevention, and Toxics
U.S. Environmental Protection Agency 1200 Pennsylvania Avenue Washington, DC 20460

This P age I ntentionally Left Blank▌ pg

. i 

### Table of Contents

1. Introduction

................................ ................................ ................................ ................................ ... 1

- 1

1.1 Statutory Authority

................................ ................................ ................................ ............... 1

- 1

1.2 Summary of Methodology

................................ ................................ ................................ .... 1

- 1

1.3 Organization of this Report

................................ ................................ ................................ ... 1

- 1

2. Chemical Uses and Manufacturers

................................ ................................ .............................. 2

- 1

2.1 Significant New Uses under the Proposed SNUR

................................ ................................ 2

- 1

2.2 Chemical Uses

................................ ................................ ................................ ....................... 2

- 2

2.2.1 Historical Uses

................................ ................................ ................................ ........ 2

- 2

2.2.2 Ongoing Uses

................................ ................................ ................................ .......... 2

- 2

2.2.3 Consumer Product Information

................................ ................................ ............... 2

- 4

2.3 Potentially Affected Companies

................................ ................................ ........................... 2

- 4

3. Industry Compliance Costs

................................ ................................ ................................ .......... 3

- 1

3.1 Wage Rates

................................ ................................ ................................ ........................... 3

- 2

3.2 Unit Industry Compliance Costs

................................ ................................ ........................... 3

- 3

3.2.1 Rule Familiarization

................................ ................................ ................................ 3

- 3

3.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup

......... 3

- 3

3.2.3 Form Completion and Submission Fee

................................ ................................ ... 3

- 4

3.2.4 Recordkeeping for Companies Choosing to Submit a SNUN

................................ 3

- 6
3.2.5 Recordkeeping for Companies that Do Not Submit a SNUN

................................ . 3

- 6
3.2.6 Customer Notification

................................ ................................ ............................. 3

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3.2.7 Import Certification

................................ ................................ ................................ . 3

- 7

3.2.8 E xport Notification

................................ ................................ ................................ .. 3

- 8

3.2.9 Estimated Number of Annual Export Notifications per Exporter

........................... 3

- 8

3.2.10 Exporter Costs

................................ ................................ ................................ ......... 3

- 9

3.3 Summary of per Submission Costs, by Option

................................ ................................ ... 3

- 11

3.4 Likelihood of SNUN Submission

................................ ................................ ....................... 3

- 12

3.5 Potential for Subsequent Regulatory Actions

................................ ................................ ..... 3

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4. Agency Costs

................................ ................................ ................................ ................................ .. 4

- 1

4.1 Labor Rates for EPA Staff

................................ ................................ ................................ .... 4

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4.2 SNUN Processing Costs

................................ ................................ ................................ ........ 4

- 2

4.3 Export Notification Cost

................................ ................................ ................................ ....... 4

- 5

5. Benefits

................................ ................................ ................................ ................................ ........... 5

- 1

6. Additional Analyses

................................ ................................ ................................ ....................... 6

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6.1 Regulatory Flexibility Act

................................ ................................ ................................ .... 6

- 1

6. 2 Unfunded Mandates Reform Act (UMRA)

................................ ................................ ........... 6

- 1

6.3 Paperwork Reduction Act (PRA)

................................ ................................ .......................... 6

- 1

6.4 Executive Order 13132, Federalism

................................ ................................ ...................... 6

- 2

6.5 Executive Order 12898, Environmental Justice

................................ ................................ .... 6

- 2

6.6 Executive Order 13045, Protection of Children

................................ ................................ .... 6

- 2

6.7 Executive Order 13175, Tribal Governments

................................ ................................ ....... 6

- 3

6.8 Executive Order 13211, Energy Supply, Distribution, or Use

................................ .............. 6

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6.9 Executive Order 13563, Improving Regulation and Regulatory Review

............................. 6

- 3

7. References

................................ ................................ ................................ ................................ ...... 7

- 1▌ pg

. ii 

### Appendix A

– Inflators and Wage Rates
Appendix B

– 2013 TRI Data for TCE▌ pg

. iii 

### List of Tables

Table 2

- 1: 2012 CDR Consumer and Commercial Use Data for TCE

................................ ............... 2

- 2
Table 2

- 2: 2012 CDR Industrial Us e Data for TCE

................................ ................................ ............ 2

- 3
Table 2

- 3: Site Level Production Volumes as Reported in the Non

- Confidential 2012 CDR Database 2

- 4
Table 3

- 1: L oaded Industry Wage Rates, December 2013

................................ ................................ . 3

- 2
Table 3

- 2: Rule Familiarization Burden and Cost for SNUR Submitters

................................ ........... 3

- 3
Table 3

- 3: CD X Registration, CDX Electronic Signature, and Pay.gov Account Setup Burden and Cost
for First

- Time Submitters

................................ ................................ ............................... 3

- 4
Table 3

- 4: Industry Cost Estimate to Complete the SNUN Form

................................ ...................... 3

- 6
Table 3

- 5: Industry Cost Estimate to Complete and Submit the SNUN Form

................................ ... 3

- 6
Table 3

- 6: Annual Per

- Chemical Costs of Recordkeeping Requirement for Companies that Choose not to
Submit a SNUN

................................ ................................ ................................ ............. 3

- 7
Table 3

- 7: Derivation of Total Mailing Cost for 13 Notices

................................ .............................. 3

- 9
Table 3

- 8: TSCA 12(b ) Export Notification Cost per Notification

................................ .................. 3

- 11
Table 3

- 9 : Compliance Options and Associated Costs Incurred by a Firm Due to the Proposed SNUR 3

- 12
Table 4

- 1: Derivation of Loaded Agency Wage Rates, 2013

................................ ............................. 4

- 1
Table 4

- 2: Derivation of Inflation Factors for Agency Extramural Costs

................................ .......... 4

- 2
Table 4

- 3: Agency Costs for SNUN and Other Submission Review and Processing

......................... 4

- 4
Table 4

- 4: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2013$)

.................. 4

- 5▌ pg

. iv 

### Contributors

The EPA analyst responsible for this report was Lynne Blake

- Hedges . Analytical and draft preparation support was provided by Abt Associates Inc. under EPA Contract No. EP

- W

- 08

- 010.▌ pg

. v 

### Executive Summary

Under sect ion 5(a)(2) of the Toxic Substances Control Act (TSCA), the U.S. Environmental Protection Agency (EPA) is proposing a significant new use rule (SNUR) at 40 CFR §721

. 10851 for

t richloroethylene (TCE) (CAS 79

- 01

- 6) by designating manufacturing (including imp ort) or processing of

TCE for any use in a consumer product

, with a proposed exception for use in cleaners and solvent degreasers, film cleaners, hoof polishes, lubricants, mirror edge sealants, and pepper spray.

TCE is a volatile organic compound (VOC) t hat is classified as a human carcinogen (EPA, 2014a). It is a colorless liquid with a pleasant, sweet odor resembling that of chloroform (EPA, 2014 a). EPA is

concerned about the adverse effects of TCE and identified it for risk assessment under EPA's Exist ing Chemicals Management Program. EPA reviewed readily available information on TCE including uses, physical and chemi cal properties, fate, exposure potential, and associated hazards to humans and the

environment. TCE was selected based on its potential h azard (e.g., human carcinogen), and its exposure profile and the risk asse ss ment identified health risks to consumers using solvent degreasers and spray

‐ applied protective coating for arts and crafts (EPA, 2014a).

Persons subject to this proposed SNUR wou ld be required to notify EPA at least 90 days before commencing any significant new use. The required notifications are intended to provide EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit t hat activity before i t

occurs. A firm intending to engage in these activities would be required to submit a Significant New Use Notice (SNUN), incurring an estimated submission cost of approximately $ 8,900 for large businesses per chemical 1 

### , and potentially other minor costs. The required notification would provide EPA with the opportunity to evaluate the intended use and, if necessary, to prevent or limit potentially adverse effects

from chemical use before it occurs.

In addition to any firms that may make a SNUN submission, t he proposed SNUR may also affect firms that do not make a submission. By avoiding a significant new use, a firm can avoid submission and testing costs but may incur other compliance costs. The firm may also incur “hidden” costs; for example, it could foreg o profitable opportunities to use the chemical in an application that would be a significant

new use

.

Costs in this report are estimated at the firm level and reflect the burden of a SNUR on the firms that

make a submission. The potential hidden costs to the firms that do not make a submission are not quantified. Neither t he total number of firms that would submit a SNUN nor the number of firms not making a submission but that are otherwise affected, is known; therefore, costs are not aggregated across

th e affected entities. However, EPA only receives a small number of SNUNs per year.

1 Fo r small businesses, the estimated cost is approximately $ 6,500 to complete and submit a SNUN. See section

3.2.3 for details.▌ pg. 1

- 1 

## 1. Introduction

This report presents the estimated costs of the proposed Significant New Use Rule (SNUR)

t richloroethylene (TCE) (CAS 79

- 01

- 6)

. Under section 5(a)(2) of the Toxi c Substances Control Act (TSCA), EPA is proposing a SNUR at 40 CFR § 721. 10851 by designating manufacturing (including import) or processing of TCE for any use in a consumer product

, with a proposed exception for use in cleaners and solvent degreasers, fil m cleaners, hoof polishes, lubricants, mirror edge sealants, and pepper

spray.

The proposed SNUR would require manufacturers (including importers) or processors of chemicals subject to this SNUR to notify EPA at least 90 days prior to the occurrence of an y significant new use. The required notifications would provide EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs.



### 1.1 Statutory Authority

Section 5(a)(2) of TSCA (15 U.S.C. 2604(a)(2) ) authorizes EPA to determine that a use of a chemical substance is a “significant new use.” EPA must make this determination by rule after considering all relevant factors, including those listed in TSCA section 5(a)(2). Once EPA determines that a use of a chemical substance is a significant new use, TSCA section 5(a)(1)(B) requires persons to submit a SNUN to EPA at least 90 days before manufacturing, importing, or processing the chemical substance for that use (15 U.S.C. 2604(a)(1)(B)).

The general SNUR provisions are found at 40 CFR Part 721, Subpart A.



### 1.2 Summary of Methodology

This analysis quantifies, to the extent possible, the costs of the proposed rule to society by identifying the costs to industry associated with performing the required reporting a nd recordkeeping activities , and the costs to EPA of administering the rule. Industry costs consist of rule familiarization; registration with the Central Data Exchange (CDX) electronic reporting tool; collection, compilation, and submission of required in formation for significant new uses of the subject chemicals; export notification; and recordkeeping. Agency costs include reviewing and processing the data received as a result of the rule. Data sources for this analysis include burden estimates derived fr om previous information collection requests and economic analyses for related rules, compensation data acquired from government publications, and supplementary market research.

In addition to estimated costs, this report qualitatively discusses the benefit s of the proposed rule based on
the value of the information it would provide.



### 1.3 Organization of this Report

The remainder of this report presents EPA’s economic analysis in support of the proposed rule. A description of TCE market information is provided i n Chapter 2 . Chapter 3 contains estimates of the industry costs to comply with the proposed rule, and Chapter 4 shows est imates of the government costs associated with the administration of the proposed rule. Chapter 5 addresses the benefits of the proposed rule. Several additional impact analyses are presented in Chapter 6 , including: small entity impact▌ pg. 1

- 2 

### analysis, as mandated by the Regulatory Flexibility Act (RFA); a burden hour analysis that responds to the requirements of the Paperwork Reduction Act (PRA); an analysis of unfunded man dates that pertains to the Unfunded Mandates Reform Act (UMRA); an analysis of environmental justice implications that addresses the requirements of Executive Order 12898; and an analysis of children’s health pertinent to

Executive Order 13045.

Note that all dollar values in this analysis are reported in 201 3 dollars

.▌ pg. 2

- 1 

## 2. Chemical Uses and Manufacturers

EPA is proposing that manufacturing and processing for any use of TCE in a consumer product

, except
for use in cleaners and solvent degreasers, film cleaners , hoof polishes, lubricants, mirror edge sealants,

and pepper spray , be considered a significant new use. This proposed significant new use rule would apply to the uses that EPA believes are not ongoing at the time of this proposed rule. E PA defines use in a consumer product as the use of a chemical substance or a mixture (including as part of an article) when

sold to or made available to consume rs for their use (40 CFR 7 21 .3) ).

TCE is a volatile organic compound (VOC) that is classified as a human carcino gen (EPA, 2014a) . It is a colorless liquid with a pleasant, sweet odor resembling that of chloroform. EPA is concerned about the

adverse effects of TCE and identified it for a risk assessment under of EPA's Existing Chemicals Management Program. EPA review ed readily available information on TCE including uses, physical and

chemi cal properties, fate, exposure potential, and associated hazards to humans and the environment. TCE was selected based on concerns for its human health hazard (e.g., human carcinogen ), and its exposure profile and the risk asse ss ment identified health risks to consumers using solvent degreasers and

spray

‐ applied protective coating for arts and crafts (EPA, 2014 a ).

However, the Agency believes that if a new consumer use begins or resu mes, it may present a risk that EPA should evaluate under TSCA before the manufacturing or processing for that use begins

. This proposed SNUR would require persons that manufacture (including import) or process any of the chemicals for a significant new us e, consistent with the requirements at 40 CFR 721.25, to notify EPA at least 90 days before commencing such manufacture or process of the chemical substance for a significant

new use.



