# Nation Ford Chemical Waiver Petition for

Dioxin/Furan Test Rul e Regarding Import of

Chloranil

Economic Assessment

October 9 , 2014

CONTAINS NO CBI

Economics and Policy Analysis Branch

(EPAB)

Office of Pollution Prevention and Toxics2



## Background

In March 2014, Nation Ford Chemical (NFC) submitted a request for a waiver ( NFC , 2014a) to the

Dioxin / Furan t es t Rule (D/F Test Rule) , c odified in Title 40 CFR 766 , t hat would allow them to import

c hloranil without triggering subsequent testing obligations

. The D/F Test Rule, speci fic ally in 40 CFR 766.32(a)(2) (ii), allow s for a waiver from testing if "in the judg e ment of EPA, the cost of test ing would
drive the chemical substance off the market, or prevent resumption of manufacture or import of the
chemica l substance, if it is not currently manufactured, and the chemical subst ance will be produced so
that no unreasonable risk will occur due to its manufacture, import, processing, distributio n, use, or disposal ( i n which case , the manufacturer must submit t o EPA all data supporting the determination.)" The Economics and Policy Analysis Branch (EPAB) within the Environmental Protection Agency’s (EPA)
Office of Pollution Prevention and Toxics (OPPT) was asked to consider affordability of the testing for the manufacturer and whether the cost of testing would drive the chemical substance o f f the market, or prevent resumption of manufacture or import of the chemical substance if it is not currently
manufacture d. The chemical in question is c hloranil (CASRN 118

- 7 5

- 2).



## Company Information

NFC is a privately owned specialty chemical producer with approximately $25 million in annual

revenue (2010) and approximately 40 percent of manufacturing is for toll sales. The company has 85 employees and at a single site loc ated in South Carolina (SOCMA, 2010).

Nation Ford Chemical can be classified under NAICs 325998, Al l Other Miscellaneous Chemical Products and Preparation Manufactur e (Dunn and Bradstreet, 2014). The Small Business Administration
defines a small business in this NAICs code as one that has 500 employees or fewer (SBA, 2014) . Because NFC has approximately 85 employees (SOCMA, 2010) it qualifies as a small business.



## Market Information

Chloranil is used as an intermediate in the manufacture of a number of products, including certain colorants (Robinson, 2007). Of particular interest to NFC i s its use in the manufacture of

c arbazole pigment v iolet 23 ( PV 23 ) (CASRN 6358

- 30

- 1).

Chloranil

There are no repor ts of manufacture or import of c hloranil to the most recent Chemical Data Reporting (CDR) (EPA, 2014)

. [CBI]

NFC claims that Clariant Chemical Ltd. ( Clariant ) is the sole source of this chemical (NFC, 2014 b )

.

NFC’s intere st in importing c hlorani l stems from a desire to improv e the production process for

PV 23 resulting from concerns about the company’s ability to remain competitive in the market. Currently , NFC uses d ianil (CAS 380546

- 37

- 8) to produce PV 23

. According to NFC, m arket conditions ar e such that it has been investigating alternative approaches to manufacturing PV 23 and has found that a process using c hloranil would produce PV 23 more efficiently . Clariant is currently the only source of

c hloranil for NFC (and is a direct competitor in the final product market

– see below). Therefore, NFC is3

s eeking to begin importation of c hloranil from China in a manner that would allow them to remain competitive in the final product ( PV 23 ) market (NFC, 2014 a )

.

Carbazole Pigment Violet 23 ( PV 23 )

PV 23 is used as a colora nt in inks, plastics, rubber, coatings, and fibers among other things ( Dyestuff Intermediates, 2014). PV 23 can refer to both crude and finished product. Crude PV 23 is solely
used to produce finished PV 23 which takes the form of presscake and dry color (USITC, 2010). Crude PV

23 must be further processed to produce pr esscake and dry color which involves additional cost and adds value. Therefore, prices for finished product PV 23 are higher than for PV 23

. There are no direct
subs titutes for PV 23 (USITC, 2010).

