## Ec o o nomic A *



## nalysis o *Interagen cy

Rin2070-A J



## o f the Pr o ch l

(EP A cy Review Dr a

J 36_EO1286



## o posed S

l oro (CA S

A Docket E P

E



## —

Ec o a ft – D o Not C

6_3-Chemic a



## S ignifica n S RN: 71 0

P A-HQ-OPP T

E O 12866 R E



## — Does no t

Economics a

o nomics, Ex p Office of Pol

U.S. Envir o 1200 Pe n Wa s C ite, Quote, o

a l-SNUR-N P



## n t New U s 0 11-12-6)

T -2010-057 3

E VIEW DR A



## t contain T

Prepared

a nd Policy A n

p osure and T e

lution Preve n

o nmental Prot

n nsylvania A v

s hington, DC o r Release D u

P RM_EA-Al k



## s e Rule f

3 )

A FT – 06/15/ 2



## T SCA CB I

by:

n alysis Bran c

e chnology Di v

n tion and To x ection Agenc y

v enue, N.W.

20460 u ring the R ev i

k anes_2011-



## f or Alkan e

2 011



## I

—

c h

v ision

x ics

y i ew**

06-15



## e s, C 12-13 

## ,**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) i Economic and Policy Analysis Branch CONTRIBUTORS

The EPA analyst responsible for this report was Joe Callahan. Analytical and draft preparation support was provided by Abt Associates Inc. under EPA Contract No. EP-W-08-010.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) ii Economic and Policy Analysis Branch ABSTRACT

This report estimates the costs of the U.S. Envi ronmental Protection Agency (EPA)’s proposed Significant New Use Rule (SNUR) for the chemical alkanes, C 12 - 13 , chloro (C 12 - 13 chloro alkanes, Chemical Abstracts Service Registry Number (CAS RN): 71011-12-6). C 12 - 13 chloro alkanes, are short chained chlorinated paraffins (SCPPs); a SCCP is defined as any chlorinated paraffin with a carbon chain length between C 10 and C 13

. The proposed SNUR applies to all manufacturing, import, and processing of C 12-13 chloro alkanes for any use. EPA found no evidence of any manufacturing or importation into the United States of the chemical, and no data was reported in the 2006 Toxic Substan ces Control Act (TSCA) Inventory Update Reporting (IUR) database for C 12-13 chloro alkanes (EPA 2006a). 1 Because the domestic manufacture, import and processing of C 12-13 chloro alkanes has been discontinued, th ere is expected to be no economic impact from the proposed SNUR.

The proposed SNUR would require persons to notif y EPA at least 90 days before commencing the manufacture, import, or processing of C 12-13 chloro alkanes for any signifi cant new use as defined in the SNUR. A firm intending to engage in these activities would be required to submit a Significant New Use Notice (SNUN). EPA is proposing the SNUR because of concerns regarding the environmental fate and the exposure pathways that lead to C 12-13 chloro alkanes presence in wildlife and humans. Because C 12-13 chloro alkanes is not currently manufactured in or im ported into the United States it is important that EPA is notified if a company chooses to produce, import, or process C 12-13 chloro alkanes for any significant new use. The SNUN provides the Agency with an op portunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs.

To submit this SNUN, a firm incurs a modest subm ission cost of $8,112 and potentially other minor costs. However, since no firms have been identified which import, manufacture, or process C 12-13 chloro alkanes for any significant new uses, it is highly unlikel y that any firm will incur this cost. EPA does not require the development of test data for submissi on of a SNUN, although a firm may submit test data already in its possession or describe any other av ailable data. Because EPA does not require the development of test data, EPA assumes that no firms will incur testing costs as a result of the proposed

SNUR.

In addition to the firms that make a SNUN submission, the proposed SNUR may also impact 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. However, th is may not be a concern given that the domestic manufacture, import and processing of C 12-13 chloro alkanes for the uses s ubject to the SNUR have been phased out.

Costs are estimated at the firm level and reflect the burden of a SNUR on the firms that would make a

submission.

1 The IUR compiles production data from manufacturers and importers of certain chemical substances (including

C 12-13 chloro alkanes ) listed on the TSCA Chemical Substance Inventory. Sites are only required to submit IUR data if they manufacture or import more that 25,000 lbs of a chemical during the reporting year. The most recent year
with data available was 2006.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) iii Economic and Policy Analysis Branch TABLE OF CONTENTS

CONTRIBUTORS .................................................................................................................. ....................... i

ABSTRACT ...................................................................................................................... ............................ ii

LIST OF TABLES ................................................................................................................ ....................... iv

1. INTRODUCTION .................................................................................................................. .............. 1

1.1 Background .................................................................................................................... ............. 1
Uses and Su bstitutes .......................................................................................................... ......... 1
Health Effects ................................................................................................................ ............. 2 Environmental Exposure ........................................................................................................ .... 2 Current Manufacturing ......................................................................................................... ...... 3

1.2 Statutory Authority ........................................................................................................... .......... 3

1.3 Summary of Methodology ........................................................................................................ .. 3

1.4 Organization of this Report ................................................................................................... ..... 3

2. INDUSTRY COMPLIANCE COSTS .................................................................................................. 4

2.1 Wage Rates .................................................................................................................... ............. 4

2.2 Unit Industry Compliance Costs ................................................................................................ . 5

2.2.1 Rule Familiarization ...................................................................................................... 5

2.2.2 CDX Registration, CDX Electronic Signat ure, and Pay.gov Account Setup ................ 6

2.2.3 Form Completion and Submission Fee .......................................................................... 7

2.2.4 Recordkeeping ............................................................................................................... 8

2.2.5 Import Certification ....................................................................................................... 9

2.2.6 Export Notification ........................................................................................................ 9

2.3 Industry Costs of SNUR, by Option (per Submission) ............................................................. 11

2.4 Likelihood of a SNUN Submission .......................................................................................... 12

2.5 Potential for Subsequent Regulatory Action ............................................................................ 12

3. AGENCY COSTS .................................................................................................................. ............. 13

3.1 Labor Rates fo r EPA Staff ..................................................................................................... ... 13

3.2 SNUN Processi ng Costs ......................................................................................................... .. 14

3.3 Export Notification Cost ...................................................................................................... ..... 17

4. BENEFITS ...................................................................................................................... .................... 18

5. ADDITIONAL ANALYSES ........................................................................................................... ... 19

5.1 Regulatory Flexibility Act .................................................................................................... .... 19

5.2 Unfunded Mandates Reform Act .............................................................................................. 19

5.3 Paperwork Reduction Act ....................................................................................................... .. 19

5.4 National Technology Transfer and Advancement Act ............................................................. 19

5.5 Executive Order 12898: Federal Actions to Address Environmental Justice in Minority Populations and Low-In come Populations ............................................................................... 20

5.6 Executive Order 13045: Protection of Children fro m Environmental Health Risks and Safety

Risks ......................................................................................................................... ................ 20

5.7 Executive Order 13132: Federalism ......................................................................................... 20