### 2.1 Significant New Uses under the Proposed SNUR

EPA may promulgate a SNUR for a substance when potential use could result in significant changes in human exposure or environmental release levels and/or that concern exists about the substance’s health or environmental effects (40 CFR §721.170). According to TSCA Section 5(a)(2), the determination that a chemical use qualifies as a significant new use must consider all relevant factors, including:

• The projected volume of manufacturing , importation, and processing of the chemical substance;

• The extent to which a use changes the type or form of exposure of human beings or the environment to a chemical substance;

• The extent to which a use increases the magnitude and duration of exposure of human beings or the environment to a chemical substance; and

• The reasonably anticipated manner an d methods of manufacturing, processing, distribution in commerce, and disposal of a chemical substance.

EPA is proposing to define the significant new use as manufacturing and processing for any use of TCE in a consumer product except for use in cleaners a nd solvent degreasers, film cleaners, hoof polishes, lubricants, mirror edge sealants, and pepper spray

.

A company would be expected to submit a SNUN for TCE for any consumer uses not explicitly exempted from the proposed SNUR prior to initiating a new us e.▌ pg. 2

- 2 

### 2.2 Chemical Uses

2.2.1 Histor ical Uses



### TCE has historically had a wide range of uses drawn from various markets, including intermediate chemicals (for refrigerant and polyvinyl chloride [PVC] manufacture), industrial and commercial solvents, pharmaceutic als, in secticides, fumigant, textiles (processing and flame retardants), adhesives,

and paints (as diluent) (Ash and Ash, 2009). The chemical was first commercial ly used in the 1920s as a metal degreasing solvent and a processing solvent in food production (Doher ty, 2000). Beginning in the

1930s

, TCE was also used dry

- cleaning solvent but it never gained popularity as a primary solvent in dry

cleaning applications . However, it is still used as a pre

- cleaning or spotting agent in dry

- cleaning applications (State Co alition for Remediation of Drycleaners, 2009). The peak of TCE use in the United States was in the 1970 when it was the most popular vapor degreasing solvent in the United States. However, throughout the 1970s and 1980s the chemical became widely regulated by several Federal Agencies , including the FDA, EPA, and OSHA and its use declined ( Doherty, 2000 ).

2.2.2 Ongoing Uses



### As of 2011 the majority of U.S. consumption of TCE is attributable to two specific uses ; 1) use as an intermediate in manufacturing the ref rigerant HFC

- 134a

, a major alternative to CFC

- 12 which was

banned under the Montreal Protocol in 1996

, (83.6 percent of production volume ) and , 2) use as a metals degreasing solvent (14.7 percent of production volume )

. TCE is widely used as a solvent, beca use it works well on fats, grease, waxes, and a large variety of natural and synthetic substances (Doherty, 2000). Few solvents perform as well as TCE in cleaning and degreasing applications, in addition it is noncorrosive, nonflammable and easy to recycle (Doherty, 2000). The remaining 1.7 percent of production volume is attributed to other uses. 2 

### Table 2

- 1 contains the consumer and commercial use data from the 2012 Chemical Data Reporting (CDR) database.

Table 2

- 1 : 2012 CDR Consumer and Commercial Use Data for TCE

Site Product Category Consumer or

Commercial Use Used in Children’s

Productions Percent of

Production Volume

in Use

The Dow Chemical Company

- Freeport,

23 10 N Brasoport Blvd,

Freeport, TX, 77541 Adhesives

and

Sealants Both No 1

2 In order to identify current uses of TCE, EPA reviewed published literature including IHS’ Chemical Economics Handbook (formerly of SRI Consulting); National Institute of Health’s (NIH) Household Product Database ; EPA CPCat ; the Consumer Product Information Database ; the most recent data available from EPA’s Chemical Data Reporting program (CDR) and Tox ic Release Inventory ; general Google.com searches; Material Safety Data Sheets (MSDSs) , Safety Data Sheets (SDSs) and other information from manufacturing company
websites.▌ pg. 2

- 3 Site Product Category Consumer or

Commercial Use Used in Children’s

Productions Percent of

Production Volume

in Use

CBI * NKRA * * NKRA NKRA 100

TRInternational I n c, 600 Stewart Street Suite 1801, Seattle, WA, 98101 NKRA NKRA NKRA 100

* Confidential Business Information

** Reported as Not Know n or Reasonably Ascertainable
Sources: EPA, 201 4 b. US Environmental Protection Agency. Office of Pollution Prevention and Toxics. Downloadable of
the Non

- Confidential Chemical Reporting Data (CDR) Database

, July 201 4



### Table 2

- 2 cont ains a summary of industrial TCE uses from the 2012 Chemical Data Reporting (CDR)

database.

Table 2

- 2 : 2012 CDR Industrial Use Data for TCE

Industrial Sector (Based on NAICS) Industrial Function Type of Proce ssing

Agriculture, Forestry, Fishing
and Hunting Agricultural chemicals
(non

‐ pesticidal) Processing as a reactant

All Other Basic Organic Chemical Manufacturing Intermediates Processing as a reactant

Solvents
(for cleaning or degreasing) Processing

‐ repackaging

NKRA * Processing

‐ repackaging

All Other Chemical Product and Prepa ration Manufacturing NKRA * Use

‐ non

‐ incorporative activities

Solvents
(which become part of product
formulation or mixture) Processing

‐ incorporation into
formulation, mixture, or reaction product

Industrial Gas Manufacturing Functional fluids
(closed sys tems) Processing as a reactant

Primary Metal Manufacturing Solvents
(for cleaning or degreasing) Processing

‐ incorporation into
formulation, mixture, or reaction product

Wholesale and Retail Trade Solvents
(for cleaning or degreasing) Processing as a reac tant

* Reported as Not Know or Reasonably Ascertainable
Sources: EPA, 2014b

. US Environmental Protection Agency. Office of Pollution Prevention and Toxics. Downloadable of
the Non

- Confidential Chemical Reporting Data (CDR) Database , July 2014▌ pg. 2

- 4 2.2.3 Consumer Product Information



### To identify consumer products available in the U.S. market, EPA examined its Chemical/Product Categorical Data (CPcat) database, the National Institutes of Health’s (NIH) Household Products Database, the Consumer Product Information Dat abase, and conducted web searches for TCE

- containing products including searches on online catalogs, and identified specific products that were thought to

contain TCE. EPA then examined product MSDS s /SDSs and company websites to determine if products

were still available and if they still contained TCE (e.g., some may have been reformulated)

. A detailed example of the approach for one of the databases is described below. NIH’s Household Products

Database iden ti fied three companies manufacturing 12 consumer products containing TCE . However, upon further research of the products, EPA confirmed the presence of TCE in only six out of the 12 products listed in the database. These six products were degreaser and arts and crafts aerosol spray products that may be used by consumers at home. The remaining six products have either been

discontinued or reformulated us ing other chemical s ( DHHS, 2012 and EPA, 2014a).



### 2.3 Potentially Affected Companies

The proposed SNUR would require manufacturers, importers, and processors t o notify EPA at least 90 days before commencing the manufacture, import, or processing of any of the subject chemicals for any significant new use. The proposed SNUR may also affect firms that currently do not manufacture, import, or process any of the che micals, but who may be interested in manufacturing, importing, or processing

these chemicals in the future. EPA has not identified any firm manufacturing, importing, or processing TCE for any of the new uses identified in the proposed rule.

However, certai n firms manufacturing, importing, or processing TCE for uses not identified as new uses in the proposed rule may take actions based on the requirements of the rule such as rule familiarization and supplier notification. Based on Toxics Release Inventory (T RI) data a total of 203 sites had TCE releases to the environment in the year 2013 ; 26 sites use d TCE as a formulation component, 26 sites use d TCE in repackaging, 23 sites use d TCE as a manufacturing aid, 3 sites use d TCE as an article component,

and 101 sites use d TCE for ancillary uses, such as degreasing. Appendix B contains a list of the most
recent TRI data available for TCE in 2013. Some of these companies may take actions resulting from requirements in the proposed rule, however, it is not possible to estimate what actions they may

undertake.

Seven companies publicly reported manufacturing or importing TCE at one site in the 2012 CDR database; Dow Chemical, Greenchem, PPG Industries Inc., Shin Etsu, Solvchem Inc., TRInternational,

Inc. , and Vinmar Ov erseas LTD (EPA, 201 4b ). T wo other sites reported data, however their identities

were claimed as confidential business information (CBI) and are not in the public CDR database

. Table

2

- 3 contains site location and production data for TCE as reported in the public CDR database. Some of these companies may take actions resulting from requirements in the proposed rule (see Table 3

- 9 for more information) , however, it is not possible to estimate what actions

, if any, these firms may undertake.

Table 2

- 3 : Site Level Production Volumes as Reported in the Non

- Confidential 2012 CDR Database

Company Site Manufacture d

Volume Import ed

Volume Past

Production

Volume (20 10)▌ pg. 2

- 5 PPG INDUSTRIES

INC PPG INDUSTRIES INC., LAKE
CHARLES PLANT, PO BOX
1000, LAKE CHARLES, LA,

70602 CBI 0 lbs/yr CBI

DOW CHEMICAL

CO The Dow Chemical Company

- Freeport, 2310 N Brasoport Blvd, Freeport, TX, 77541 CBI 0 lbs/yr CBI

VINMAR

OVERSEAS LTD VI NMAR INTERNATIONAL,
LTD., 16800 IMPERIAL
VALLEY DRIVE, HOUSTON,
TX, 77060

- 3159 0 lb/yr 91,359 lb/yr 0 lb/yr

SOLVCHEM INC SOLVENTS & CHEMICALS,
4704 SHANK RD.,
PEARLAND, TX, 77581 109,116 lb/yr 0 lb/yr 35,963 lb/yr

TRINTERNATIONAL

INC TRInternational I n c, 600 Stewart Street Suite 1801, Seattle, WA,

98101 0 lb/yr 209,780 lb/yr 219,590 lb/yr

GREENCHEM

INDUSTRIES LLC Greenchem Industries LLC, 222 Clematis St. Suite 207, West Palm Beach, FL, 33401 0 lb/yr CBI CBI

SHIN ETSU SHINTECH PLAQUEMINE
PLANT, 26270 HI GHWAY 405,
RIVER ROAD SOUTH, PLAQUEMINE, LA, 70764 140,810 lb/yr 0 lb/yr 33,863 lb/yr

CBI CBI CBI CBI CBI

CBI CBI CBI CBI CBI

* Confidential Business Information
Sources: EPA, 2014b

. US Environmental Protection Agency. Office of Pollution Prevention and Toxics. Downloadable of
the Non

- Confidential Chemical Reporting Data (CDR) Database

, July 2014▌ pg. 3

- 1 

## 3. Industry Compliance Costs

The proposed SNUR discussed in this report specifies that any manufacture (including import ) or processing of TCE for a designat ed significant new use would require reporting under section 5(a)(1)(A) of TSCA. Therefore, a firm intending to manufacture (including import) and/or process TCE for a significant new use must submit a SNUN. Alternatively, a firm can decide not to manufact ure, import, and/or process the chemical or articles in such a way that it is not considered a significant new use. The firm, therefore, has two options:

• Option 1: Submit a SNUN. A SNUN indicates to EPA that the firm would like to manufacture, import, and /or process TCE for a significant new use, which, in this case, means manufacturing (including import) or processing of TCE for any use in a consumer product

, with a proposed exception for use in cleaners and solvent degreasers, film cleaners, hoof polishe s, lubricants, mirror edge sealants, and pepper spray. A firm must submit the SNUN to EPA at least 90 days before it plans to commence the manufacture, import, and/or processing of the new use of the substance . T he SNUN provides EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs. If EPA allows the manufacture, import, and/or processing of any

of the chemical substances for a significant new use, then the costs associated with this opt ion are the costs of submitting the SNUN (including a user fee) plus, if there is any export of these chemicals, the export notification costs that result from TSCA Section 12 (b) requirements that are automatically triggered for chemicals regulated under TSCA Section 5 (see Section 3.2.8 for details).

• Option 2: Comply with SNUR limits (not manufacture, import, and/or process a new use of the
chemical ). A firm can avoid engaging in a Significant New Use and submitting a SNUN by not
manufactur ing

, i mporting, and/or processing TCE in a manner such that would be considered new uses. That is, if the firm does not manufacture (including import) or process TCE for any use in a consumer product

, except for use in cleaners and solvent de greasers, film cleaners, hoof polishes, lubricants, mirror edge sealants, and pepper spray , as a significant new use r , then it would meet all applicable SNUR requirements. While this option avoids the costs of submitting a SNUN, it may

entail the “hidden” cost of the foregone profit as a result of not engaging in the commercial activity originally planned, and may involve substituting one of the subject chemicals for another, more costly substance. If the firm elects to produce the chemical for research and development (R&D) purposes only (an exemption for R&D purposes is provided in 40 CFR §721.47), it may have costs associated with R&D recordkeeping. In addition, if the firm exports any existing stockpiles of the chemicals, it

would incur the export notifi cation costs. The firm may also pursue this option temporarily by complying with SNUR restrictions while also pursuing Option 1. Due to the uncertainty related to this option, and EPA’s expectation that affected entities would select Option 1

, the costs of Option 2 are not fully quantified in this report.