According to EPA’s most recent CDR information, PV 23 was produced (manufactured and/or imported) by six companies in 2012. The companies and their production volumes are reported in Table

1. It is not clear if the produc tion volumes represent crude or finished product PV 23

, however, in 2010,

Table 1. Producers and Production Volumes for PV23 Company Name Manufacture or Import 2012 Production

Volume (lbs.) Previous Year’s

Production Volume (lbs.) Heucotech, Ltd. Import 126,000 75, 158 Flint Group [ CBI ] [CBI] 105,911

DIC Americas 1 [CBI] [CBI] 120,537
Shanco [CBI] [CBI] 56

, 966
Nation Ford Chemical Manufacture 444,910 307,460 [CBI] [CBI] [CBI] [CBI]

1 Sun Chemical is a member of the DIC Group of companies.

the U

. S

. I nternational T rade C ommission (USITC) found that NFC accounted for 100 percent of the U.S. production of PV 23 crude and that NFC’s production of PV 23 crude is exclusively produced through its toll agreement with Sun Chemical, Inc. (USITC, 2010)

. This implies that the remaining imports are of finished product. It is still possible that s ome of the imports are crude PV 23 that is subsequently processed into final product in the U.S

. since the CASRN does not distinguish between the two forms of
the chemic al

. According to the USITC, NFC has been able to provide Sun’s entire crude PV 23 needs since

2009 (USITC, 2010) , however

, given that Sun has recorded some import of PV 23 (crude and/or finished product) it is not clear that this is happening at this time. In the past, Sun has decreased its toll purchases from NFC and increased imports or lowered tolling fees to NFC in order to respond to market forces, although Sun has testified that it does have an interest in maintaining a secure U.S. supply source
for c rude PV 23 (USITC, 2010 )

.

Regardless of whether imports of PV 23 are in crude or finished form, it appears that NFC controls a large portion of the domestic market. However, because PV 23 is used for a variety of end products, it is expected that the mar ket and price for PV 23 is driven by the markets and prices for the final end products (e.g., printer inks). The demand for PV 23 has remained relatively stable (USITC , 2010 ) which suggests that strong growth in the overall market is not expected

, however

, CDR data indicate an
increase in total volume (adding all forms, crude and finished product together) of almost 24 percent from 2010 to 2012 (EPA, 2014).4

In 2004, the USITC investigated a petition from NFC and Sun Chemical alleging that imports of

PV 23 from India were being subsidized and that imports of PV 23 from India and China were being sold at less than fair market value in the U.S. The USITC prepared a report concluding that under the U.S. Tariff Act of 1930, the U.S. market was materially injure d by these imports and an antidumping duty order was imposed. In 2010, USITC revisited the situation and came to the determination that revocation of the antidumping duty orders would st ill materially injure the U.S. “within a reasonably
fo reseeable time” (USITC, 2010). During its investigations, the USITC conducted extensive reviews of the
market for PV 23

.

The USITC studies point to a market that is particularly sensitive to price changes. There is moderate to high substitutability between imported and domestic product. While quality of product is a consideration (top ranked ) in choosing a PV 23 supplier, price (second ranked) was also an important consideration (USITC, 2010). The investigation also showed that both China and India have capacity to produce large volumes of PV 23 and that these countries have incentive to increase their exports to the U.S. (USITC, 2010). When the USITC imposed anti

- dumping orders , producers exporting to the U.S. were found to shift their exports to downstream products (such as inks) the contain PV 23 but are not subject to the orders further demonstrating a desire to supply the U.S. market (USITC, 2010). In the past, the domestic industry’s financial performance has been found to suffer due to decreasing prices resulting from imports from China and India (USITC, 2010).

According to NFC, their current selling pric e for PV 23 is $ [CBI] /lb

. This price is slightly higher than the price that is available on the market at $ [CBI] /lb

. (NFC, 2014 b ). NFC has stated that they have been able to hold market share because of the quality and consistency of their product, however that share is beginning to diminish ( NFC , 2014 c ). While the production volume increases from 2010 to 2012 do not support this argument, it is plausible given the pri ce sensitivity of the product. Additionally, the USITC indicated that, as a result of inst allation of new production process equipment, NFC had significantly reduced production capacity from 2006 to 2008. During this time, Sun sourced crude PV 23 from China and India. NFC reported that it was able to return to producing Sun’s PV 23 requirement in
mid

- 2009 (USITC, 2010 ) . It is possible that the growth in production by NFC from 2010 to 2012 was partially from regaining previously held market share rather than an expansion of the market.