5.8 Executive Order 13175: Consultation and Coordina tion with Indian Tribal Governments ..... 20

5.9 Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use

.............................................................................................................................. .................... 20

6. REFERENCES .................................................................................................................... ................ 21

A. INFLATORS AND WAGE RATES ................................................................................................... .. 26**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) iv Economic and Policy Analysis Branch LIST OF TABLES

Table 1: Loaded Industry Wa ge Rates, December 2009 ............................................................................ ... 5
Table 2: Rule Familiarization Burden and Cost for SNUR Submitters ........................................................ 6 Table 3: CDX Registration, CDX Electronic Signature , and Pay.gov Account Setup Burden and Cost for

First-Time Submitters ......................................................................................................... .......................... 7 Table 4: Industry Cost Estimate to Complete the SNUN Form .................................................................... 8 Table 5: Industry Cost Estimate to Complete and Submit the SNUN Form ................................................. 8 Table 6: Derivation of Total Mailing Cost for 12 Notices ...................................................................... .... 10 Table 7: TSCA 12(b) Export Notif ication Cost per Notification ................................................................ 11 Table 8: Compliance Options and Associated Costs Incurred by a Firm Due to the Proposed SNUR ...... 12 Table 9: Derivation of Loaded Agency Wage Rates ............................................................................... ... 14 Table 10: Derivation of Inflation Factors for Agency Extramural Costs .................................................... 15 Table 11: Agency Costs for SNUN and Ot her Submission Review and Processing .................................. 16 Table 12: TSCA 12(b) Export Notification Co st: Agency Burden per Activity (2009$) ........................... 17 Table 13 : Detail of Labor Categor ies Used in th e Analysis .................................................................... ... 26
Table 14: Derivation of Loaded Wage Rates ..................................................................................... ......... 28
Table 15: Derivation of Inflation Factors ..................................................................................... .............. 30**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 1 Economic and Policy Analysis Branch 

### 1. INTRODUCTION

This report presents the U.S. Environmental Protecti on Agency (EPA), Office of Chemical Safety and Pollution Prevention’s (OCSSP’ s) analysis of the potential costs incurred as a result of a proposed Significant New Use Rule (SNUR) the chemical alkanes, C 12 - 13 , chloro (C 12 - 13 chloro alkanes, Chemical Abstracts Service Registry Number (CAS RN): 71011-12-6). C 12-13 chloro alkanes is a short chained chlorinated paraffin (SCPP); a SCCP is defined as any chlorinated paraffin with a carbon chain length

between C 10 and C 13 . SNURs are proposed by EPA under the authority granted by Section 5(a)(2) of TSCA. The proposed SNUR would require persons to notify EPA at least 90 days before commencing the manufacture, import, or processing of C 12-13 chloro alkanes. EPA promulgates a SNUR for a substance when potential uses could result in increased exposur e to, or releases of, the substance which in turn, could present an unreasonable risk to health or the environment.

1.1 Background

As part of EPA’s efforts to enhance the existing chemicals program under TSCA, the Agency identified an initial list of widely recognized chemicals for th e development of Action Plans based on one or more of the following factors: presence in humans; persiste nt, bioaccumulative, and toxic (PBT) characteristics: use in consumer products; and production vo lume. SCCPs were selected because they 

### are bioaccumulative in wildlife and humans, are persiste nt and transported globally in the environment, and toxic to aquatic organisms at low concentrations. The Action Plan summarized all readily available use, exposure, and hazard information for SCCPs, considered which authorities provided under TSCA and other statutes could be used to address potentia l concerns; and described various courses of actions available to EPA to address the concerns (EPA 2009c).

Uses and Substitutes

The largest use of SCCPs in the United States is as a component of lubricants and coolants in metal cutting and metal forming operations. The second-larg est use is as both a secondary plasticizer and a flame retardant in plastics, especially polyvinyl chlori de (PVC). Other minor domestic SCCP uses are as a plasticizer and a flame-retardant additive to a variet y of products including: rubber formulations, paints and other coatings, and adhesives and sealants (CPIA, 2009). For safety reasons, other countries (those in the European Union and Canada) have allowed SCCPs to be used as a flame retardant in underground mining conveyor belts (rubber formulations) and fi re retardants in dam sealants (ECHA 2008a).



### Medium chained chlorinated paraffins (MCCP; C 14-17 

### alkyl chain) are alternatives to SCCPs for many applications. Based on their physical-chemical properties, MCCPs are also expected to be persistent in the environment and several field surveys have shown they are present in sediments and biota, demonstrating their release to and persistence in the environment. Field-measured bioaccumulation factors (BAFs) that are greater than 5000 and 

### biomagnification factors (BMF) greater than 1 indicate that MCCPs are bioaccumulative in biota and can biomagnify in f ood chains (UNEP, 2009). MCCPs have toxicity to sensitive aquatic organisms that is similar to SCCPs. Canada has concluded that MCCPs are “toxic” as defined by the Canadian Environmental Protection Act (CEPA) (Government of Canada 2008). The European Union’s 2005 Risk Assessment Report and 2007 draft update conclude that there is a need for limiting the risks posed by certain us es of MCCPs in the production of PVC and metal cutting (EC, 2005, 2007).

Long-chained chlorinated paraffins (LCCP; generally C 18 - 28 

### ) appear to have been used as alternatives to SCCPs in some of the more demanding metal working applications (HELCOM, 2002). LCCPs also appear to have potential as an alternative in leather, paints and coatings, sealants and**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 2 Economic and Policy Analysis Branch 

### rubber applications. LCCPs are expected to be persistent and bioaccumulative in the environment based on their physical-chemical properties and bi oaccumulation modeling, respectively. Canada has concluded that LCCPs up to C 20 

### are “toxic” as defined by CEPA (Government of Canada 2008). Canada has not made a determination of whether LCCPs greater that C 20 

### are toxic.

A number of other potential alternatives, e.g. nitroalkanes, alkyl phosphate and sulfonated fatty acid esters and vegetable oil based products, are available for specific applications. It is stated that thesealternatives are considered less harmful than chlorinated paraffins (UNECE, 2006). These nonchlorinated paraffin alternatives are often more expensive and may require special handling. A UK estimated cost for completely converting SCCPs to non-SCCPs in metal working was predicted to be four million £ per year (IRTA, 2004). An analysis of costs conducted in California found that overall metal working processing costs were more expensive for the SCCP alternatives but including other associated costs (clean up and waste removal) ma de the non-SCCP alternatives competitive (IRTA, 2004).

Health Effects

Acute toxicity of SCCPs (C 10-13 ) is very low (EC, 1999; UNEP, 2009). SCCPs may cause skin and eye irritation upon repeated application, but do not a ppear to induce skin sensitization (EC, 1999; UNEP, 2009). There was no evidence of developmental effects in prenatal developmental toxicity studies in rats and rabbits (EC, 1999; UNEP, 2009).