The remainder of this chapter estimates the quantified portion of costs associated with the proposed

SNUR. Section 3.1 summarizes the wage rates used in this ch apter. Section 3.2 provides the unit industry compliance costs, including the costs of rule familiarization, registration with the Central Data Exchange (CDX) electronic reporting tool, completing the SNUN form, submission fee, import certification, and export notification. Total costs under each option are presented in Section 3.3

.▌ pg. 3

- 2 

### 3.1 Wage Rates

The proposed rule involves activities that may require efforts by employees in three labor classifications: managerial, technical, and clerical. Costs for each activity are calculated by estimating the labor hours required in each labor catego ry and multiplying those burden hours by the wage rate for the corresponding labor category. This sectio n presents the estimated wage rate in each labor category.

Loaded wage rates for managerial, technical, and clerical personnel are derived by combining data on wages and fringe benefits with estimates of overhead rates, following the methodology described in Wage Rates for Economic Analysis of the Toxics Release Inventory Program (EPA, 2002b). Wage data for each labor category for December 201 3 are provided by the Employer Costs for Employee Compensation (ECEC) Supplemental Tables available on the BLS webs ite (BLS, 201 4 b ). The loaded wage rate is $ 77.77 for managerial labor; $ 67.59 for technical labor; and $ 30.36 for clerical labor. Table 3

- 1 presents the data used to calculate the loaded wage rates for the three labor categories. Appendix A: provides more information on the wage rates and inflat ion factors used in this analysis.

Table 3

- 1 : Loaded Industry Wage Rates, December 201 3

Labor Category Data Source Date Wage Fringe
Benefit Fringe
as %
W age Over

head

% Wage Fringe + O verhead Loaded Wages 1

(a) (b) (c) =(b)/(a) (d) (e)=(c)+ (d)+1 (f)=(a) x (e)

Managerial BLS ECEC , Private Manufacturing

industries

, “Mgt, Business, and

Financial” 3 Dec
'13 $46.21 $2 3.70 51.29% 17% 1.68 $77.77

Professional/

Technical BLS ECEC , Private Manufacturing industries,

“Professional and

related“ 3 Dec
'13 $39.70 $21.14 53.25% 17% 1.70 $67.59

Clerical BLS ECEC , Private Manufacturing industries, “Office
and Administrative

Su pport” 3 Dec
'13 $18.05 $9.24 51.19% 17% 1.68 $30.36

Notes:

1 Wage rates are rounded to the closest pennies; however, unrounded values were used in calculations

. 2 An overhead rate of 17 percent was used based on assumptions in Wage Rates for Economic An alyses of the Toxics Release Inventory Program (EPA, 2002b), and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a).

3 Employer Costs for Employee Compensation Supplementary Tables: December 2006

- June 2014, US Bu reau of Labor Statistics, September 10 , 2014 (BLS, 201 4 b ).▌ pg. 3

- 3 

### 3.2 Unit Industry Compliance Costs

3.2.1 Rule Familiarization



### The proposed rule would require manufacture r s, processors, and importers of the chemicals subject to the proposed rule to become familiar with the SNUR and its various requirements. Rule familiarization is estimated to require 0.55 hours of technical labor and 0.27 hours of managerial labor, as described in the Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009a), which measures the costs of mandatory electronic reporting of SNUNs and other TSCA Section 5 notices.

As shown in Table 3

- 2 , the total labor cost associated with rule familiarization is estimated at $ 57.92

.

Table 3

- 2 : Rule Familiarization Burden and Cost for SNUR Submitters

Reporting

Activity Clerical Labor ( $ 30.36 /hour) Technical Labor ( $ 67.59 /hour) Managerial Labor ( $ 77.77 /hour) Total Labor Cost ( 201 3 $)

Burden Cost B urden Cost Burden Cost Burden Cost

Rule

Familiarization 0.00 $0.00 0.55 $37.17 0.27 $20.74 0.82 $57.92

Note: Costs may not equal labor wage rate multiplied by burden hours as shown, due to rounding. Unrounded values were used

in calculations

. Source s : Wage rates: Table 3

- 1 ; Burden estimates: EPA, 2009a.

3.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup



### The pr oposed SNUR would require submission of a SNUN for any firm that chooses to manufacture, import, a nd/or process a chemical for a significant new use. First

- time submitters of any TSCA section 5 notice (including Premanufacture Notices (PMNs), SNUNs, Test Market Exemption (TME) applications, Low Volume Exemption (LVE) notices, Low Exposure/Low Release ( LoREX) exemption notices, Biotechnology Notices for genetically modified microorganisms, Notices of Commencement of Manufacture or Import (NOCs), and support documents to Section 5 notices) are required to register their company and key users with the CDX reporting tool, deliver a CDX electronic signature to EPA, and establish and use a Pay.gov E

- payment account. 3 

### These activities are only required of first

- time submitters of any Section 5 notice. These activities are estimated to require the following burd en hours

, based on the estimates presented in the Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009a):

• CDX registration

. EPA estimates that companies would spend approximately 0.18 hours per employee to registe r with CDX, and that an average of four technical staff members and one manager

would need to register for each company, totaling approximately 0.92 hours of burden per company.

• CDX electronic signature

. EPA estimates that companies would spend 0.25 hours preparing, submitting, and filing an electronic signature agreement (Authentication of Identity) form to EPA per employee. This burden would apply to four technical staff members and one manager per company, totaling 1.25 hours of burden per company. In ad dition, EPA estimates that a manager would spend

3 Although the proposed rule does not require submitters to establish and use a P ay.gov account, the burden estimates in this analysis are conservative insofar as to include the use of Pay.gov as a required activity.▌ pg. 3

- 4 

### an additional 0.50 hours accessing, preparing, and submitting verification forms (Verification of Authorization) for all authorized submitters to EPA. The total burden incurred by companies submitting and th en verifying electronic signature agreements is 1.75 hours. Note that this burden does not include any additional time required to contact EPA’s CDX help desk to notify a change of submitter status, should one occur. Filing the electronic signature agreeme nt may be done either through mail or electronically. EPA believes the cost of electronic filing to be negligible, and the cost of a paper filing via the US Postal Service to be to be $ 2.62 per company (including five $ 0.46
stamps 4 

### and five $0.06 business envelopes 5 

### ).

• Payment via Pay.gov account

. EPA estimates that one manager per company would spend approximately 0.13 hours setting up a Pay.gov ID account, logging into the system, finding the appropriate form, and filling it out. This burden does not inclu de the time required to click ‘submit’ on the form and wait for payment processing.

As shown in Table 3

- 3

, the cost associated with CDX registration, CDX electronic signature, and Pay.gov account setup is $ 203 , and this cost is on ly incurred by a first

- time submitter

.

Table 3

- 3 : CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup Burden and
Cost for First

- Time Submitters

Reporting Activity Clerical Labor ( $30.36 /hour) Technical Labor ( $67.59 /hour) Managerial Labor ( $77.77 /hour) Total Labor Cost (201 3 $)

Burden Cost Burden Cost Burden Cost Burden Cost
CDX Registration 0.00 $0.00 0.73 $49.56 0.18 $14.26 0.92 $ 64

CDX Electronic Signature 0.00 $0.00 1.00 $67.59 0. 75 $58.33 1.75 $126

Mailing Cost $2. 77

E

- Payment (Pay.gov ID) 0.00 $0.00 0.00 $0.00 0.13 $10.37 0.13 $10

Total 0.00 $0.00 1.73 $117 1.07 $ 83 2.80 $203

Note: Costs may not equal labor wage rate multiplied by burden hours as shown, due to rounding . Unrounded values were used in

calculations

. Source s : Wage rates: see Table 3

- 1 ; Burden estimates: EPA, 2009a.

3.2.3 Form Completion and Submission Fee



### Respondents who choose to submit a SNUN are required to gather and submit infor mation regarding the data elements identified in the applicable SNUN reporting form. The methodology and calculations used in this analysis assume that the employee responsible for collecting, filling out, and submitting the requested information has a rea sonable level of familiarity with the company and knowledge of operations at the site. It is assumed that for most entities these tasks are similar to other employee duties that require familiarity with EPA, State, and other Federal agency requests for che mical information and

4 Price for a stamp was taken from the Stamps.com website . (See Stamps.com , 201 3 )

5 Price for an envelope was determined based on the per unit price of a regular business envelope. See “ Staples® #10, Self

- Sealing Envelopes, 500/Box." Available at: http://www.staples.com/ (Accessed 1 0 / 1 /201 4 ).▌ pg. 3

- 5 

### do not require additional familiarization or training beyond the basic rule familiarization described above. In addition, this analysis focuses on the marginal costs of submitting information for the proposed rule

and not the total co sts for the company to comply with a range of other Federal and State environmental, health, and safety regulations or accounting requirements that rely on this type of information.

Estimates of the costs of completing a SNUN form are based on the costs of completing a PMN submission, since the data requirements are the same and the same form is used for both. The PMN submission costs
came from EPA's 1994 Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications

, which relied on industry estimates of the effort needed to collect and compile all data required for a PMN submission, prepare the form, submit the form and data to EPA, and maintain a file of the submission (EPA, 1994, Table III

- 2 and pages III

- 11,

- 12, and

- 13). The 1994 estimates were based on a survey conducted by the Chemical Manufacturers Association, which became the American Chemistry Council. These burdens include “the time spent reading and becoming familiar with the form, gathering the required information and preparing the report, producing sanitized responses for items claimed as confidential business information, and maintaining a file of the submission” (EPA, 1994. p. III 11

- 13). The burden associated with SNUN submission and preparation has been adjusted to reflect burden reductions resulting from the 2009 final PMN Electronic Reporting (ePMN) Rule that requires the electronic submission of all TSCA section 5 notices. Electronic submission of SNUN forms is expected to remove all clerical bur den and reduce the recordkeeping burden associated with preparing a SNUN (EPA, 2009a). 6 

### In addition, electronic submission is expected to generate and an additional 0.18 hours of technical burden, for the completion of the User Fee Payment Identification N umber and email

address data elements on the electronic SNUN form.

SNUN form completion and electronic submission is estimated to require approximately 74 hours of

technical labor and 18 hours of managerial labor (EPA, 2009a). Tabl e 3

- 4 combines the estimated reporting burden and loaded wage rates for all three labor categories to estimate the per

- SNUN cost of form completion. The labor cost incurred by a SNUN submission for both large and small business

submitters is estimated to be approximately $ 6,400

.

6 The Economic Analysis of the Premanufacture Notification Electronic Reporting F inal Rule (EPA, 2009a) reported a 0.5 hour clerical and a 0.5 hour technical burden associated with recordkeeping in addition to the burden estimates from the 1994 RIA (EPA, 1994, p. III

- 14). These burden estimates (the 0.5 for clerical burden
and 0.5 for technical burden) are based on the recordkeeping burden for polymer exceptions and not the recordkeeping burden associated with PMN submissions.

Therefore, for this analysis, the 0.5 hour for clerical labor and the 0.5 hour for technical labor were removed . It is important to note that for this analysis, clerical burden changes are not applicable because the entire clerical
burden is assumed to be eliminated under the electronic reporting requirements . In summary, we do not include the one hour recordkeepin g burden (0.5 hour for clerical, 0.5 for technical) reported in the ePMN EA.▌ pg. 3

- 6 

### Table 3

- 4 : Industry Cost Estimate to Complete the SNUN Form

Reporting

Activity Clerical Labor ( $30.36 /hour) Technical Labor ( $67.59 /hour) Managerial Labor ( $77.77 /hour) Total Labor
Cos t (201 3 $) 1

Burden Cost Burden Cost Burden Cost Burden Cost

Form Completion 0.00 $0.00 74.20 $5,015 18.00 $1,400 92.2 0 $ 6 , 400

Note: 1. Costs may not equal labor wage rate multiplied by burden hours as shown, due to rounding. 2. Loaded wages include fr inge benefits and overhead. See Table 3

- 1 of this report for derivation. Wage rates presented in this table are rounded; however, unrounded values were used in calculations . For this reason, total labor costs may not equal the

pro duct of rounded values.
3. The estimate of zero clerical burden is taken from the Economic Analysis of the Premanufacture Notice Electronic Reporting Final Rule (EPA, 2009a, page 7)

. 4. Technical and managerial labor burden is from the PMN Amendments RIA ( EPA, 1994, Table III

- 2). An additional eleven minutes (0.18 hours) of technical burden is estimated to complete the User Fee Payment Identification Number and Email Address data elements on the Electronic SNUN form (EPA, 2009a, page 15).
Sources : Burden e stimated: EPA, 1994 and EPA, 2009a; Wage rates: see Table 3

- 1

.



### In addition, each submitting large business must pay a $2,500 per

- SNUN submission fee, and each submitting small business must pay a $100 per

- SNUN submission fee. Table 3

- 5 adds the labor cost and

submission fee to estimate the total cost of a SNUN submission. The total cost of a SNUN submission is estimated to be approximately $ 8, 900 for large business submitters and $ 6, 500 for small busines s submitters.