## Cost of Testing

The Economic Analysis of Final Section 4 T esting Rule for Chemicals Potentially Contaminated with Polyhalogenated Dibenzo

- p

- dioxins and Polyhalogenated Dibenzofurans (D/F Test Rule) developed estimates of costs associated with testing required by the test rule (EPA, 1987). Because the rule was
fin alized over 17 years ago, it is reasonable to expect that the estimated costs have changed significantly. Factors that would contribute to changes include increases due to rising costs (e.g., labor, materials) over time and decreasing costs due to things s uch technological advances in testing approaches and methodology developments, etc. However, it is reasonable to expect that some of the activities outlined in the economic analysis for the rule would still occur. The economic analysis of the
rule identifi es methodology development, synthesis of analytic standards, and sample analysis. In addition, NFC would need to develop and submit a study plan for review by the EPA.

Since the test rule became effective , a number of companies have submitted data to the Agency to comply with the rule. It is expected that contract research organizations (CROs ) that are expected to do the testing, likely have experience with this type of testing such that costs for methodology development and synthesis of analytic standard s are minimal. Remaining costs would be most likely to5

include costs for analytical testing, testing oversight, and test plan development and negotiation (if necessary) with EPA.

NFC developed an overall testing cost estimate of $200,000. EPA contacted N FC and received further explanation on the basis for the estimated cost ( NFC , 2014b, c , 2014). The estimate included [CBI]

. According to NFC, the estimate was based on [CBI]

. EPA finds this estimate to be reasonable and

uses it in the analysis below.

In its waiver request, NFC offered an alternative testing strategy to the requirements of the D/F test rule. Under their proposed approach, NFC would have a composite sample drawn [CBI] and have it tested using method [CBI] . NFC estimates the cost of this tes ting to be approximately $ [CBI] /sample ( NFC , 2014 c ). EPA, through its contractor, informally contacted SGS Environmental Services, Inc. in Wilmington, North Carolina, to inquire about the cost to run this test method and were told that this method provi des a sampling protocol but that the cost to analyze the sample could be approximately $ [CBI] per sample ( Wilson , 2014). It is not clear how many sample s would need to be drawn or if a composite sample would be sufficient, however, the analytical costs est imated by NFC seem reasonable.

NFC has also indicted that the cost of testing [CBI] . EPA used this price to back calculate the potential annual cost of testing using method [CBI]

.

Because th e potential imported volume of c hloranil is not known and was not provided to EPA

, EPA assumed that NFC will import the volume of c hloranil necessary to manufacture the volume of
crude PV 23 that is currently produced in the U.S. which is estimated to be 444,910 lbs. (based on the
most recent CDR data provided by NFC) . Using the relationship of the molecular weight (MW) of

c hloranil (246 g/mol) to the MW of PV 23 (589 g/mol), we find that :

Mass of c hloranil/246 g/mol = Mass of PV 23 /589 g/mol or

(246/589) x ( mass of PV 23 ) = M ass of c hloranil or

( 0.4 2) x (mass of PV 23 ) = Mass of c hloranil

.

Therefore,

(0.42 ) x (444,910 lbs.) l = Mass of c hloranil = 186,862 lbs. c hloranil.

If the price increase is [CBI] /lb . c hloranil, then the cost of testing is approximately [CBI] /year (186,862 lbs./year) [CBI] ). A s a check, 186,862 lbs

. is equivalent to approximately 17 MT (186,862lbs.)/(11,000 lbs/MT). If each lot is [CBI] , then NFC would be shipping [CBI] lots of c hloranil. At a testing cost of [CBI] /lot and [CBI] / lot, testing costs per year would amount to [CBI ] and [CBI] , respectively. To be conservative, EPA uses the highest of the three cost estimates for this method and assumes costs of testing each [CBI] lot will be approximately $ [CBI] /year.



## Additional Costs

In addition to laboratory costs, companies subject to the D/F Test Rule may experience other costs including administrative costs (including development of study plans, selection of laboratories,6

monitoring labs, and paperwork ) and costs associated with complying with export notification requirements under Section 12(b) of the Toxic Substances Control Act (TSCA).