The liver, kidney and thyroid are major target organs in repeated-dose studies with rats and mice. When administered by gavage, chlorinated paraffins (C 12 , 60 percent chlorine) are carcinogenic in rats and mice of both sexes (NTP, 1986a; 2005). The underlying mechanisms for the carcinogenicity of SCCP in rats and mice are not clearly known. SCCPs were not mu tagenic to bacteria with or without metabolic activation (NTP 1986a, b). There are some indications that the SCCP-induced kidney tumors in male rats are associated with alpha 2 μ -globin accumulation in hyaline droplets, a mode of action unique to male rats and irrelevant to humans, but this could not be confirmed by immunocytochemical techniques. There are also data showing that the liver toxicity/car cinogenicity induced by SCCP is associated with peroxisome proliferation, whereas the thyroid e ffects are correlated to altered thyroid hormone homeostasis. A number of scientific working groups, including the International Agency for Research on Cancer (IARC), have concluded that liver tumors indu ced by peroxisome proliferators are not relevant to humans (IARC, 1990; Klaunig et al., 2003). Humans are expected to be much less sensitive to thyroid hormone perturbation than rats and mice.

There is no experimental evidence using human data that demonstrates the carcinogenicity of SCCPs. In the 11th Report on Carcinogens, NC I lists chlorinated paraffins (C 12 , 60 percent chlorine) as reasonably anticipated to be human carcinogens based on sufficient evidence of carcinogenicity in experimental animals (NTP, 2005). They are classified by the IARC as Group 2B - possibly carcinogenic to humans based on sufficient evidence of carcinogenicity in expe rimental animals and mechanistic considerations (IARC, 1990).

Health Canada and Environment Ca nada have characterized all chlo rinated paraffins (SCCPs, MCCPs and LCCPs) as “toxic” under CEPA (Government of Canada 2008).

Environmental Exposure

SCCPs are highly toxic to aquatic invertebrates fo llowing acute (48-hr EC50 = 0.043 to 11 mg/L) and chronic (NOEC = 0.005 to 2 mg/L) exposures. In fish high toxicity is associated with chronic exposures, but not for acute exposures (96-hr LC50 = 300 to 10,000 mg/L and NOEC = 0.0096 to 0.05 mg/L). For**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 3 Economic and Policy Analysis Branch aquatic plants, there is high toxicity associated w ith both acute and chronic exposures to SCCPs (96-hr EC50s range from 0.043 to 0.39 mg/L and NOEC ranges from 0.012 to 0.39 mg/L) (UNEP, 2009).

Both Health Canada and Environm ent Canada have characterized a ll chlorinated paraffins (SCCPs, MCCPs and LCCPs) as “toxic” under CEPA (Government of Canada 2008).

Current Manufacturing

The current use of chlorinated paraffins (SCCP, MCCP , and LCCP) in the United States is on the order of 150 million pounds per year. Production of short-chain and medium-cha ined chlorinated paraffins (C 9 to
C 17 ) was 100 million pounds in 2007. A very small fraction of that numbe r is attributable to import/export business. According to the Chlorinated Paraffins Industry Association, MCCPs represent the largest production and use of chlorinated paraffins in Nort h America while SCCPs is only half that volume (CPIA, 2009). In the United States, Dover Chemical Corp. is the sole manufacturer of chlorinated paraffins and several companies import chlorinated paraffins according to 2006 IUR data (EPA, 2006). However, no 2006 IUR data has been reported for C 12-13 chloro alkanes (CAS RN 71011-12-6) and EPA found no additional evidence of any importation or manufacturing of the chemical. It therefore appears, there is no current manufacture or importation of C 12-13 chloro alkanes in the United States.

1.2 Statutory Authority

Section 5(a)(2) of TSCA (15 U.S.C. 2604(a)(2)) author izes 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 se ction 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 Significant New Use Notice (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.

1.3 Summary of Methodology

This analysis quantifies, to the extent possible, the co sts to society of the propo sed rule by identifying the costs to industry associated with performing the requi red reporting and recordkeeping, 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; co llection, compilation, and submission of required information for significant new uses of the subject ch emicals; 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 from previous information collection requests and economic analyses for related rules, compensati on data acquired from government publications, and supplementary market research.

1.4 Organization of this Report

The remainder of this report provides EPA’s economic analysis in support of the proposed rule. Chapter

Error! Reference source not found. presents estimates of the costs incurred by manufacturers, importers, and/or processors under the SNUR options. Ch apter 3 shows estimates of the government costs associated with the administration of the proposed ru le. Chapter 4 discusses the benefits of the proposed rule. Chapter 5 presents an analysis of other impacts, as required by various statutes and executive orders.

Note that all dollar amounts in this analysis are reported in fourth quarter 2009 dollars.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 4 Economic and Policy Analysis Branch 

### 2. INDUSTRY COMPLIANCE COSTS

The proposed SNUR discussed in this report specifies that significant new uses of C 12-13 chloro alkanes be reported under section 5(a)(2)(A) of TSCA. A signifi cant new use is defined as the manufacturing, importation, and/or processing C 12-13 chloro alkanes for any use. A firm intending to manufacture, import, and/or process C 12-13 chloro alkanes for any significant new u se must submit a SNUN. Alternatively, a firm can decide not to manufacture, import, and/or process the chemical for 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 the chemical for a signifi cant new use, which, in this case, means the manufacturing, importing, and/or processing of this chemical for any use. The firm must submit the SNUN to EPA at least 90 days before it plan s to commence the manufacture, import, and/or processing of the substance; the SNUN provides EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activ ity before it occurs. If EPA allows the manufacture, import, or processing of C 12-13 chloro alkanes for the intended use, then the costs associated with this option are the costs of submitting the SNUN (including a user fee) plus, if there is any export of these products, the export notification costs that result from TSCA Section 12(b) requirements that are automatically triggered for chemicals regulated unde r TSCA Section 5 (see Section 2.2.6 for details). Because the domestic manufacture, import and processing of C 12-13 chloro alkanes for the uses subject to the SNUR have been phased out, EPA exp ects that no firms will choose this option.

• Option 2: Decide not to manufacture, import, and/or process the chemical . The firm may decide simply not to proceed to manufacture, import, and/ or process the chemical. While this option avoids the costs of submitting a SNUN, it entails the ‘hidde n’ cost of the profit that will be foregone as a result of not engaging in the commercial activity origin ally planned. Similarly, if the firm would have used a given amount of C 12-13 chloro alkanes in the production of another product, and must substitute to a more costly substance, it will incur those add itional “hidden” costs of production. However, these hidden costs are expected to be minimal, if not zero, because C 12-13 chloro alkanes is not currently manufactured in the United States. If the firm elects to produce C 12-13 chloro alkanes for research and development (R&D) purposes only (an exempti on for R&D purposes is provided in 40 CFR §721.47), it may have costs associat ed with R&D recordkeeping.

Because the domestic manufacture, import and processing of C 12-13 chloro alkanes for the uses subject to the SNUR have been phased out, EPA does not expect th ere to be compliance cost associated for either of the options. The remainder of this chapter estimates the quantified portion of costs associated with the proposed SNUR. Section 2.1 summarizes the wage rates used in this chapter. Section 2.2 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 cost s under each option are presented in Section 2.3.