Table 3

- 5 : Industry Cost Estimate to Complete and Submit the SNUN Form

Reporting Population Labor Cost Submission Fee Total Cost ( 201 3 $)

Large Business Submitters $6, 400 $2,500 $8, 900

Small Business Submitters $6, 400 $100 $6, 500

Source : Labor cost: see Table 3

- 4 ; Submission fees: EPA, 1994

3.2.4 Recordkeeping for Companies Choosing to Submit a SNUN



### Companies submitting a SNUN must, under 40 CFR §721.4 0, keep records of the information contained in the SNUN. Some EPA reports have assumed that SNUN recordkeeping hours would be five percent of SNUN submission hours, or about five to six hours. For this report, the SNUN recordkeeping hours were

included in the SNUN submission hours (see Section 3.2.3) and the SNUN recordkeeping costs under 40 CFR §721.40 were not separately estimated.

3.2.5 Recordkeeping for Companies t hat Do Not Submit a SNUN



### If a firm that manufactures, imports, or processes a substance subject to the proposed SNUR chooses not to submit a SNUN, they must keep records that document compliance with SNUR conditions for avoiding a Significant New Use. Such recordkeeping requirements essentially involve copying and filing relevant records, including those related to category of use. Records must be maintained for five years from the date of their creation (40 CFR 721.40). For firms that choose to not submit a SNUN, costs for compliance▌ pg. 3

- 7 

### with the recordkeeping requirements are estimated to be five perce nt of the reporting burden for reporting information for a specific section of the SNUN form and are performed by clerical staff (EPA, 2005b, pages 10 and 14). EPA used the per

- activity burden for reporting, human exposure, category of use and

releases to the environment presented in the Information Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules for Existing Chemicals (Renewal) (EPA, 2005b, page 12). Any clerical

burden associated with these activities was removed to reflect the burden reduction associated with electronic submissions (EPA, 2009a).

The recordkeeping burden for a company that does not submit a SNUN is estimated at 0.15 hours and $ 10.14 and is derived in Table 3

- 6

.

Table 3

- 6 : Annual Per

- Chemical Costs of Recordkeeping Requirement for Companies that Choose
not to Submit a SNUN

Reporting Activity P er Activity

Burden (Hours) % of Reporting

Burden
Attributed to Recordkeeping Total Labor Cost ( 2013 $)

Burden Cost

Category of Use 1 3 5% 0.15 $10.14

Notes: For the category of use reporting activity, the burden is associated with technical labor. See Table 3

- 1 for the technical
wage rate.
Source :

1 US EPA, 2005b Office of Pollution Prevention and Toxics Information Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules for Existing Chemicals (Renewal)

, page 13.

3.2.6 Customer Notification



### Manufacturers, processors, and importers of chemicals subject to SNURs must notify recipients of such chemicals of the SNUR or verify that knowledge of the SNUR has been otherwise acquired by recipients, or that the recipients are unable to engage in significant new uses. Since it is not expected that all su ch

entities would have complete knowledge of all uses of any products subject to a SNUR, and because filing a SNUN could require significantly more burden, it is assumed that manufacturers, processors, and importers would most often choose to notify their customers of SNUR regulatory activities. As this notification may be accomp lished by simply annotating an SDS, EPA estimates the associated burden to be about one hour of a technical employee's time or $ 67.59 per manufacturer, processor, or importer per

ch emical.

3.2.7 Import Certification



### In general, promulgation of a SNUR triggers a TSCA Section 13 import certification requirement and the corresponding regulations at 19 CFR §12.118 to 12.127 and 19 CFR §127.28 for all imports of the

relevant chemical substance s. Thus, any U.S. manufacturer, importer, or processor receiving an imported shipment of chemicals subject to the proposed SNUR would have to certify that all chemical substances in the shipment either comply with all applicable rules and orders under TSCA or that all chemical▌ pg. 3

- 8 

### substances in the shipment are not subject to TSCA. 7 

### The statement must be on or attached to a commercial invoice or entry document belonging to the imported shipment.

Import certification is fulfilled by checking a box on an invoice or entry document and EPA assumes that it generally imposes no additional burden or cost on the importer. Any potential burden associated with submitter’s familiarization with this requirement is assumed to be included in the more general SNUR

familiarizat ion burden discussed above.

3.2.8 Export Notification



### Under Section 12(b) of TSCA, exporters must notify EPA if they export or intend to export a chemical subject to various TSCA sections (40 CFR §707.60 through 75). For TSCA 5(a)(2) (the section under

which EPA promulgates significant new use rules) and certain other TSCA sections, this is a one

- time notification requirement 8 

### per destination country for each exporter of a chemical substance. After receiving a notification from a firm, EPA notifies the importing country and the United States State Department (40 CFR §707.70). To calculate the burden associated with making a single export notification, EPA first estimated the average annual number of export notifications made by an exporter.

EPA then derived the an nual and per notification burden associated with preparing and submitting an export notification.

EPA estimated the average burden associated with making a single notification, but did not estimate either the total number of exporters of a SNUR chemical o r the number of notifications per SNUR chemical. This is because the SNURs apply to a variety of different chemicals with a variety of unrelated uses, manufacture r s, and processors, making it impractical within the resources available for this report to

as sess the potential number of exporters and importing countries per chemical.

Most underlying data in this section come from t he ( 2012 TSCA Section 12(b) ICR), ICR No.: 0795. 1 4

OMB Control Number 2070

- 0030 [Information Collection Request for] Notification of Chemical Exports

- TSCA Section 12(b) Supporting Statement for Request for OMB Review under the Paperwork

Reduction Act (EPA, 20 12 b )

.

3.2.9 Estimated Number of Annual Export Notifications per Exporter



### EPA’s 20 12 TSCA Section 12(b) ICR estimated that the aver age exporter making notifications would

make 1 3 notifications per year

. 9 

### This includes notifications resulting from SNURs and notifications

7 The exact statements are as follows: For imports of chemical substances subject to TSCA, “I certify that all chemical substances in this shipment comply with all applicable rule s or orders under TSCA and that I am not offering a chemical substance for entry in violation of TSCA or any applicable rule or order under TSCA.” For imports of chemical substances not subject to TSCA (e.g., pesticides), “I certify that all chemicals in t his shipment are not subject to TSCA.” ( 40 CFR 707.20 )

8 On November 14, 2006, EPA revised the export notification requirement for chemicals subject to TSCA §5(a)(2), 5(b), 5(e)(1) and 5(e)(2) from an annual to a one

- time requirement per destination count ry for each exporter (November 14, 2006, 71 FR 66234).

9 EPA calculated the average number of export notifications per exporter in the 20 12 TSCA Section 12(b) ICR (EPA, 2012b) by dividing the estimated number of submitted notifications ( 3, 090 ) by the est imated number of exporters ( 240).▌ pg. 3

- 9 

### resulting from other TSCA activities. Therefore, it is likely that an exporter would make less than 1 3

notification s per year as a result of this proposed SNUR. A notification is typically no more than one page per chemical/country combination, and one notification mailing often includes multiple chemicals and/or

destination countries. 10



### The percent of notifications re sulting from SNURs in general is unknown, and it is also unknown how many notifications may result from this rulemaking, as not all manufacturers may choose to export a chemical, or they may make several notifications for a single chemical.

3.2.10 Exporter Costs



### The 20 12 TSCA Section 12(b) ICR (EPA, 20 12 b , page 11, Table 3), estimated the annual export notification cost for an exporter under the one

- time export notification requirement. These costs include the cost to the exporter of compiling a list of their pro ducts that are subject to TSCA Section 12(b) requirements, writing or revising an export notification letter to EPA, checking the outgoing shipments, and sending the notification letters with the associated shipping costs

.

The per

- notification cost was cal culated based on the average burden per firm. Exporters who make a larger number of notifications per year may benefit from economies of scale and have lower costs per notification; conversely firms making fewer notifications may have a higher cost per not ification.

Estimated Submission (Mailing) Costs. Regulated companies would incur mailing costs for export notifications delivered to EPA. Notifications are assumed shipped via the U.S. Postal Service (U

. S

. PS) as
first

- cla ss registered mail with a return r eceipt ( Stamps.com

, 2013 ). The estimated per

- shipment and annual mailing costs incurred by individual submitters are detailed in Table 3

- 7

.

Table 3

- 7 : Derivation of To tal Mailing Cost for 1 3 Notices

Postal Service Cost
Registered mail, regular, with $0 declared value $ 11.20

Return receipt, requested at time of mailing (receive by mail) $ 2.55

Postage, regular First Class, up to 1 ounce $0. 46

Cost per export noti ce - Subtotal $ 14.21

× 1 3

Total Mailing Cost for 1 3 Notices $ 184.73

Source: Mailing rates are from the Stamps.com web site ( http://www.stamps.com/whitepapers/2013

- usps

- postage

- rate

increase

- guide.pdf ). The assumption on the mailing method is based o n the Economic Analysis of the Proposed Change to TSCA Section 12(b) Export Notification Requirements, November 2005 (EPA, 2005a), as clarified in a later SNUR economic analysis (EPA, 2007c, Table 8).

10 Based on review by an EPA economist of notifications received under TSCA Sections 4, 5 and 6 over approximately three weeks in early 2010.▌ pg. 3

- 10 

### Compile and Maintain the List of Products. Since TSC A §12(b) information collection activity has been in place for twenty years, most respondents would have already developed a list of their products subject to TSCA §12(b) export notification. Respondents need only check for new regulations promulgated and any new products exported by the company. Updating the list is estimated to take an average of one hour of technical time, which may also include some proportion of legal time (EPA, 20 12 b ) . The total burden can vary from two hours per year up to two hou rs per month, depending on the number of products exported by the company and the number of their products subject to TSCA §12(b) (EPA, 20 12 b ).

The number of submitters per year who report under TSCA §12(b) has varied over time, rising from
around 160 in 1991 to over 460 in 2000, and declining since. In the most recent TSCA §12(b) ICR, EPA

estimated that there would be approximately 240 submitters per year in near

- future years (EPA, 20 12 b ).
Of these 240 submitters, EPA estimated that 160 companies were near th e lower burden estimate of two hours per year, and 80 companies were near the upper estimate of 24 hours per year. Compiling the list for all respondents was therefore estimated to take 2, 240 hours (2 hours x 160 firms plus 24 hours x 80 firms), or an aver age of about 9.3 hours of technical time per firm per year for 1 3 notifications per year (EPA, 20 12 b ).

Write or Revise Export Notification. Companies that export chemicals subject to TSCA §12(b) reporting must prepare an export notification to send to EPA when export shipments are made. Time for initial preparation of the export notice may vary depending on whether the company has prior experience with this requirement. This step is estimated to take an average of one hour of technical time (which may also include some proportion of legal time) per firm per year for 1 3 notifications per year (EPA, 20 12 b ).

Check Orders and Send Notifications. Companies that export chemicals subject to TSCA §12(b) reporting must check outgoing shipments against the list of the ir products described above. A form letter notifying EPA and providing the required data must be printed and mailed within the required time period. This process is estimated to take an average one half hour of clerical time per export notification

or 6.5 hours for 1 3 notifications (EPA, 20 12 b ).

Total Burden and Cost per Notification

. The burdens and associated costs for each notification activity are provided in Table 3

- 8 . EPA estimates that the burden associated with making one notification is approximately 1. 3 hours and $ 83

.▌ pg. 3

- 11 

### Table 3

- 8 : TSCA 12(b) Export Notification Cost per Notification

Notification Activity Technical Labor Clerical Labor Total
Wage

Rate ($/hr) Burden Cost Wage

Rate ($/hr) Burden Cost Burden Cost

Compile list $67.59 9.3 $629

-- -- -- 9.3 $629

Write letter $67.59 1 .0 $68

-- -- -- 1 .0 $68

Check order and send

notice -- -- -- $30.36 6 .5 $ 197 6 .5 $ 197

Mailing cost 1

-- -- -- -- -- -- -- $ 185

Total per av erage facility 2 -- 10.3 $696

-- 6. 5 $ 197 16. 8 $1,078

Total per Notification

-- 0. 8 $ 53. 55

-- 0.5 $15. 18 1. 3 $ 8 2.94

Notes: Costs may not equal labor wage rate multiplied by burden hours as shown due to rounding. Unrounded values were used in

calculations

. 1 Mailing costs reflect 2013 U

. S

. PS rates and can be found in Table 3

- 7

. 2 An average facility submitting notifications is assumed to submit 1 3 export notifications per year.
Source: Appendix A o f this report derives technical and clerical hourly labor costs. Burden hour estimates are from ICR No.:
0795. 1 4 ICR for Notification of Chemical Exports

- TSCA Section 12(b) Supporting Statement for Request for OMB Review under the Paperwork Reduction Act (EPA, 20 12 b

, p.10)

.