EPA has used costs of testing supplied by NFC of $200,000. Information provided by NFC ( NFC

, 2014 c ) suggests that this estimate includes additional administrative costs, so n o additional costs are included. Because NFC’s entire production of crude PV 23 (from c hloranil) is estimated to be sold to Sun Chemicals (domestically), export notification requirements are not expected to be incurred and therefore, no costs have been add ed for export notification.



## Economic Impact s and Analysis

EPA uses several approaches to evaluate the economic impact of required testing on companies.

Two specific approaches are presented here followed by a qualitative discussion of the results. Each approach was designed to provide different information and, in this particular case, may be best considered together with the qualitative discussion.

Small Business Impacts Approach

NFC is a small business as defined by the SBA under 13 CFR 131. To evaluate the possibility of adverse effects on the business as a result of testing, EPAB employs an approach that compares the cost of testing to the company’s total sales.

As previously stated, NFC’s total revenue is estimated to be $25 million (SOCMA, 2010) . The

cost

- to

- sales ratio is therefore estimated to be ($ 200,000 ) / ( $ 25 million ), or 0 .8 percent

. When evaluating small business impacts for rulemakings

, EPA generally has a higher level of concern when

costs a re greater than 1 percent of a company’ s overall revenue

.

However, NFC has stated that it is currently searching for ways to make the production of crude

PV 23 more efficient to stem market share losses it is currentl y experiencing due to having a product priced higher than competitors ( NFC

, 2014 c ). S hould the company decide that it cannot continue this
line of business or if this line of business suffers because the business line cannot remain competitive

, impacts cou ld be larger for the company. Currently, estimated production volume of PV 23 is 444,910 lbs. At the current selling price of $ [CBI] /lb., this product line is valued at approximately $ [CBI ] million

. Given an estimated total company revenue of $25 million, this product line would represent about [CBI]
percent ($25 million / [ CBI] million ) of the company’s business. 1 Loss of this entire business line would be a significant portion of the company’s overall business and decreased market share could also have

some potential adverse impacts depending on the extent of business loss.

The cost of testing compared to the overall revenue is not at a level that would typically elevate

concern for small business if EPA were evaluating a proposed rulemaking effort. I nformation was not provided with which to assess the level or significance of any impact on volume of sales and percent of
market share specifically from the costs of required testing.

1 Approximately 40 percent of NFC’s manufacturing is toll manufacturing (SOCMA, 2010) and NFC reports that production of CPV23 is toll production for Sun Chemical. Therefore, it is reasonable to estimate that [CBI] percent of revenue is attributable to toll production of CPV23.7

Analysis for Adverse Economic Impacts on a Firm Approach

To evalua te whether there is a potential for adverse economic impacts as a result of the cost of testing, EPA has employ ed (in the rulemaking context) a straightforward approach that compares the annualized cost of the testing to the annualized revenue from sales o f the subject chemical. In general,

t he costs of testing are expected to increase the cost of manufacturing a chemical and could therefore, decrease overall profitability. If profitability falls below an acceptable level, firms may choose to discontinue pr oduction of that chemical, to raise prices of products, or to suffer reduced profitability while testing costs are recouped

.

The profitability of a producing and selling a chemical is measured by the flow of costs and
revenues associated with the chemica l over time. Testing is a short

- term effort. Evaluations of profitability, however, are not only based on one or even a very few years’ results, but rather on the total earnings stream associated (appropriately discounted) with a chemical over time. Thus, losses in one year may be appropriately balanced against revenues in another to assess the net present value of the stream of earnings of a chemical.

The complete net present value analysis of the profitability of a particular chemical with and
without testing costs requires specific information on costs revenues that is difficult to obtain and only limited information was provided in this case . Therefore, this analysis uses a simplified screening approach for the potential of adverse economic impacts b ased on the relationship between testi ng costs
and revenues. Because c hloranil is an intermediate in the manufacture of crude PV 23

, the revenue from

PV 23 sales considered to be the relevant value.

Annualized Costs

Annualized costs represent the amount one would have to pay each year to add up to the same amount as the overall cost of the testing when those costs are presented in present value terms. The standard formula for annualizing a lump sum cost is given by:

A= I x [I ( 1+i) n

– 1)]

where A equals the annualized amount, I is the initial lump sum investment cost, I is the discount rate,
and n is the useful life of the investment.