2.1 Wage Rates

The proposed rule involves activities that may require efforts by employees in three labor classifications: managerial, technical, and clerical. Costs for each act ivity are calculated by estimating the labor hours required in each labor category and multiplying those burdens by the wage rate for each labor category. This section presents the estimated wa ge rate in each labor category.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 5 Economic and Policy Analysis Branch Loaded wage rates for managerial, technical, and clerical personnel are derived by combining data on wages and fringe benefits with estimates of overh ead 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 in December 2009 are provided by the Employer Costs for Employee Compensation (ECEC) Supplemental Tables availabl e on the BLS website (BLS 2010a). The loaded wage rate for managerial labor is $68.24; for techni cal labor, $59.49; and for clerical labor, $28.31. Table 1 presents the basic data used to calculate the lo aded wage rates for all three categories of labor.

Table 1: Loaded Industry Wage Rates, December 2009

Labor Category Data Sources Wage (2009$) Fringe

Benefit (2009$) Fringes

as %

wage Overhead %

wage 2 Fringe +

overhead

factor Loaded Wages 1
(2009$)

(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 $42.36 $18.68 44.10% 17% 1.61 $68.24

Professional/

Technical BLS ECEC , Private Manufacturing industries,
“Professional and related“ 3 $35.96 $17.42 48.44% 17% 1.65 $59.49

Clerical BLS ECEC , Private Manufacturing industries,
“Office and Administrative Support” 3 $17.21 $8.17 47.47% 17% 1.64 $28.31

1 Wage data are rounded to the cl osest pennies in this table.

2 An overhead rate of 17% 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 Amen ded Inventory Update Rule: Final Report (EPA, 2002a).

3 Employer Costs for Employee Compensa tion Supplementary Tables: December 2009. US Bureau of Labor Statistics, March 10, 201- (BLS 2010a).

2.2 Unit Industry Compliance Costs



### 2.2.1 Rule Familiarization

The proposed rule requires submitters and their staff to become familiar with the SNUR and its various requirements. The per company burden associated with rule familiarization is approximately 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). As shown in Table 2 the total

labor cost associated with rule familiari zation by a first-time reporter is $50.92.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 6 Economic and Policy Analysis Branch Table 2: Rule Familiarization Burden and Cost for SNUR Submitters

Reporting Activity Clerical Labor (at $28.31/hour) Technical Labor (at $59.49/hour) Managerial Labor (at $68.24/hour) Total Labor Cost

Burden (hours) Cost (2009$) Burden (hours) Cost (2009$) Burden (hours) Cost (2009$) Burden (hours) Cost (2009$) Rule Familiarization 0.00 $0.00 0.55 $32.72 0.27 $18.20 0.82 $50.92 Total 0.00 $0.00 0.55 $32.72 0.27 $18.20 0.82 $50.92

Source : BLS 2010a (labor rates); EPA 2009a (burden hours)



### 2.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup

The proposed SNUR requires first-time submitters (that is, those companies who have not submitted information to EPA through CDX before) to register their company and key users with the CDX reporting tool, deliver a CDX electronic signature to EPA, a nd establish and use a Pay.gov E-payment account. 2
These activities are only required of first-time submitters (companies already registered with CDX would not need to re-register for the purposes of complyi ng with the proposed SNUR). The burdens associated

with these activities were estimated in the Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009a) and are described in more detail below:

• CDX registration: EPA estimates that companies will spend approximately 0.18 hours per employee to register with CDX, and that an average of f our technical staff members and one manager will need to register for each company, totaling approxi mately 0.92 hours of burden per company.

• CDX electronic signature: EPA estimates that companies will spend 0.25 hours preparing, submitting, and filing an electronic signature agreemen t (Authentication of Identity) form to EPA per employee. This burden will apply to four techni cal staff members and one manager per company, totaling to 1.25 hours of burden per company. In addition, EPA est imates that a manager will spend 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 then verifying electronic signature ag reements is 1.75 hours. Note that this burden does not include any additional time required to cont act EPA’s CDX help desk to notify of a change of submitter status, should one occur. Filing the electronic signature agreement requires an additional mailing cost of $2.30 per company (including five $0.44 stamps and five $0.02 business envelopes) (USPS 2010).

• Payment via Pay.gov account: EPA estimates that one manager per company will 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 do es not include the time required to click ‘submit’ on the form and wait for payment processing.

As shown in Table 3, the cost associated with C DX registration, CDX electronic signature, and Pay.gov account setup is $178.21, and this cost is only incurred by a first-time submitter.

2 Although the proposed rule does not specifically require submitters to establish and use a Pay.gov account, the burden estimates in this analysis are conservative insofar as to include the use of Pay.gov as a required activity.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 7 Economic and Policy Analysis Branch Table 3: CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup Burden

and Cost for First-Time Submitters

Reporting Activity Clerical Labor (at $28.31/hour) Technical Labor (at $59.49/hour) Managerial Labor (at $68.24/hour) Total Cost

Burden (hours) Cost (2009$) 1 Burden (hours) Cost (2009$) 1 Burden (hours) Cost (2009$) 1 Burden (hours) Cost (2009$) 1 CDX Registration 0.00 $0.00 0.73 $43.63 0.18 $12.51 0.92 $56.13

CDX Electronic Signature 0.00 $0.00 1.00 $59.49 0.75 $51.18 1.75 $110.67

Mailing Cost $2.30 E-Payment (Pay.gov ID) 0.00 $0.00 0.00 $0.00 0.13 $9.10 0.13 $9.10

Total 0.00 $0.00 1.73 $103 1.07 $72.79 2.80 $178

Notes: Costs may not equal labor wage rate times burden hours due to the rounded burde n estimate presente d in the table,

unrounded estimates were used during the cost calculations.
Source : BLS, 2010a (labor rates); EPA, 2009 a (burden hours); USPS, 2010 (mailing cost)



### 2.2.3 Form Completion and Submission Fee

Respondents are required to gather and submit informa tion regarding the data elements identified in the applicable SNUN reporting form. The methodology and calcu lations used in this analysis assume that the employee responsible for collecting, filling out, and submitting the requested information has a reasonable level of familiarity with the company a nd knowledge of operations at the site. It is assumed
that for most entities these tasks are similar to othe r employee duties that require familiarity with EPA, State, and other Federal agency requests for chem ical information and do not require additional familiarization or training beyond the basic rule familia rization described above. In addition, this analysis focuses on the marginal costs of submitting information for the proposed rule an d not the total costs for the company to comply with a range of other Fe deral and State environmental, health, and safety regulations or accounting requirements that rely on this type of information.