### 3.3 Summary of per Submission Costs, by Option

The number of firms affected that do not make submissions to EPA (see Option 2 in Table 3

- 9 ) is not known; therefore, costs are not aggregated across the affected entities. The following table summarizes the per

- company per

- chemical costs to comply with the proposed rule amendment, as described in more

detail in section 3.2 above.▌ pg. 3

- 12 

### Table 3

- 9 : Compliance Options and Associated Costs Incurred by a Firm Due to the Proposed
SNUR
Option 1 Costs Quantified Costs per Chemical ( 201 3 $) 2

1. Electronic submission of a Significant New Use Notice (SNUN), indicating to EPA that
the firm woul d like to manufacture, import, or process the chemical for a Significant New Use as
defined in the SNUR. Costs of submitting a SNUN, including rule familiarization, CDX registration (for companies

that are first

- time submitters), form completion, user fee, export notification, and any test

costs. $ 5 8 rule familiarization cost; $ 8, 900 submission cost (including SNUN recordkeeping under 40 CFR §721.40 and fe e $2,500 for large businesses). EPA usually receives well under ten SNUNs per year 3

. Import certificat ion costs are approximately $ 1 7 per transaction

. Export
notifications costs are estimated at $ 83 per notification; total cost per company would vary. First time submitters would incur $ 203 for CDX registration and associated activities. Companies

manufactu ring, importing, or processing a chemical currently used in commerce in the
United States would incur a cost $ 6 8 for notifying consumers of SNUR regulatory

activities.

2. Manufacture, import, or process in a way that avoids a Significant New

Use. Cost of the profit foregone as a result of not engaging in the commercial activity originally planned (opportunity costs), recordkeeping

, and export

notification costs. Opportunity costs are not quantified. Other costs
include rule familiarizati on ($ 5 8 ), recordk eeping ( $ 10 ), import certification ($ 17 per transaction), export notification ($ 83 per notification), and customer notification ( $ 6 8 ) may appl y.

Notes:

1 Firms may be subject to both options at once since submission of a SNUN results in profits foregone as a result of not manufacturing, importing, or processing the chemical.

2 Quantified costs are attributable to the SNUR only if a firm would not otherwise follow the specified practices. Costs are

detailed in Section 3.2

. 3 See Section 3.4 for more details.



### 3.4 Likelihood of SNUN Submission

This analysis assumes that no entities are expected to submit a SNUN. EPA has, over the years, promulgated SNURs that cover a total of more than 1, 000 chemicals. In response, the Agency receives only a handful of SNUNs per year. For example, the number of SNUNs received was six in Federal fiscal year (FY) 2007, eight in FY2008, seven in FY2009 , two in FY2010, and ten in FY2011

. 11 

### In addition, as

discu ssed in Chapter 2

, the no ongoing commercial uses of TCE are subject to this proposed rule

, therefore this suggests that it is unlikely a firm would submit a SNUN

.



### 3.5 Potential for Subsequent Regulatory Actions

The Agency recogn izes that if submission of a SNUN does result from a SNUR, the Agency may take additional regulatory actions under TSCA. These additional regulatory actions might be necessary to

11 Values based on US EPA’s PMN Gold (V1.1) record keeping system as of Septembe r 1, 2011 (EPA, 2011a)

.▌ pg. 3

- 13 

### further evaluate an intended new use and associated activities, or to prohibi t or limit that activity before it occurs to prevent unreasonable risk of injury to human health or the environment. It is not known what specific subsequent regulatory actions, if any, the Agency may determine are necessary after reviewing a SNUN. Any suc h actions are highly dependent on the circumstances surrounding the individual SNUN (e.g., available information and scientific understanding about the chemical and its risks at the time the SNUN is being reviewed).

Should the Agency’s review of the SNUN result in further regulatory actions, the Agency would initiate and follow the appropriate procedures for taking those actions. Included in those procedures would be an

assessment of the costs and benefits of those actions.▌ pg. 4

- 1 

## 4. Agency Costs

As described in t he following sections, EPA’s costs to review and process SNUN submissions are
assumed to be the same as EPA costs to review PMNs.



### 4.1 Labor Rates for EPA Staff

Agency labor costs are calculated based on annual Federal salaries for the Washington

- Baltimore ar ea published by the Office of Personnel Management effective January 201 3 (OPM, 20 1 3 ). EPA assumes that, on average, a federal GS

- 13, Step 5 full

- time equivalent (FTE) would conduct its collection and administrative activities under the proposed rule. 12 

### The average salary for a GS

- 13 Step 5 employee was $100,904 in 2013 without fringe benefits and overhead costs. In order to derive the fully loaded salary, EPA multiplied the annual salary by an assumed loading factor of 1.6 to reflect federal fringe benefits and

overhead (EPA, 2009c) , which results in a fully loaded annual salary of $161,446 (see Table 4

- 1 ). Dividing the fully loaded annual salary by 2,080 hours (i.e., the number of hours in a work year) yields an

estimated hourly FT E wage rate of $77.62.

Fully loaded costs for Agency labor are shown in Table 4

- 1

.

Table 4

- 1 : Derivation of Loaded Agency Wage Rates, 2013

Labor Category Data Source Date Wage Fringe
Benefit Fringes

as %

wage Overhead

as %

wage Fringe +

overhead

factor Loaded Wages

(a) (b) (c)=(b)/(a) (d) (e)=(c)+(d)+1 (f)=(a)*(e)

EPA staff

FTE Annual Federal staff cost: OPM Washington

- Baltimore

Northern Virginia, DC

- MD

PA

- VA

- WV, area, GS

- 13 Step 5 pay rates, with 60%
overhead 1 Jan
201 3 $100,904 (annual)

-- Included
in 60%

overhead 60% 2 1.60 $161,446 (annual)

$48.51 (hourly) $77.62 (hourly)

Notes:

1 The Agency salary is the unloaded federal GS

- 13 Step 5 salary ($100,904 for 2013 ), from the OPM salary table for the Washington

- Baltimore

- Northern Virginia Locality Pay Area (OPM, 201 3 ). Hourly rates are based on annual salary divided by 2,080 hours.

2 The 60% fringes

- and

- overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (EPA, 2009c).

12 The GS

- 13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007) ( EPA, 2007a ), which covers PMN SNURs. Use of this grade level follows the approach introduced in EPA , 2007b . That report represented a change from
an earlier PMN SN UR economic analysis ( EPA, 2003 ), which used an average of GS

- 12 Step 1 and GS

- 12 Step
10 salaries.▌ pg. 4

- 2 

### 4.2 SNUN Processing Costs

The list of review steps, estimates of extramural costs, and the percent of chemicals requiring a particular review step are derived from the costs for processing PMN submissions in Table V II

- 1 of a 1994 EPA report, Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications (EPA, 1994 ). The Agency burden associated with processing a PMN has been adjusted to reflect burden reductions resulting from the 2009 final PMN Electronic Reporting (ePMN) Rule that requires the electronic submission of all TSCA section 5 notices. Electronic submission of SNUN forms is expected to reduce Agency burden by 16.5 percent (EPA, 2009b, p.28 ).

For each review step, th e “EPA staff” cost is calculated by multiplying the number of FTEs (in the first column) by the fully loaded hourly salary . This shows EPA staff cost for chemicals requiring the selected review step.

The Extramural Cost column shows costs for contractor s upport and other outside purchases for chemicals requiring the selected review step , and is inflated from 1993 prices using the Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) data (BLS, 201 4c ). The ECI for total compensation (not seasonally a djusted) of private industry professional and related workers (Series ID CIU2010000120000I)

is used be cause it is the only series with continuous data since 1985, and that includes professional and technical labor, which perform the majority of Agency extr amural activities

. Table 4

- 2 contains the derivation of inflation factors for Agency extramural costs.

Table 4

- 2 : Derivation of Inflation Factors for Agency Extramural Costs

Item Infl ation Index Source 1 Starting

year Index
for starting

year (a) Index for

December
2013

(b) Inflation
factor (b)/(a) 2

Agency Extramural
costs Professional
and Related Private Industry BLS ECI, Total comp, Private industry, Professional and

related , 4 th Q [BLS, 201 4 c ] 3 1993 67.0 120.5 1.80

Notes:

1 In 2006, Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) series “were rebased to December 2005 = 100 from June 1989 = 100.” The change is reflected in the indices in this table and explained on t he BLS website, Employment Cost Index News Release Text: Employment Cost Index, March 2006 (BLS, 2006b). The Consumer Price Index (CPI) was

not rebased.

2 Inflation factors are rounded ; unrounded values were used in calculations

. 3 Beginning with the re port Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: EPA

Docket OPPT

- 2009

- 0922 (EPA 2011b), we began to use the not

- seasonally adjusted CIU2010000120000I for private industry Professional, and Related workers, instead o f SA CIS2010000W00000I for private industry white collar workers because BLS

retired the “white

- collar” series.
Source: (BLS 201 4 c ) Bureau of Labor Statistics. Employment Cost Index

– Total Compensation: Professional and R elated Private Industry, Not Seaso nally Adjusted. (Series ID: CIU2010000120000I (B)), extracted October 2 , 201 4

. http:/data.bls.gov/cgi

- bin/srgate. (BLS 201 4 c ).



### The Percent of Cases column in Table 4

- 3 is a weighting factor applied to reflect the fact that not a ll chemicals require each review step. For example, in the PMN process, all chemicals require▌ pg. 4

- 3 

### Administrative Prescreening, but not all chemicals require the intensive scrutiny of “Standard Review.” The three types of submissions resulting from a SNUR may have weighting factors that differ from each other and from the weighting factors for PMNs. Changes in weighting factors could cause actual review costs to be higher or lower than calculated here. For example, some SNUNs require little review because they are determined to be “invalid”

– i.e. not required in the first place. However, often a SNUN may take more Agency time than a typical PMN because of factors such as the need to retrieve old PMN records from archives, and the likelihood that more data requi ring EPA review are submitted with a SNUN than would be submitted on average with a PMN. Resources were not available to update the review hours to reflect the current review process or to tailor the cost estimates to SNUNs. Therefore, for this analysis, t he review steps and weighting factors are assumed to be the same as those derived in 1994 for PMNs.

Values in t he Weighted Cost column is calculated by multiplying the un

- weight ed c osts (EPA staff cost plus extramural costs) by the percentage of cases requ iring this review step. Weighted costs are then multiplied by the burden reduction of 16.5 percent to account for burden savings generated electronic submission. This calculation yields total Agency costs of approximately $ 5,100 per SNUN, for

submission re view and processing, as shown in Table 4

- 3

.Agency Costs ▌ pg

. 4

- 4 

### Table 4

- 3 : Agency Costs for SNUN and Other Submission Review and Processing

Review Steps EPA S taff (FTE) Cost Extramural Cost 2 Unweighted
C ost % of
Cases Weighted
Cost 3 Burden Reduction 4 Weighted Cost with
Burden Reduction FTE
F raction Cost per
FTE 1 FTE Total ( 201 3 $ ) 1993 $ 201 3 $

(a) (b) (c)=(a)*(b) (d) (e) (f)=(c)+(e) (g) (h)=(f)*(g) (i) (j)=(h)*(1

- (i))

Pre

- notice consultation 0.0 024 $161,446 $387 $4.00 $7.19 $395 41% $162 0.165 $135 Administrative prescreen/ notice receipt/user fee 0.0024 $161,446 $387 $92.00 $165 $553 100% $553 0.165 $462

CRSS (Chemical Review and Search Strategy) 0.0025 $161,446 $404 $268 $482 $886 100% $886 0 .165 $739

SAT (Structure Activity Team) 0.0006 $161,446 $96.87 $14.00 $25.18 $122 100% $122 0.165 $102 Engineering/Exposure 0.0015 $161,446 $242 $56.00 $101 $343 100% $343 0.165 $286 Exposure/Fate 0.0008 $161,446 $129 $0.00 $0.00 $129 100% $129 0.165 $1 08

Focus 0.0009 $161,446 $145 $23.00 $41.37 $187 100% $187 0.165 $156

Standard Review Functions 0.0219 $161,446 $3,536 $511 $919 $4,455 29% $1,292 0.165 $1,079 Division Directors Meeting 0.0129 $161,446 $2,083 $113 $203 $2,286 15% $343 0.165 $286

Order Development/Negotiation
Review 0.0171 $161,446 $2,761 $22.00 $39.57 $2,800 3% $84.01 0.165 $70.15

Post Order Data Review 0.0886 $161,446 $14,304 $0.00 $0.00 $14,304 3% $429 0.165 $358

Order Modification 0.2167 $161,446 $34,985 $0.00 $0.00 $34,985 3% $1, 050 0.165 $876

New Chemical SNUR Development 0.0277 $161,446 $4,472 $85.00 $153 $4,625 7% $324 0.165 $270

Notices of Commencement 0.0012 $161,446 $194 $40.00 $71.94 $266 31% $82.36 0.165 $68.77 FOIA (Freedom of Information Act) Requests 0.0333 $161,446 $5,376 $287.00 $516 $5,892 1% $58.92 0.165 $49.20

CBI (Confidential Business Information) Substantiation 0.0004 $161,446 $64.58 $3.00 $5.40 $69.97 100% $69.97 0.165 $58.43

TOTAL $ 6,100 $ 5,100

Notes:

1 GS

- 13 Step 5 salaries loaded with benefit s and overhead. See Table 4

- 1 for derivation.

2 Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated from 1993 prices using Table 4

- 2

. 3 Weighted costs were calculated using unrounded unit cost estimates.