The Office of Management and Budget’s (OMB’s) economic analysis guidance recommends that analysts use the opportu nity cost of capital for discounting in economic analyses of regulations (OMB, 2003). The discount rate used in this analysis is seven percent and is con sistent with OMB Circular A

- 4. To determine the number of years, n, to use in the annualization formula , EPAB applied a standard estimate for the life of a chemical of 15 years. Under these assumptions, the annualized cost of testing
under to NFC as a result of the required testing is approximately $22,000/yr.

In NFC’s May 16, 2014 memo, they applied a [CBI] time horizon to their cost estimate. NFC indicates that this is a standard time frame for business decisions related to toll manufacturing because
of the short

- term nature of the contracts with customers ( NFC , 2014 c ). According to the USITC (2004)

re port, the toll agreement between Sun and NFC is renegotiated each year for volume and price, and Sun has imported crude PV 23 from China during times when NFC has been switching to new production systems USITC, 2010). Therefore, EPA also estimated annualiz ed costs using a [CBI] time horizon. With a8

[CBI] time horizon (and seven percent discount rate), the estimated annualized cost of testing under the D/F Test Rule requirements is approximately $ [CBI] /yr.

Compare Annualize d Testing Costs to Annual Revenue s

To estimate if the annualized costs of testing could potentially result in an adverse economic impact, the annualized cost of testing is compared to annual revenue from the chemical, in this case, the final product (crude PV 23 ) providing an indicator of the effect on the profitability of the chemical. A threshold of 1 percent was used to determine if there is a potential for an adverse impact on the profitability of the chemical.

The revenue from sales was not provided to EPA, therefore, EPA estimated the value of sales of

PV 23 based on a production volume of 444,910 lbs. (EPA, 2014) and a target selling price of $ [CBI] , for
estimated revenue from the product line of approximately $ [CBI] /year

. Results are presented in Table 2. This revenue was compared to annuali zed costs of testing under a 15

- year and [CBI]

- year scenario to estimate a percentage of revenue impact.

Table 2. Annualized Testing Cost Percent Impact on Annual Revenue
Annualization Years Annual Revenue Annualized Cost Percent of Revenue Impact

15 Years $ [CBI] $ [CBI] [CBI] % [CBI] $ [CBI] $ [CBI] [CBI] %

I n evaluating testing rules, EPA has used a benchmark of 1 percent of annual sales to indicate a
level that could potentially have an adverse effect on the profitability of the product line

. The results of this analysis show that u nder the 15

- year chemical life scenario, the percent impact of testing costs is
well below 1 percent , however, at under the [CBI]

- year time horizon, the estimated impact exceeds 1

p ercent of annual revenues from the chemical

.

A company facing impacts on profitability of a product line may choose a number of options including raising prices to cover the loss, discontinuing (or not implementing) a particular product line, or suffer

r educed profit for a period of time while test costs are recouped. [CBI] Given the price sensitivity of PV

23

, it is less likely that NFC would raise prices to cover the cost of testing and the company could experience some level of profit loss from the PV 23 product line under the [CBI] scenario . And, given the significant portion of business that this product line appears to represent , [ CBI] , it is less likely that NFC

can entirely forego profits to cover the costs of testing , however it is not possible to determine from the information provided if some level of profit loss could be sustained until testing costs are recouped.

Using an approach comparing estimated annualized revenues of the PV 23 product line and the annualized cost of testing to identify the po tential for adverse impacts on PV 23 ’s profitability, it appears that there is a potential for adverse impacts to the profitability of NFC’s PV 23 product line as a result of

test costs . However, the information supplied is insufficient to assess the magnitude of any adverse impact on profits , how long that adverse effect might occur

, the implications of any adverse impact (such as whether impacts are short

- term with a subsequent return to normal or increased profits after testing costs h ave been recouped or are a more permanent effect on profits) , or whether the impact would effectively prevent NFC from import ing the intermediate, c hloranil

.9



## Conclusions

NFC has applied for a waiv er to requirements for testing c hloranil under the D/F Test Rule citing