Estimates of the costs of completing a Significant New Use Notice (SNUN) form are based on the costs of completing a Premanufacture Notification (PMN) s ubmission, since the data requirements are the same

and the same form is used for both. The PMN submission costs are based on EPA's 1994 Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications and the updates to this estimate in 2009 (EPA 2009a)

. The original 1994 estimates 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). 3 The 1994 estimates were based on a survey conducted by the Chemical Manufac turers Association, whic h became the American Chemistry Council. These burdens “include the time sp ent 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). 4
The burden associated with SNUN submission and pr eparation 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 burden associated with preparing a SNUN (EPA 2009a) 5 . In addition, electronic

3 Table III-2 and pages III-11, -12, and -13.

4 p. III 11-13

5 The Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009a)
estimates a 0.5 hour clerical burden and a 0.5 hour technica l burden associated with recordkeeping in addition to the**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 8 Economic and Policy Analysis Branch submission is expected to generate an additional 0. 18 hours of technical burden, for the completion of the User Fee Payment Identification Number and email address data elements on the electronic SNUN form.

SNUN form completion and electronic submission is estimated to require 73.68 hours of technical labor and 18.00 hours of managerial labor. Table 4 combin es 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 larg e and small business s ubmitters is $5,612.

Table 4: Industry Cost Estimate to Complete the SNUN Form

Reporting Activity Clerical Labor (at $28.31/hour) Technical Labor (at $59.49/hour) Managerial Labor (at $68.24/hour) Total Labor Cost

Burden (hours) Cost (2009$) Burden (hours) Cost (2009$) 1 Burden (hours) Cost (2009$) 1 Burden (hours) Cost (2009$) 1 Form Completion 0.00 $0.00 73.68 $4,414 18.00 $1,228 91.68 $5,612

Notes: Costs may not equal labor wage rate times burden hours due to the rounded burde n estimate presente d in the table,
unrounded estimates were used during the cost calculations.

Source :
1 Loaded wages include fringe benefits and overhead. See Appendix A of this report for derivation. Wage rates presented in this table are rounded values; however, unr ounded values are used to calc ulate total labor costs. For this reason, total labor costs may not equal the product of rounded values.

2 The estimate of no clerical burden is taken from the Economic Analysis of the Premanufacture Notice Electronic Reporting Final Rule (EPA, 2009a, page 7)

3 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 Electr onic SNUN form (EPA, 2009a page 15).

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 subm ission fee. Table 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 $8,112 for large business submitters and $5,712 for small business submitters.

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

Reporting Population Labor Cost Submission Fee Total Cost (2009$) Large Business Submitters $5,612 $2,500 $8,112 Small Business Submitters $5,612 $100 $5,712

Source : EPA, 2009a.



### 2.2.4 Recordkeeping

Companies submitting a SNUN must keep records under 40 CFR §721.40. Some EPA reports have assumed that SNUN recordkeeping hours would be five percent of SNUN submission hours, or about five

burden estimates from the 1994 RIA, which include the burden for recordk eeping (EPA, 1994, p. III-14). These
burden estimates are based on the reco rdkeeping burden for polymer exemptions and not the recordkeeping burden associated with PMN submissions. Therefore, for this an alysis we assume that any reduction in recordkeeping burden is captured in the reduction of th e clerical burden, and we do not consid er the one hour r ecordkeeping burden from the ePMN EA in order to avoid double counting.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 9 Economic and Policy Analysis Branch to six hours .6 For this report, the SNUN recordkeeping hours were included in the SNUN submission hours (see Section 2.2.3) and the SNUN recordkeeping costs under 40 CFR §721.40 were not separately
estimated. 7



### 2.2.5 Import Certification

In general, promulgation of a final SNUR trigge rs 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 substances. Thus, any U.S. manuf acturer, 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 substances in the shipment are not subject to TSCA. 8 The statement must be on or attached to a commercial invoice or entry document belonging to the imported shipment.

In practice, import certification is fulfilled by checking a box on an invoice or entry document and generally imposes no additional burden or cost on the importer (EPA 2009b). Any potential burden

associated with a submitter’s familiarization with this requirement is assumed to be included in the more general SNUR familiarization burden discussed above.



### 2.2.6 Export Notification

Under Section 12(b) of TSCA, exporters must notify EPA if they export or intend to export a chemical or an article 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 rul es) and certain other TSCA sections, this is a onetime notification requirement 9 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 bur den associated with making export notifications, EPA first estimated the average annual number of export no tifications made by an exporter. EPA then derived the annual and per notification burden associated wi th preparing and submitting an export notification.

6 For example, OPPT’s Information Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules for Existing Chemicals (Renewal), October 11, 2005, estimates SNUN reco rdkeeping costs at 5.67 hours (ICR 118.08, page 10).

7 SNUN submission costs estimated in Section 2.2.3 of this report were based on PMN submission costs from a 1994 report, Regulatory Impact Analysis of Amendments to Regulations for TSC Section 5 Premanufacture Notifications (EPA, 1994). Page III-14 of the 1994 report refers to “the normal records kept with a PMN submission

which are included in the estimates fo r submission costs.” Page III-12 iden tifies “maintaining a file of the submission” as part of the labor hours for the PMN reporting form. These statements imply that the 95 to 114 total hours for a PMN submission (page III-10 of EPA 1994) included recordkeeping hours.

8 The exact statements are as follows: Fo r imports of chemical substances su bject to TSCA, “I certify that all chemical substances in this shipment comply with all applicable rules 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 this shipment are not subject to TSCA.” (40 CFR 707.20)

9 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 country for each exporter (November 14, 2006, 71 FR 66234).**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 10 Economic and Policy Analysis Branch Exporter Costs 10

The 2009 TSCA Section 12(b) ICR estimated the annual export notification cost for an exporter under the one-time export notification requirement (EPA 2009b). 11 These costs include the co st to the exporter of compiling a list of their products that are subject to TSCA Section 12(b) requirements, writing or revising an export notification letter to EPA, checking the outgo ing shipments, and sending the notification letters with the associated shipping costs.

The per-notification cost was calculated based on the assumption that the average exporter makes 12 notifications per year

. 12 Exporters making more notifications per year may benefit from economies of scale and have lower costs per notification; those ma king fewer notifications may have higher costs per

notification.

Estimated Submission (Mailing) Costs . Regulated companies will incur mailing costs for export

notifications delivered to EPA. Notifications are ass umed shipped via the U.S. Postal Service (USPS) as first-class registered mail with a return receipt (USPS 2010). The estimated per-shipment and annual mailing costs incurred by individual submitters are detailed in Table 6.

Table 6: Derivation of Total Mailing Cost for 12 Notices

Dates that the rates were verified on United States Postal Service web site: April 2010

Postal services costs
Registered mail, regular, with $0 declared value $10.60
Return receipt, requested at time of mailing (receive by mail) $2.30

Postage, regular First Class, up to 1 ounce $0.44

Cost per export notice – Subtotal $13.34

Source : Mailing rates are from the US Postal Service web site as of April 2010 (http://www.usps.com/prices/). The mailing
method comes from the Economic Analysis of the Proposed Change to TSCA Section 12(b) Export Notification Requirements , November 2005 (EPA, 2005), as clarified in a late r SNUR economic analysis (EPA, 2007a, Table 8).

Compile and Maintain the List of Products. Since TSCA §12(b) information collection activity has been in place for twenty years, most respondents will have al ready 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 propor tion of legal time (EPA 2009b). The total burden can vary from two hours per year up to two hours per m onth, depending on the numbe r of products exported by the company and the number of their products subject to TSCA §12(b) (EPA 2009b).