4 Electronic submission is expected to generate a cost savings of 16.5% to the Agency (EPA 2009a, p. 28). Sources: FTEs per review step, 1993 extramural costs, and percent of cases are from EPA, 1994 Table VII

- 1 ; GS

- 13 salaries are from OPM, 2013

.▌ pg. 4

- 5 

### 4.3 Export Notification Cost

Under TSCA Section 12(b), exporters must notify EPA if they intend to export chemicals subject to SNURs, as described in Section 3.2.8 . The Agency burden and cost due to TSCA §12(b) export notification result from three tasks. In the first task, EPA receives export notifications from companies that intend to export one of the chemicals subject to TSCA §12(b) (EPA, 20 12 b ) . In the second task, EPA staff prepares separate notification letters that are subsequently reviewed and delivered to importing countries, their embassies, or representatives, and to the importing country’s U

. S

. embassies (EPA,

20 12 b ). (See Table 3

- 7 for the cost of mailing one notification). The third task is comprised of EPA staff responses to public inquiries and other TSCA 12(b) activities. The work of responding to non

- routine requests for information and clarification from i ndustry and importing countries, and of handling other tasks associated with the TSCA §12(b) program, was estimated to require roughly 400 hours per year (EPA, 20 12 b ). Since the current rulemaking covers only a very small percent of the chemicals subject t o TSCA 12(b) reporting, a very small percent of such activity would be attributable to the current rulemaking.

Because it is unknown how many, if any, notifications EPA would receive or send as a result of the current rulemaking, the costs to the Agency a re presented per activity. The estimated burden for the first two Agency activities is provided in Table 4

- 4 . To estimate the Agency cost, hourly burdens are multiplied by the loaded wage rate of a GS

- 13, Step 5, which is derive d in Table 4

- 1

.

Table 4

- 4 : TSCA 12(b) Export Notification Cost: Agency Burden per Activity ( 201 3 $)

Agency Activity Hours per Activity FTE per Activity 1 Loaded Wages Mailing
Cost Total Agency Cost per Activity GS

- 13, Step 5 FTE

(a) (b) = (a)/2,080 (c) (d) (e) = ((b)*(c))+(d)

Process an incoming

notification from an exporting company 0.1 0.00005 $161,446 $0.00 $7.76

Prepare and mail a
notification to an importing country 0.5 0.00024 $161,446 $ 14.21 $ 53.02

Notes:

1 The burden associated with an Agency activity is the burden for the Agency to process one incoming notification, or to prepare and mail an outgoing notification

. Source: Appendix A of this report derives Agency labor costs. Mailing costs are from Table 3

- 7 of this report. Other

burden estimates are from ICR No.: 0795. 14 [Information Collection Request for] Notification of Chemical Exports

- TSCA Section 12(b) Supporting Statement for Request for OMB Review under the Paperwork Reduction Act (EPA 20 12 b ), adjusted for inflation.▌ pg. 5

- 1 

## 5. Benefits

A SNUN submission provides EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity b efore it occurs. It allows the Agency to take immediate action to mitigate an activity that the Agency deems harmful to the environment or human health. The proposed SNUR allows EPA to evaluate the use of, or exposure to these chemical and allow the Agency to take preventive action to limit or prohibit any Significant New Use.

EPA is concerned about the adverse effects of TCE and identified it for a risk assessment as part of EPA's Existing Chemicals Management Program. TCE exposure has been associated wit h several types of cancer in humans including kidney, liver, and lymphatic system cancer (EPA, 20 14a ). Acute and chronic

in ha lation exposure can affect the liver, kidney, nervous system, immune system, and reproductive system and can cause developmental ef fects. (EPA, 20 14a ). EPA’s risk assessment identified cancer risk

concerns and short

‐ term and long

‐ term non

‐ cancer risks for workers and occupational bystanders at small commercial degreasing facilities and dry

- cleaning facilities that use TCE

‐ based spotting agents. EPA also

identified short

‐ term non

‐ cancer risks for consumers and residen tial bystanders from the use of TCE

‐ containing solvent degreasers and spray

‐ applied protective coatings. The main route of exposure for TCE
is believed to be inhalation for the uses identified , but highly volatile compounds such

, as TCE

, may also

be absorb ed through the skin. However, based on the physical

‐ chemical properties of TCE and its

exposure scenarios EPA believes that inhalation is the main exposure pathway (EPA, 2014 a )

.

While the proposed SNUR would not address the risk to consumers from TCE expos ure from cleaners and solvent degreasers, film cleaners, hoof polishes, lubricants, mirror edge sealants, and pepper spray , the Agency believes that if a new consumer use begins or resumes, it may present a risk to consumers and residential bystanders

. The proposed SNUR allows EPA to evaluate the use of, or exposure to the chemical and allow the Agency to take preventive action to limit or prohibit any Significant New Use. EPA also expects that the proposed rule may restrict future uses or exposure to the c hemical, as a company may choose to modify planned uses in such a way that does not trigger a SNUR, as opposed to submitting a SNUN. Therefore, the proposed SNUR may limit future exposure to the chemical.▌ pg. 6

- 1 

## 6. Additional Analyses

6.1 Regulatory Flexibility Act

Pu rsuant to section 605(b) of the Regulatory Flexibility Act (RFA) (5 U.S.C. 601 et seq .), the Agency hereby certifies that promulgation of this SNUR would not have a significant adverse economic impact on

a substantial number of small entities. The rational e supporting this conclusion is as follows. The requirement to submit a SNUN applies to any person (including small or large entities) who intends to engage in any activity described in the rule as a significant new use. Where a use is new, by definition n o small or large entities presently eng age in such activities. Although some small entities may decide to manufacture or process a substance for the new use after the SNUR is promulgated, EPA receives very few SNUNs, and few of those are submitted by small entities. In response to the promulgation of SNURs covering over 1

, 000 chemical substances, the Agency receives only a handful of SNUNs per year. For example, the number of SNUNs was four in Federal fiscal year 2005, eight in FY2006, six in FY2007, eight in FY2008, seven in FY2009, two in 2010, and ten in 2011 (EPA, 2012 a ), for an average of 6 per year from all SNURs. EPA has no reason to believe that this SNUR would alter the pattern of SNUN submissions that EPA has historically seen. In addition, the es timated reporting cost for submission of a SNUN is minimal regardless of the size of the firm, averaging about $8, 7 00 including SNUN recordkeeping and reporting costs. The Agency currently offers some relief to certain small businesses

with sales (includin g those of subsidiary/parent companies) of less than $40 million per year by reducing

the SNUN submission fee from $2,500 to $100. This lower fee reduces the cost of submitting a SNUN to about $ 6, 3 00 for smaller firms. During the six year period from 2005

- 2010, only three submitters self

identified as small in their SNUN submission 13 

### (EPA, 2012 a ). EPA believes the cost of submitting a

SNUN is relatively small compared the cost of developing and marketing a chemical new to a firm and that the requirement to s ubmit a SNUN generally does not have a signific ant economic impact.

EPA believes that the potential economic impact of complying with a SNUR is not expected to be significant or adversely affect a substantial number of small entities

.



### 6.2 Unfunded Mandates Re form Act (UMRA)

The proposed rule does not impose any enforceable duty, contain any unfunded mandate, or otherwise have any effect on small governments because none of the current producers of the subject chemicals are governments. Additionally, it is not expected that any governments would initiate production of these

chemicals.



### 6.3 Paperwork Reduction Act (PRA)

According to the Paperwork Reduction Act (PRA), 44 U.S.C. 3501 et seq., an Agency may not conduct or sponsor, and a person is not required to respond to a collection of information that requires OMB approval under the PRA, unless it has been approved by OMB and displays a currently valid OMB

C ontrol number. The OMB control numbers for EPA's regulations in title 40 of the CFR, after appearing

in the Fede ral Register , are listed in 40 CFR, part 9, and included on the related collection instrument, or form, if applicable. The information collection requirements related to this action have already been

13 The three “small” submitters were identified by review of actual SNUN submissions from the years 2005

- 2010.▌ pg. 6

- 2 

### approved by OMB pursuant to the PRA under OMB control nu mber s 2070

- 0038 (EPA ICR No. 1188)
and 2070

- 0030 (EPA ICR No. 0795).

If an entity were to submit a SNUN to the Agency, the annual burden is estimated to average 98.2 hours per response: 0.82 hours for rule familiarization (Section 3.2.1 ), 2.80 hours for CDX registration, CDX electronic signature, and pay.gov account setup (Section 3.2.2 ), 92.2 hours for form completion, submission and recordkeeping under CFR §721.40 ( Sections 3.2.3 ), 1 hour for consumer notifications (Section 3.2.6 ) and 1.36 hours for export notification (Section 3.2.8 )

. The burdens for rule familiarization, CDX registration, CDX electronic signature, pay.gov account setup form completion, submission, and recordkeeping consumer notifications are approved under EPA ICR No. 1188 (OMB control number

2070

- 0038 ). The burden f or export notification is approved under EPA ICR No. 0795 (OMB control

number 2070

- 0030).



### 6.4 Executive Order 13132, Federalism

Executive Order 13132, entitled Federalism (64 FR 43255, August 10, 1999), requires EPA to develop an accountable process to ensure “meaningful and timely input by State and local officials in the development of regulatory policies that have federalism implications.” Policies that have federalism implications are defined in the Executive Order to include regulations that have “substan tial direct effects on the States, on the relationship between the national government and the States, or on the distribution of power and responsibilities among the various levels of government” (64 FR 43255, August 10, 1999).

The proposed rule establish es reporting and recordkeeping requirements that apply to manufacturers (including importers) and processors of certain chemicals. EPA has no information to indicate that any state or local government manufactures or processes the chemical substances cover ed by this action.



### 6.5 Executive Order 12898, Environmental Justice

Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority Populations and Low Income Populations” (59 FR 7629, February 16, 1994), establishes federal executive poli cy on environmental justice. Its main provision directs federal agencies, to the greatest extent practicable and permitted by law, to make environmental justice part of their mission by identifying and addressing, as appropriate, disproportionately high an d adverse human health or environmental effects of their programs, policies, and activities on minority populations and low

- income populations in the United States.

The information collected under this proposed rule, if finalized, would assist EPA and othe rs in determining the potential hazards and risks associated with various chemicals manufactured and used at high production volumes. Although not directly impacting environmental justice

- related concerns, this

information would enable the Agency to better protect human health and the environment, including in

low

- income and minority communities.



### 6.6 Executive Order 13045, Protection of Children

Executive Order 13045, Protection of Children from Environmental Health Risks and Safety Risks (62 FR 19885, April 23 , 1997), requires EPA to identify and assess environmental health and safety risks that may disproportionately affect children. This type of analysis is required for rules that would have an impact of▌ pg. 6

- 3 

### $100 million or more only. The impact of this SNUR woul d be less than $100 million and therefore no analysis of such impacts on children is required.



### 6.7 Executive Order 13175, Tribal Governments

Executive Order 13175 is Consultation and Coordination with Indian Tribal Governments (59 FR 22951, November 6, 2000). This rule does not have Tribal implications because EPA has no information to indicate that any tribal government manufactures or processes the chemical substances covered by this

action.



### 6.8 Executive Order 13211, Energy Supply, Distribution, or Use

This rule is not subject to Executive Order 13211, entitled Actions Concerning Regulations That Significantly Affect Energy Supply, Distribution, or Use (66 FR 28355, May 22, 2001), because this action is not expected to affect energy supply, distribution, or use.



### 6.9 Executive Order 13563

, Improving Regulation and Regulatory Review

Executive Order 13563, Improving Regulation and Regulatory Review (76 FR 3821, January 21, 2011), requires EPA to base regulations on the best available science, allow for public participati on and the open exchange of ideas, promote predictability and reduce uncertainty , identify and use the best, most innovative, and least burdensome tools for achieving regulatory ends, consider both the costs and benefits qualitatively and quantitatively a nd ensure regulations are accessible, consistent, written in plain language, and easy to understand.

The proposed rule establishes reporting and recordkeeping requirements that apply to manufacturers (including importers) and processors of certain chemic als. Consistent with EO 13563, this document qualitatively and quantitatively describes both the costs and benefits of the proposed rule as well as the underlying data used in the analyses. EPA chose the best available data to analyze the costs and benefit s described in this document and the best analytic approaches given the available data and other constraints

.▌ pg. 7

- 1 

## 7. References

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- 2 

### EPA, 2002a. U.S. E PA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Revised Economic Analysis for the Amended Inventory Update Rule: Final Report. Washington, DC. August 2002.

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- 3 

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. Stamps.com

. 201 3 . “ 2013 USPS Postage Rate Increase Guide

. ” Available at http://www.stamps.com/whitepapers/2013

- usps

- postage

- rate

- increase

- guide.pdf . Accessed December
2014

. State Coalition for Remediation of Drycleaners, 2009

. Chemicals Used In Drycleaning Operations. Revised July 20 09. Available at http://www.drycleancoalition.org/chemicals/ChemicalsUsedInDrycleaningOperations.pdf

Weinstein, 2004. Harriet G. Weinstein and Mark A. Loewenstein, U.S. Bureau of Labor Statistics.
C omparing Current and Former Industry and Occupation ECEC S eries. Originally posted August 25,
2004 at h ttp://www.bls.gov/opub/cwc/cm20040823ar01p1.htm

.▌ pg. A

- 1 

## Appendix A:

– Inflators and Wage Rates

This appendix describes the derivation of the fully loaded labor rates and inflation factors used in calculating costs of labor, mater ials, and other inputs. Costs presented in this report are in 2013 dollars

.