40 CFR 766.32 (a)(2) (ii) which states that the regulations allow for a waiver from testing if "in the judgment of EPA, t he cos t of testing would drive the chemical substance off the market, or prevent resumption of ma nufacture or import of the chemical substance, if it is not currently manufactured, and
the chemical sub st ance will be produced so that no unreasonable risk will occur due to its manufacture, import, processing, distribution

, use, or disposal

. ” NFC is inte rested in importing c hloranil for the sole purpose of manufacturing crude PV 23 . Currently, t here is one domestic source of c hloranil, Clariant Corporation, who is also a direct competitor with NFC in the crude PV 23 market. Because c hloranil is an

interme diate used to create an end product for NFC, this analysis evaluates the effects of the cost of testing on the end product ( PV 23 ) assuming that it will drive decisions on the intermediate, c hloranil.

NFC is currently in a position whereby a significant portion of its revenues (estimated to be 38
percent ) are derived from a toll agreement to produce crude PV 23 for Sun Chemical. According to NFC, they are currently [CBI] ( NFC , 2014 c ). This was not verified by an observed [CBI] ; however, the most current production volume data are from 2012. Because price plays an important role in customer
decisions about PV 23 suppliers (USITC, 2010), it is not unreasonable to expect that [CBI] . NFC has
identified a process to produce PV 23 at a competitive price ( [CBI] ) that would require using c hloranil. In order to move to this alternative production process, NFC w ould like to be able to import c hloranil directly rather than have to purchase it from Clariant, Corporation

.

Using a standard a pproach for evaluating small business impacts for purposes of rulemaking

, the cost of testing is below one percent of overall company sales

. EPA generally has a higher level of concern when costs are greater than 1 percent o f a company’s overall revenue. S hould the company
decide that it cannot continue this line of business

, or if this line of business suffers because the business line cannot remain competitive, impacts could be larger for the company because of the significance of this business line for N FC. However, under this part of the assessment, the information supplied by NFC did not give EPA a reasonable basis to determine that testing costs would cause the

company to discontinue this business line

. Information was also not provided that EPA could use to assess the level and significance of any impact on volume of sales and percent of market share specifically from the costs of required testing.

EPA also evaluated the potential for adverse impacts on the product line of PV 23 by comparing
the discounted stream annualized of costs to the annual revenue of PV 23 . Assuming a 15 year time frame as the “life of the chemical”, the estimated impact is [CBI] percent of sales. However, assuming a
shorter time frame of [CBI] , which NFC has claimed is the term of a toll contract, the estimated impact is [CBI] percent of the sales of PV 23

. In evaluating testing rules, EPA has used test costs as 1 percent of
annual sales as a benchmark to indicate a level that could potentially have an adv erse effect on the profitability of a product line. While it does appear that there is a potential for an adverse effect on profitability, the information provided did not allow EPA to assess the level of adverse impact on profits, how long that adverse ef fect might occur, the implications of any adverse impact (such as whether impacts are short

- term with a subsequent return to normal or increased profits after testing costs have been recouped or are a more permanent effect on profits), or whether the costs would cause NFC to discontinue the product line and not import the intermediate, chloranil.10

Under EPA’s standard measures for impacts of costs for rulemakings, it seems that there is potential for some adverse effects on the profitability (e.g., reduced or lost profit) of NFC’s PV 23 production line

. However

, the information provided by NFC did not give EPA a reasonable basis to determine the likelihood or level of any potential adverse effect, and thus, did not give EPA a reasonable
basis to determine t hat NFC would be effectively prevented from importing chloranil if it had to pay for the testing of the imported chloranil as specified under the D/F Test Rule

.11 References

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- p

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, to Wendy Cleland

- Hamne t t

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- 1,4

- Dione (Chloranil), 71 Fed. Reg. 75703. March 7, 2007.

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. Accessed July 2,2014.

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- TA

- 437 and 731

- TA

- 1060 and 1061 (Final ). Publication 3744. Washington, DC. December, 2004.

USITC, 2010 . Carbazole Violet Pigment 23 from China and Ind ia Investigation Nos. 701

- TA

- 437 and 731

- TA

- 1060 and 1061 (Review) . Publication 4151. Washington, DC. April 2010.

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