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

10 Most underlying data in this section come from th e 2009 TSCA Section 12(b) ICR, ICR No.: 0795.13 [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 2009b), with updating for inflation.

11 Page 11, Table 3

12 EPA calculated the average number of export notifications per exporter in the 2009 TSCA Section 12(b) ICR (EPA 2009b) by dividing the estimated number of submitted notifications (3,500) by the estimated number of exporters (300).**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 11 Economic and Policy Analysis Branch include some proportion of legal time) per firm per y ear for 12 notifications per year, or 0.08 hours per notification (EPA 2009b).

Check Orders and Send Notifications . Companies that export chemicals subject to TSCA §12(b) reporting must check outgoing shipments against the list of th eir products described above. A form letter notifying EPA and providing the required data must be printe d and mailed within the required time period. This process is estimated to take an average one half hour of clerical time per export notification (EPA 2009b).

The burdens and associated costs for each notifica tion activity are provided in Table 7 below.

Table 7: TSCA 12(b) Export Notification Cost per Notification

Technical Clerical Total

$/Hr Hours 2009$ 3 $/Hr Hours 2009$ 3 Hours 2009$ 3

Compile list $59.49 0.78 $46.08 -- -- -- 0.78 $46.08

Write letter $59.49 0.08 $4.96 -- -- -- 0.08 $4.96

Check order and send

notice -- -- -- $28.31 0.50 $14.17 0.50 $14.17

Mailing cost 1 -- -- -- - $13.34 Total per notification 0.86 $51.04 0.50 $14.15 1.36 $78.54

Notes:

1 Mailing costs reflect April 2010 USPS rates and can be found in Table 6.

2 Per notification costs are based on an average f acility submitting 12 export notifications per year.

3 Costs may not equal labor wage rate tim es burden hours due to the rounded burden es timate presented in the table, unrounded estimates were used during the cost calculations.
Source: ICR No.: 0795.13 [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 2009b, p.10), and are updated to 2009 dollars.

2.3 Industry Costs of SNUR, by Option (per Submission)

The number of firms affected by not making submissions to EPA is not known; therefore, costs are not aggregated across the affected entiti es. Table 8 summarizes the costs to co mply with the proposed rule, as

described in more detail in section 2.2 above.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 12 Economic and Policy Analysis Branch Table 8: Compliance Options and Associated Costs Incurred by a Firm Due to the Proposed SNUR

Option 1 Costs Quantified Costs per Chemical (2008$) 2

1. Electronic submission of a Significant New Use Notice (SNUN), indicating to EPA that
the firm would like to manufacture, import, or process the
chemical for a Significant New Use

as defined in the

SNUR. Costs of electroni cally submitting a SNUN, including rule familiarization, CDX registration (for companies that are first-time submitters), form completion, user fee, export notification cost (if relevant). Rarely, a firm may choose to conduct toxicity or fate testing to support the SNUN, but such testing is not required by law. $50.92 rule familiarization cost; $8,112 submission cost (including SNUN recordkeeping and $2,500 fee). EPA usually receives well under ten SNUNs per year. Based

on review of recent SN UNs, it appears that firms rarely conduct toxicity or fate testing to support a SNUN (such testing would be voluntary). 3 Export notifications costs are estimated at $78.56 per notification; total cost per company will vary. First time submitters would incur $178 for CDX registration and

associated activities.

2. Decide not to manufacture, import, or process thechemical for any nonexempt uses. Cost of the profit foregone as a result of not engaging in the commercial activity originally planned (opportunity costs). Other costs include rule familiarization, and export notification costs. Opportunity costs are not quantified. Other costs include rule familiarization ($50.92), and export notification costs ($78.56 per notification) would apply.

Notes:

1 Firms may be subject to both options at once since submis sion 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 2.2.

3 EPA does not require the development of test data for submission of a SNUN, although a firm may submit test data already in its possession and/or describe any other available data. Because EPA does not require the development of test data, EPA assumes that no firms will incur testing costs as a result of the proposed SNUR.

2.4 Likelihood of a SNUN Submission

Because the domestic manufacture, import and processing of C 12-13 chloro alkanes for the uses subject to the SNUR have been phased out (see Section 1.1), ve ry few, if any, entities are expected to submit a

SNUN.

2.5 Potential for Subsequent Regulatory Action

EPA recognizes that if submission of a SNUN does result from the proposed SNUR, the Agency may take additional regulatory actions under TSCA. These a dditional regulatory actions might be necessary to

further evaluate an intended new use and associated activ ities, or to prohibit or li mit 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 such actions are highly dependent on the circumstances surroundi ng the individual SNUN (e.g., available information and sci entific understanding of the chemical and its risks at the time the SNUN is being reviewed).

Should EPA’s review of the SNUN result in furthe r regulatory actions, the Agency will initiate and follow the appropriate procedures for taking those ac tions. Included in those procedures would be an

assessment of the costs and benefits of those actions.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 13 Economic and Policy Analysis Branch 

### 3. AGENCY COSTS

As described in the following sections, EPA’s co sts to review and process SNUN submissions are

assumed to be the same as EPA costs to review PMNs.

3.1 Labor Rates for EPA Staff

Agency labor costs are calculated based on annua l Federal salaries for the Washington-Baltimore area published by the Office of Personnel Management effective January 2009 (OPM 2009). EPA assumes that, on average, a federal GS-13, Step 5 full-tim e equivalent (FTE) will conduct its collection and administrative activities under the proposed rule. 13 The average salary for a GS-13 Step 5 employee was $98,518 in 2009 without fringe benefits and overhead cost s. In order to derive the fully loaded salary, EPA multiplied the annual salary by an assumed loading f actor of 1.6 to reflect federal fringe benefits and overhead, which results in a fully loaded annual sal ary of $157,629 (see Table 9). Dividing the fully loaded annual salary by 2,080 hours (i.e., the num ber of hours in a work year) yields an hourly FTE compensation wage rate of $75.78.

The Agency loading factor of 1.6 is from an EPA guide entitled Instructions for Preparing Information Collection Requests (ICRs) (EPA 1992). 14 The 60 percent assumption was labeled “the benefits multiplication factor” in the EPA guide, but has been used in many EPA OPPT ICRs to reflect both fringe benefits and overhead for federal staff. For exampl e, it was used in a document supporting EPA ICR No. 1139.06 (EPA 2000), 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 only benefits

but also overhead.

Fully loaded costs for Agency labor are shown in Table 9.

13 The GS-13 Step 5 is consistent with ICR No. 0574.14 (12/18 /2007) (EPA, 2007b), which covers PMN SNURs. Use of this grade level follows the approach introduc ed in EPA, 2007b. That report represente d a change from an earlier PMN SNUR economic analysis (EPA, 2003), which used an averag e of GS-12 Step 1 and GS-12 Step 10 salaries.