### A.1 Derivation of Loaded Wage Rates

Unit labor costs are calculated by adding fringe benefits and overhead to the wage or salary to derive a fully loaded labor cost. The basic met hod is described in Wage Rates for Economic Analysis of the Toxics Release Inventory Program (EPA, 2002b). The resulting loaded labor rates are given in Table A

- 2 . Costs are calculated for several labor categories: Managerial, Pr ofessional/Technical, Clerical, and EPA staff.

In March 2004, BLS began using the North American Industry Classification System (NAICS) codes instead of the Standard Industrial Classification (SIC) System, and the Standard Occupational Classification (SOC ) system instead of the Occupational Classification System (OCS). The following table shows the crosswalk between old and new occupational titles.

Table A

- 1 : Labor Category Crosswalk

EPAB Reports Labor Category BLS Old Title (O CS) BLS New Title (SOC)

Managerial Executive, administrative, and managerial Management, business, and

financial

Professional/Technical Professional specialty and technical Professional and related

Clerical Administrative support, including

clerical O ffice and administrative support

Source: Employer Costs for Employee Compensation: Changes to NAICS and SOC, Table 2 . ECEC Occupational Comparability between SOC and OCS (BLS, 2006a and Weinstein, 2004).



### A.1.1 Derivation of Labor Rates for Managerial, Pr ofessional/Technical, and Clerical
Labor
Wages and fringe benefits for managerial, professional/technical, and clerical labor were taken from the Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation (ECEC) data, 14 

### for

December 2013 , fo r manufacturing industries. 15



### The cost of fringe benefits such as paid leave and insurance, specific to each labor category, are taken from the same ECEC series. Fringe benefits as a percent of wages are calculated separately for each labor

14 This follows the approach introduced in Economic Analysis of Expedited Significant New Use Rules for 65 Chemical
Substances: EPA Docket OPPT

- 2003

- 0063 (EPAB, 2007 b )

.

15 Employer Costs for Employee Compensation Supplementary Tables December 2006

- June 2014

. (BLS, 2014b )

. This follows the approac h introduced in EPAB, 2007a. Earlier PMN SNUR economic analyses, such as EPA, 2003 , used ECEC data for “All Goods Producing” sectors (manufacturing, mining, and construction)

. However, the manufacturing sector data seem more relevant since the SNURs mainly affect the chemicals industry.▌ pg. A

- 2 

### category. For ex ample, for December 2013 , the average wage rate for professional/technical 16 

### labor was $ 39.70 ; the average fringe benefit was $ 21.14 . Fringe benefits as a percent of wages were $ 21.14 /$ 39.70

, or approximately 53.25 percent.

An additional loading factor of 1 7 percent is applied to wages to account for overhead. This approach is used for consistency with Office of Pollution Prevention and Toxics economic analyses for two major rulemakings: Wage Rates for Economic Analyses of the Toxics Release Inventory Progra m (EPA, 2002b),

and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a). This overhead loading factor is added to the benefits loading factor, and the total is then applied to the base wage to derive the fully loa ded wage. For example, the December 2013 fully loaded wage for professional/technical labor is $ 39.70 × (1+ 0. 5325 + 0.17) = $ 67.59

.

Fully loaded costs for managerial and clerical labor are calculated in a similar manner, as shown in Table

A

- 2

.

A.1.2 Derivation of Labor Rates for EPA Staff
Agency labor costs are calculated based on annual Federal salaries for the Washington

- Baltimore area published by the Office of Personnel Management effective January 2013 (OPM, 2013 ). The averag e salary for one FTE staff member is estimated as the salary for a GS

- 13 Step 5 employee. 17



### Multiplying the annual pay by an assumed loading factor of 1.6 to reflect Federal fringe benefits and overhead, the loaded annual salary of EPA staff was calculated to be $161,446.

The Agency loading factor is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (EPA, 1992, page 30, footnote 9). The 60 percent assumption was labeled “the benefits multiplication factor” in the EPA Guid e, but has been used in many EPA Office of Pollution Prevention and Toxics ICRs to reflect both fringe benefits and overhead for Federal staff. For example, it was used in an August 2000 document supporting ICR No. 1139.06 (EPA, 2000 a ), with the following explanation:

The annual costs per FTE are derived by multiplying the annual pay rate by 1.6 (the benefits multiplication factor). The multiplication factor used is recommended in EPA’s Office of Policy, Planning, and Evaluation’s Instructions for Preparing Information Collection Requests (ICRs) (June 1, 1992). An EPA internal phone call between Carol Rawie (OPPT/EETD/RIB) and Carl Koch (OPPE/RMD/IMB) on May 3, 1994, indicated that the 1.6 factor included not o nly benefits but also overhead. (ICR No.1139.06)

16 This follows terminology introduced in EPAB, 2007 b . Earlier SNUR economic analyses used the term “technical” labor. Here the category is called “professional/technical” labor, to make clear how it relates to BLS categorie s

. In 2004, BLS changed from the Occupational Classification System, OCS, to the Standard Occupational Classification system, SOC

. In the process, the “Professional specialty and technical” category became the “Professional and related” category

. However, the coverage of

the old and new occupational groups is approximately the same

. See the BLS article, C omparing Current and Former Industry

and Occupation ECEC Series (Weinstein, 2004).

17 The GS

- 13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007), whi ch covers PMN SNURs. Use of this grade level follows the approach introduced in EPAB, 2007a. That report represented a change from the earlier PMN SNUR economic analysis (EPA, 2003), which used an average of GS

- 12 Step 1 and GS

- 12 Step 10 salaries.▌ pg. A

- 3 

### Table A

- 2 : Derivation of Loaded Wage Rates

EPAB Labor

Category Data Source Date Wage Fringe
Benefit Fringes as % Wage Overhead % Wage 2 Fringe +
Overhead

Factor Loaded Wages 1

(a) (b) (c) =(b)/(a) (d) (e)=(c)+(d)+1 (f)=(a) x (e)

Managerial BLS ECEC , Private Manufacturing
industries

, “Mgt, Business, and

Financial” 3 Dec

- 13 $46.21 $23.70 51.29% 17% 1.68 $77.77

Professional/
Technical BLS ECEC , Private Manufacturing industries, “Professional and related“ 3 Dec

- 13 $39.70 $21 .14 53.25% 17% 1.70 $67.59

Clerical BLS ECEC , Private Manufacturing industries, “Office and Administrative Support” 3 Dec

- 13 $18.05 $9.24 51.19% 17% 1.68 $30.36

EPA staff

FTE Annual Federal staff cost: OPM Washington

- Baltimore

- Northern Virgin ia, DC

- MD

- PA

- VA

- WV, area,
GS

- 13 Step 5 pay rates, with 60%

overhead 4 Jan

- 13 $48.51

-- [Included in 60% overhead] 60% 1.6 0 $77.62

Notes:

1 Wage data are rounded to the closest penny; however, unrounded values were used in calculations.

2 An overhead rate of 17 percent was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b), and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a).

3 Employer Costs for Emplo yee Compensation Supplementary Tables : December 2006

- March 2014 , U.S. Bureau of Labor Statistics, June 11, 2014 (BLS, 2014 b ).

4 The Federal salary is the unloaded Federal GS

- 13 Step 5 salary ($100,904 divided by 2

, 080 hours to get the hourly wage rate in th e table) for 2013 , from the Office of Personnel Management salary table for Washington

- Baltimore

- Northern Virginia (OPM, 2013 ). The 60% fringes

- and

- overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (EPA, 1992, page 30, footnote 9).▌ pg. A

- 4 

### A.2 Derivation of Inflation Factors

Detailed information on the derivation of the inflation factors used is presented in Table A

- 3

. In 2006, the Bureau of Labor Statistics (BLS) made several changes to the Employment Cost Index. The changes are described on a BLS web page, “Change has come to the ECI,” (BLS, 2006c ) and in several April 2006 Monthly Labor Review articles posted on the BLS web site: “Changes affecting the Employment Cost

Index: an overv iew” (Caroll

, 2006 ); “Employment Cost Index Publication Plans” ( Sleemi, 2006 ); and “Seasonal adjustment in the ECI and the conversion to NAICS and SOC” ( Branch, 2006 ).

Under a mandate from OMB, BLS changed its classifica tion of industries and occupations f rom the Standard Industrial Classification (SIC) and Occupational Classification System (OCS) to the North American Industry Classification System (NAICS) and Standard Occupational Classification (SOC) system. In 2006, BLS adjusted all ECI series to reflec t this change.

In addition to changing the industry and occupational classification systems, in 2006, BLS rebased the
ECI from June 1989 = 100 to December 2005 = 100 for all current and historical non

- seasonally adjusted series, including the NAICS and SI C based series. (Seasonally adjusted indices, including those in Table

A

- 3 of this report, may not exactly equal 100 for December 2005 as a result of the seasonal adjustment. Seasonal adjustments are explained in Branch, 2006.)

According to BLS, the official ECI for the years 1975

- 2005 is the SIC

- OCS based series, and for subsequent years, the official ECI is the NAICS

- SOC based series (Sleemi, 2006, p.8). 18



### “Starting year” indices in Table A

- 3 continue to be SIC

- OCS based. Current year indices are NAICS

SOC based. We use indices from both the NAICS

- SOC and the SIC

- OCS based ECI series because neither series spans the entire period over which testing and other costs need to be inflated.

18 BLS has been publishing the NAICS

- SOC based ECI series since March 2001 and it became official in March 2006. The SIC

OCS based series and NAICS

- SOC series have different series ID numbers, even when they describe essentially the same population. For example t he series ID for seasonally adjusted total compensation for all private industry workers is

ECS10002I for the SIC

- OCS series and CIS2010000000000I for the NAICS

- SOC series

.▌ pg. A

- 5 

### Table A

- 3 : Derivation of Inflation Factors

Item Inflation Index Source 1 Starting

Year Index for Starting Year (a) Index for
2013

(b) Inflation

Factor (b)/(a) 2

Agency Extramural costs
Professional and Related Private Industry BLS ECI, Total c omp, Private industry, Professional and

related , 4 th Q [BLS, 201 4 b] 3 1993 67 120.5 1.799

Labels, placards etc. BLS CPI, All urban consumers, not SA. CUUR0000SA0, Annual [BLS, 2014 a ] 1997 160.5 232.957 1.451

File cabinet

Photocopies BLS CPI, All urban consumers, not SA. CUUR0000SA0, Annual [BLS, 2014 a ] 1988 118.3 232.957 1.969 Record keeping materials

Key: BLS = Bureau of Labor Statistics. CPI = Consumer Price Index. ECI = Employment Cost Index. SA = Seasonally Adjusted. Total Comp = Tota l Compensation (wages/salaries and benefits). 4 th Q = Fourth Quarter.

Notes:

1 In 2006, Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) series “were rebased to December 2005 = 100 from June 1989 = 100.” The change is reflected in the indices in this table and explained on the BLS website, Employment Cost Index News Release Text: Employment Cost Index, March 2006 (BLS, 2006b). The Consumer Price Index (CPI) was not

rebased. “Starting year” ECI indices are SIC

- OCS based: Seasonally Adjusted (SA ) ECS10002I for private industry All Workers, and

not SA ECU11122I for private industry Professional and Related Workers. After 2006, ECI indices are NAICS

- SOC based: Seasonally Adjusted (SA) CIS2010000000000I for private industry All Workers, and not SA CIU2010000120000I (B) for private industry Professional, and Related workers.