14 page 30, footnote 9.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 14 Economic and Policy Analysis Branch Table 9: Derivation of Loaded Agency Wage Rates

Labor Category Data Source for Wage

Information 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 WashingtonBaltimore-NorthernVirginia, DC-MD-PAVA-WV, area, GS-13

Step 1 pay rates a Dec09 $98,518 (annual)

-- [Included
in 60% overhead] 60% b 1.60 $157,629 (annual)

$47.36 (hourly) $75.78 (hourly)

Notes :

a The Agency salary is the unloaded federal GS-13 Step 5 salary ($98,518 for 2009), from the OPM salary table for the Washington-Baltimore-Northern Virginia Lo cality Pay Area (OPM 2009). Hourly rate s are based on annual salary divided by 2,080 hours.

b The 60% fringes-and-overhead rate is fro m an EPA guide, Instructions for Prepari ng Information Collect ion Requests (ICRs) (EPA 1992, page 30, footnote 9).

3.2 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 pro cessing PMN submissions in a1994 EPA report entitled, Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications (EPA 1994). 15 The Agency burden associated with pr ocessing a PMN has been adjusted to reflect burden reductions resulting from the 2009 fi nal PMN Electronic Reporting (ePMN) Rule that requires the electronic submission of all TSCA section 5 notices. Electronic submission of SNUN forms is expected reduce Agency burden by 16.5 percent (EPA, 2009a). 16

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

The Extramural Cost column shows costs for contractor support and other outside purchases for chemicals requiring the selected review step is inflated from 1993 prices using the Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) da ta (BLS 2010b). The not seasonally adjusted ECI for total compensation of private industry professional and related workers (Series ID CIU2010000120000I) is used because it is the only series with continuous data since 1985, and that includes professional and technical labor, which perform the majority of Agency extramural activities. Table 10, below contains the derivation of inflation factors for Agency extramural costs.

15 Table VII-1.

16 p.28.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 15 Economic and Policy Analysis Branch Table 10: Derivation of Inflation Fa ctors for Agency Extramural Costs

Item Inflation index source Starting

year Index for starting

year

(a) Index
for

2009

(b) Inflation

factor (b)/(a) 2

Agency Extramural costs White collar labor; equipment; supplies BLS ECI, Total comp, Private industry, Professional and related

, 4 th Q [BLS 2010d] 4 1993 67.0 111.4 1.663

Source:
Bureau of Labor Statistics. Employment Cost Index – Total Compensation: Professional and Related Private Industry, Not Seasonally Adjusted. (Series ID: CIU2010000120000I) , extracted April 12, 2010 (BLS 2010b).

The Percent of Cases column in Table 11 is a weighti ng factor applied to reflect the fact that not all chemicals require each review step. For exampl e, in the PMN process, all chemicals require Administrative Prescreening, but not all chemicals requ ire 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. Cha nges 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 require d in the first place. However, often a SNUN may take more Agency time than a typical PMN because of fact ors such as the need to retrieve old PMN records from archives, and the likelihood that more data re quiring EPA review is submitted with a SNUN than would be submitted, on average, with a PMN. Resour ces 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, the review steps and weighting factors are assumed to be the same as those derived in 1994 for PMNs.

The Weighted Cost column is calculated by multiply ing the un-weighted Costs (EPA staff cost plus extramural costs) by the percentage of cases requiring this review step. Weighted costs are then multiplied by the burden reduction of 16.5 percent to account for burden savings generated electronic submission. As shown in Table 11, this calculation yields tota l Agency costs of $4,934, per SNUN, for submission review and processing.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics(CAS RN): 71011-12-6) 16 Economic and Policy Analysis BranchTable 11: Agency Costs for SNUN and Other Submission Review and ProcessingReview StepsEPA staff (FTE) CostExtramural Cost2UnweightedCostPct. ofCasesWeightedCost3ePMNBurdenReduction4Weighted Costwith ePMNBurden ReductionFTEfractionCost perFTE1FTE Total($2009)1993dollars2009dollars(a)(b)(c)=(a)*(b)(d)(e)(f)=(c)+(e)(g)(h)=(f)*(g)(i)(j)=(h)*(1-(i))Pre-notice consultation 0.0024 $157,629 $378 $4.00 $6.65 $385 41% $158 0.165 $132Administrative prescreen/notice receipt/user fee0.0024 $157,629 $378 $92.00 $152.97 $531 100% $531 0.165 $444CRSS (Chemical Review andSearch Strategy)0.0025 $157,629 $394 $268.00 $445.60 $840 100% $840 0.165 $701SAT (Structure ActivityTeam)0.0006 $157,629 $94.58 $14.00 $23.28 $118 100% $118 0.165 $98.41Engineering/Exposure 0.0015 $157,629 $236 $56.00 $93.11 $330 100% $330 0.165 $275Exposure/Fate 0.0008 $157,629 $126 $0.00 $0.00 $126 100% $126 0.165 $105Focus 0.0009 $157,629 $142 $23.00 $38.24 $180 100% $180 0.165 $150Standard Review Functions 0.0219 $157,629 $3,452 $511.00 $849.63 $4,302 29% $1,247 0.165 $1,042Division Directors Meeting 0.0129 $157,629 $2,033 $113.00 $187.88 $2,221 15% $333 0.165 $278OrderDevelopment/NegotiationReview0.0171 $157,629 $2,695 $22.00 $36.58 $2,732 3% $81.96 0.165 $68.44Post Order Data Review 0.0886 $157,629 $13,966 $0.00 $0.00 $13,966 3% $419 0.165 $350Order Modification 0.2167 $157,629 $34,158 $0.00 $0.00 $34,158 3% $1,025 0.165 $856New Chemical SNURDevelopment0.0277 $157,629 $4,366 $85.00 $141.33 $4,508 7% $316 0.165 $263Notices of Commencement 0.0012 $157,629 $189 $40.00 $66.51 $256 31% $79 0.165 $66.18FOIA (Freedom ofInformation Act) Requests0.0333 $157,629 $5,249 $287.00 $477.19 $5,726 1% $57 0.165 $47.81CBI (Confidential BusinessInformation) Substantiation0.0004 $157,629 $63.05 $3.00 $4.99 $68.04 100% $68.04 0.165 $56.81TOTAL$5,909 0.165$4,934Notes:1GS-13 Step 5 salaries loaded with benefits and overhead. See Table 9 for derivation.2Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated from 1993 prices using the factors presented in Table 10.3Weighted costs were calculated using unrounded unit cost estimates, soresults may differ from calculations using the rounded values shown in this table.4Electronic submission is expected togenerate a cost savings of 16.5% to the Agency (EPA 2009b, p. 28).Sources:FTEs per review step, 1993 extramural costs, and percents of cases are from EPA, 1994 Table VII-1, GS-13 salaries are from OPM2009.Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 17 Economic and Policy Analysis Branch 3.3 Export Notification Cost

The Agency burden and cost due to TSCA §12(b) expor t 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 2009b). In the second task, EPA st aff prepares separate notification letters that are subsequently reviewed and delivered to importing c ountries, their embassies, or representatives, and to the importing country’s US embassies (EPA 2009b). 17 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 industry and im porting countries, and of handling other tasks associated with the TSCA §12(b) program, was estimated to require roughly 400 hours per year (EPA 2009b). Since the current rulemaking covers only one chemical subject to TSCA 12(b) reporting for a minimal number of uses, a very small percent of such activity will be attributable to the current rulemaking.