2 Inflation factors are rounded; however, unrounded values were used in calculations.

3 B eginning with the report Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: EPA

Docket OPPT

- 2009

- 0922 (EPA, 2011b) we began to use the not

- seasonally adjusted CIU2010000120000I for private industry Professional, and Related workers, instead of SA CIS2010000W00000I for private industry white collar workers beca use BLS retired the “whit e

- collar” series.▌ pg. B

- 1 

## Appendix B: 2013 TRI Data for TCE

Table B

- 1: TRI Reporters for TCE in 2013

Facility Name Use Total On Site
Release (Pounds) Total Off Site
Release (Pounds)

DARAMIC LLC Manufacturing Aid 246,529

ENTEK IN TERNATIONAL LLC Manufacturing Aid 168,300

US DOE WASTE ISOLATION PILOT
PLANT Ancillary Use 108,711

MICROPOROUS LLC 95,992

PLYMOUTH TUBE CO Manufacturing Aid 71,794

UTI HOLDINGS LLC DBA ACCELLENT Ancillary U se 69,195 98

PPG INDUSTRIES INC BARBERTON 66,997

SPIRIT AEROSYSTEMS INC Ancillary Use ; Formulation Component ; Manufacturing Aid 56,081 1,334

ENERGIZER PERSONAL CARE Ancillary Use 4 8,800

NATIONAL COPPER & SMELTING CO Ancillary Use 46,240

AMETEK SPECIALTY METAL PRODUCTS
DIV Ancillary Use 38,314

CESSNA AIRCRAFT CO (PAWNEE FACILITY) Manufacturing Aid 33,000

SUMMERILL TUBE CORP Manufacturing Aid 32,400

GOODRICH PLATING OPS Ancillary Use 26,035 610

FISCHER SPECIAL MANUFACTURING
CO Ancillary Use 25,992

SCHICK MANUFACTURING INC Ancillary Use ; Manufacturing Aid 25,544

SALEM TUBE INC Anci llary Use 24,677

DRIL

- QUIP INC Ancillary Use 24,144

3P PROCESSING INC Manufacturing Aid 24,031

GKN AEROSPACE NA INC Manufacturing Aid 22,000

EAGLE US 2 LLC Ancillary Use 21,925 3 6

DUTTON

- LAINSON CO Ancillary Use 21,260

GREATBATCH

- GLOBE TOOL INC Ancillary Use 20,239

ROMATIC MANUFACTURING CO INC Ancillary Use 19,864 268

BELTSERVICE CORP Manufacturing Aid ; Repackaging 19,506

GLOBE ENGINEERING CO INC Ancillary Use 18,339

PHIFER INC Ancillary Use 18,200

BETTY MACHINE CO INC Ancillary Use 17,911

LARSEN'S MANUFACTURING CO Ancillary Use 17,758

WATER GREMLIN CO Ancillary Use 17,496▌ pg. B

- 2 Facility Name Use Total On Site
Release (Pounds) Total Off Site
Release (Pounds)

MJ CELCO INC Manufacturing Aid 17,100

HONEYWELL INTERNATIONAL INC
AUTOMATION & CONTROL SOLUTIONS Ancillary Use 16,770

API HEAT TRANSFER INC Manufacturing Aid 16,593

DIAMOND CHROME PLATING INC M anufacturing Aid 16,562

ADVANCED FORMING TECHNOLOGY Ancillary Use 16,292

CHEMICAL WASTE MANAGEMENT OF
THE NORTHWEST INC Ancillary Use 15,939

VIKING DRILL & TOOL INC Ancillary Use 15,566

THE BOEING CO Anci llary Use 15,000

CHEM PROCESSING INC Ancillary Use 14,812

ACCURATE FORMING LLC Ancillary Use 14,676

DIXON BRASS Ancillary Use 14,260

R E DARLING CO INC Ancillary Use 14,033

GOODRICH CORP Anci llary Use 13,870

FOUNTAIN PLATING CO INC Ancillary Use 13,420 266

EXXONMOBIL REFINING & SUPPLY
BATON ROUGE REFINERY Ancillary Use 13,190

K & G MANUFACTURING CO Ancillary Use 12,382

ROPER PUMP CO Ancillary Use 12,159

NORDAM I&S DIV Manufacturing Aid 11,314 1,100

MANUFACTURERS PLATING CO Ancillary Use 11,220

ADVANCED HEAT TREAT CORP Manufacturing Aid 11,200

OSRAM SYLVANIA INC Ancillar y Use 11,080 671

GASSER & SONS INC Ancillary Use 10,520

ARLINGTON PLATING CO INC Ancillary Use 10,296

HU

- FRIEDY MFG CO LLC Ancillary Use 10,196 2,066

ADVANCED HEAT TREAT CORP Manufa cturing Aid 10,190

ALLOYWELD INSPECTION CO Manufacturing Aid 10,088

FENNER PRECISION Ancillary Use 9,264

PROTECTIVE COATINGS INC Ancillary Use 8,944

STEEL COATINGS INC Ancillary Use 8,820

AGET MFG CO Ancillary Use 8,730

FN MANUFACTURING LLC Ancillary Use 8,644

MULLINS RUBBER PRODUCTS INC Ancillary Use 8,590

NICO PRODUCTS INC Ancillary Use 8,518

LYTRON INC Ancillary Use 8,334

ANOPLATE CORP Ancillary Use 8,214▌ pg. B

- 3 Facility Name Use Total On Site
Release (Pounds) Total Off Site
Release (Pounds)

ST REGIS MANUFACTURING LLC
TRADING AS RS OWENS & CO Ancillary Use 8,000

TWR SERVICE CORP Ancillary Use 7,840

EYELET DESIGN INC Ancillary Use 7,572 1,060

LAKE REGION MEDICAL Ancillary Use ; Formulation Component 7,460

EXXONMOBIL CHEMICAL BATON ROUGE CHEMICAL PLANT (PART) Ancillary Use 7,400

WAUCONDA TOOL & ENGINEERING CO
INC Ancillary Use 7,389

LS STA RRETT CO Ancillary Use 6,297

ROCHESTER STEEL TREATING WORKS
INC Ancillary Use 6,063

HANDYTUBE CORP Ancillary Use 6,046 11

TECH TUBE Ancillary Use ; Formulation Component 5,940

NATIO NAL ELECTRICAL CARBON
PRODUCTS DBA MORGAN ADV
MATERIALS 5,900

HONEYWELL AEROSPACE

- MINNEAPOLIS Ancillary Use 5,611

MUELLER COPPER TUBE PRODUCTS
INC Ancillary Use 5,268

MN TWIST DRILL AQUISITION LLC 4,958

KASTALON INC Manufacturing Aid 3,960
MARQUETTE TOOL & DIE CO Manufacturing Aid 3,960

MCMILLAN ELECTRIC CO Manufacturing Aid 3,885

US RINGBINDER Ancillary Use 2,645

UTICA CUTLERY CO An cillary Use 2,629

DOW CHEMICAL CO FREEPORT
FACILITY Ancillary Use ; Repackaging 2,416

DYNEX/RIVETT INC Manufacturing Aid 1,997

LORD CORP Formulation Component 1,995

LIMCO

- AIREPAIR INC Ancillary Use 1,716

ENERGIZER BATTERY
MANUFACTURING INC 1,535

WHITAKER OIL CO Repackaging 1,486

CRC INDUSTRIES INC Formulation Component ; Repackaging 1,438

ARKEMA INC 1,354

TRAVIS PATTERN & FOUNDRY INC Manufacturing Aid 1,160

QUESTVAPCO CORP Ancillary Use ; Formulation Component 1,124

AKEBONO

- ELIZABETHTOWN PLANT Ancillary Use 1,000▌ pg. B

- 4 Facility Name Use Total On Site
Release (Pounds) Total Off Site
Release (Pounds)

WESTLAKE VINYLS CO 880

SHERWIN

- WILLIAMS CO For mulation Component 844 40

RR STREET & CO INC Repackaging 766

FORMOSA PLASTICS CORP LOUISIANA Ancillary Use 712

AMREP INC Formulation Component 669

PLAZE INC Formulation Component 501
LAFARGE MIDWEST INC (INCLD SYSTECH ENVIRONMENTAL) Repackaging 500 250

KEYSTONE CEMENT CO Ancillary Use 500

CHEMICAL SOLVENTS JENNINGS ROAD
FACILITY Formulation Component ; Rep ackaging 500

AERVOE INDUSTRIES INC Article Component 500

CHEMICAL SOLVENTS INC

-- DENISON
FACILITY Ancillary Use ; Repackaging 500

FORMOSA PLASTICS CORP TEXAS Ancillary Use 440

SLOCUM ADH ESIVES CORP Formulation Component 408

LPS LABORATORIES Formulation Component 372

UNIVAR USA INC NORCROSS FACILI TY Repackaging 352

UNITED LAUNCH ALLIANCE

- DECATUR
OPERATIONS Ancillary Use 287

UNIVAR USA INC Repackaging 266

CONTINENTAL CEMENT CO LLC Ancillary Use 255

EMCO CHEMICAL DISTRIBUTORS INC Formulation Component ; Repackaging 255

PACKAGING SERVICES CO INC (PEARLAND FACILITY) Fo rmulation Component ; Repackaging 255

EMCO CHEMICAL DISTRIBUTORS INC Formulation Component ; Repackaging 255

PRECISION FORMING & STAMPING C O Ancillary Use 255 501

IPS CORP Formulation Compon ent 250

COMMERCE INDUSTRIAL CHEMICALS
INC Repackaging 250

HALOCARBON PRODUCTS CORP 220

HUBBARD

- HALL INC Repackaging 217

BUZZI UNICEM USA

- GREENCASTLE
PLANT Ancillary UseRepackaging 189

VEOLIA ES TECHNICAL SOLUTIONS
LLC Ancillary Use ; Formulation Component ; Repackaging 188 336

SOUTHWEST SHIPYARD LP Repackaging 180

TREADS DIIRECT LLC DBA MIDWEST
RUBBER Formulation Compo nent 150▌ pg. B

- 5 Facility Name Use Total On Site
Release (Pounds) Total Off Site
Release (Pounds)

3M COTTAGE GROVE CENTER Ancillary Use 146

THE DOW CHEMICAL CO

- LOUISIANA
OPERATIONS Ancillary Use 135

AXIALL LLC 129 3

WRR ENVIRONMENTAL SERVICES CO
INC Fo rmulation Component 97

OCCIDENTAL CHEMICAL CORP Ancillary Use 92 2

EMERALD SERVICES INC 80 0.01

ABC COMPOUNDING CO OF TEXAS INC Formulation Component 69

INTERSTATE CHEMICAL CO INC Formulation Component ; Repackaging 65

OXY VINYLS LP DEER PARK

- VCM
PLANT Ancillary Use 63 0.03

CLEAN HARBORS DEER PARK LLC Article Component 58

ADCO I NC Repackaging 52

CLEAN HARBORS ENVIRONMENTAL
SERVICES INC Ancillary Use 47 0.005

CLEAN HARBORS ARAGONITE LLC Ancillary Use 47 101

ROSS INCINERATION SERVICES INC Ancillary U se 42 39

VEOLIA ES TECHNICAL SOLUTIONS
LLC PORT ARTHUR FACILITY Ancillary Use 40

SHINTECH PLAQUEMINE PLANT 33

INTERSTATE CHEMICAL CO INC Formulation Component ; Repackaging 29

BARTON SOLVENTS INC DES MOINES Formulation Component ; Repackaging 23

SHAWMUT CORP 21

DUPONT SABINE RIVER WORKS Ancillary Use 19

HERITAGE THERMAL SERVICES Ancillary Use 17 10

ASTRO CHEMICALS INC Repackaging 15

GIANT CEMENT CO Ancillary Use 13 13

GEORGIA GULF LAKE CHARLES LLC 12

ENERGIZER BATTERY
MANUFACTURING INC Ancillar y Use 11

SAFETY

- KLEEN SYSTEMS INC Formulation Component ; Repackaging 10

SYSTECH ENVIRONMENTAL CORP Ancillary Use 10
KAGA (USA) INC Ancillary Use 10

AMERICAN JETWAY CORP Formula tion Component 10

MEXICHEM FLUOR INC 8

BUZZI UNICEM USA

- CAPE GIRARDEAU Ancillary Use 8▌ pg. B

- 6 Facility Name Use Total On Site
Release (Pounds) Total Off Site
Release (Pounds)

EVOQUA WATER TECNOLOGIES
DARLINGTON FACILITY Ancillary Use 8 38

WESTLAKE VINYLS INC 5

ESSROC CEMENT CORP Ancillary Use 5

SHIELD PACKAGING CO INC Formulation Component 5 530

CHEMTRON CORP Ancillary Use 4 4

NORLITE LLC Ancillary Use 4

OXY VINYLS LP LA PORTE VCM PLANT 3 0.01

CLEAN HARBORS EL DORADO LLC Ancillary Use ; Repackaging 2

ASH GROVE CEMENT CO Ancillary Use 1

ASH GROVE CEMENT CO Ancillary Use 1

SOLVAY USA INC Ancillary Use 1

SOLVAY USA INC Ancillary Use 0.4

SUPERIOR FIBERGLASS & RESINS

SUPERIOR SOLVENTS & CHEMICALS

BRENNTAG GRE AT LAKES LLC

BALMAR LLC

VEOLIA ES TECHNICAL SOLUTIONS
LLC Ancillary Use 3

QUAKER CITY CHEMICALS

SUPERIOR SOLVENTS & CHEMICALS

MON

- ECO INDUSTRIES INC

31 INC

SUPERIOR OIL CO INC

THIRD COAST TERMINALS PEA RLAND

RHO

- CHEM LLC

FARLEY CO

COMCAST URETHANE

DELTA COS GROUP ST GABRIEL Repackaging

ROBERTS CAPITOL

BLENTECH CORP

AMC INTERNATIONAL

SUPERIOR SOLVENTS & CHEMICALS

PRIDE SOLVENT & CHEMICAL CO OF
NY INC

MASTERS MACHINE CO Article Component ; Manufacturing Aid

CENTRAL PLAINS CEMENT CO

BRENNTAG GREAT LAKES LLC▌ pg. B

- 7 Facility Name Use Total On Site
Release (Pounds) Total Off Site
Release (Pounds)

CHEMICAL & METAL INDUSTRIES INC

HILL MANUFACTURING CO INC

FOUR STAR CHEMICAL

BRENNTAG NORTHEAST INC

VANCE BROTHERS INC

CLEAN EARTH OF NORTH JERSEY INC Ancillary Use 10,971

SPRAY PRODUCTS CORP

FBC CHEMICAL MEDINA

TEM

- TEX SOLVENTS CORP

CHEMICAL DISTRIBUTORS INC

APOLLO TECHNOLOGIES

WEBB CHEMICAL SERVICE CORP

Sources: EPA, 2014 c

.