Because the domestic manufacture, import and processing of C 12-13 chloro alkanes for the uses subject to the SNUR have been phased out, EPA does not expe ct to receive or send any export notifications. Nevertheless, should there be any notifications as a result of the current rulemaking, the costs to the Agency are presented per activity. Th e burden for the first two Agency activities is provided in Table 12 below. To estimate the Agency cost , hourly burdens are multiplied by the loaded wage rate of a GS-13, Step 5 (see Table 9).

Table 12: TSCA 12(b) Export Notification Co st: Agency Burden per Activity (2009$)

Agency Activity Hours per Activity FTE per Activity 1 Loaded Mailing

Cost Total Agency Cost per Activity GS-13, Step 5 FTE Wage Rate (a) (b) = (a)/2,080 (c) (d) (e) = ((b)*(c))+(d) Process an incoming
notification from an exporting company 0.10 0.000048 $157,629 $0.00 $7.58

Prepare and mail a

notification to an importing country 0.50 0.000240 $157,629 $13.34 $51.23

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: Table 9 of this report derives Agency labor costs. Mailing costs are from Table 6 of this report. Other burdens are from EPA 2009b, updated for inflation.

17 See Table 6 for the cost of mailing one notification.Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 18 Economic and Policy Analysis Branch 

### 4. BENEFITS

EPA requires additional information to fulfill its mandate under TSCA to fully assess the risks posed by the production, sale, and use of C 12-13 chloro alkanes in the United States. A SNUN submission provides EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs. This is especially important in this case, because C 12-13 chloro alkanes, has been found to be harmful to wildlife, the environment, and human health, and there is no current US production or importation of the chemical. Therefore, the SNUN allows EPA to monitor any planned production or processing of the chemical and if the Agency chooses to continue to keep the chemical from being used in the United States. The proposed rule may also restrict future production, exposure, and release of the chemical, as a company may choose to manufacture or process an alterative that does not trigger a SNUR, as opposed to submitting a SNUN.

Quantification of the benefits of the proposed rule would require more specific information about each user’s use patterns and preferences as well as the ch anges in these patterns and preferences that would

result from the additional information made available under the proposed rule. These data are not readily available and collecting such da ta would be cost-prohibitive.Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 19 Economic and Policy Analysis Branch 

### 5. ADDITIONAL ANALYSES

This section presents additional analysis of other po tential impacts of this rulemaking, as required under

various statutes and executive orders.

5.1 Regulatory Flexibility Act

The Regulatory Flexibility Act (RFA) (5 U.S.C. 601 et. seq.), as amended by the Small Business Regulatory Enforcement Fairness Act, requires regulator s to consider the impact of regulations on small entities, in particular small businesses. EPA’s experience to date is that, in response to the promulgation of SNURs covering over 1,000 chemicals, the Agency receives only a handful of notices per year. For example, the number of SNUNs was 4 in Federal fi scal year 2005, 8 in FY2006, 6 in FY2007, 8 in FY2008, and seven in FY2009. 18 During this five-year period, three small entities submitted a SNUN, using the criteria for ‘small business’ was that the company checked the box on the PMN form, page 2, stating that it was a small business for the purpose of paying the $100 fee instead of the normal fee. 19,20

.
5.2 Unfunded Mandates Reform Act

Based on EPA's experience with pr oposing and finalizing SNURs, State, local, and Tribal governments have not been impacted by these rulemakings, and EPA does not have any reas on to believe that any State, local, or Tribal government would be impacted by this rulemaking.

5.3 Paperwork Reduction Act 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 requi red to respond to a collection of information that requires OMB approval under the PRA, unless it has been approve d by OMB and displays a currently valid OMB

control number. The OMB control numbers for EPA's re gulations in title 40 of the CFR, after appearing

in the Federal Register , are listed in 40 CFR, part 9, and include d on the related collection instrument, or form, if applicable. The information collection requi rements related to this action have already been approved by OMB pursuant to the PRA under OMB control number 2070-0038 (EPA ICR No. 1188).

This action does not impose any burden requiring additi onal OMB approval. If an entity were to submit a SNUN to the Agency, the annual burden is estimat ed to average 97 hours per response – 0.82 hours for rule familiarization (Section 2.2.1), 2.80 hours fo r CDX registration, CDX electronic signature, and pay.gov account setup (Section 2.2.2), 92.20 hours for form completion and submission 2.2.3), and 1.36 hours for export notification (Section 2.2.4).

5.4 National Technology Transfer and Advancement Act

This action does not involve any technical standards; therefore, section 12(d) of the National Technology Transfer and Advancement Act of 1995 (NTTAA), P ublic Law 104–113, section 12(d) (15 U.S.C. 272 note), does not apply to this action.

18 February 5, 2009 email from Carol Rawie, EPA Office of Pollution Prevention and Toxics, to Tulika Narayan and Kimberly Wilson, Abt Associates. The counts include bo th “valid” and “invalid” SN UNs. SNUN numbering is according to Federal fiscal y ear, ending September 30.

19 February 5, 2009 email from Carol Rawie, EPA Office of Pollution Prevention and Toxics to Tulika Narayan and Kimberly Wilson, Abt Associates.

20 In order to submit SNUN as a “small business” a company needs to be classified as small using the TSCA based definition of annual revenue of less than $4,000,000 per year . This definition is not consistent with the definition of a small business using Small Business Administration (SBA) NAICs based definitions.Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 20 Economic and Policy Analysis Branch 5.5 Executive Order 12898: Federal Actions to A ddress Environmental Justice in Minority Populations and Low-Income Populations

This action does not involve special considerations of environmental justice-related issues as required by Executive Order 12898, Federal Actions to Address Environmenta l Justice in Minority Populations and Low-Income Populations (59 FR 7629, February 16, 1994).

5.6 Executive Order 13045: Protection of Children from Environmental Health Risks and Safety

Risks

The proposed SNUR does not address environmental hea lth or safety risks disproportionately affecting

children.

5.7 Executive Order 13132: Federalism

The proposed SNUR is not expected to have a subs tantial direct effect on 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 as specified in Executive Order 13132, entitled Federalism (64 FR 43255, August 10, 1999).

5.8 Executive Order 13175: Consultation and Coordi nation with Indian Tribal Governments

This proposed SNUR would not have Tribal implicat ions because it is not expect ed to have substantial direct effects on Indian Tribes. This proposed rule would not significantly or uniquely affect the communities of Indian Tribal governments, nor would it involve or impose any requirements that affect Indian Tribes. Accordingly, the requirements of Executive Order 13175, entitled Consultation and

Coordination with Indian Tribal Governments (65 FR 67249, November 6, 2000), do not apply.

5.9 Executive Order 13211: Actions that Significantl y Affect Energy Supply, Distribution, or Use

This proposed SNUR is not expected to affect energy supply, distribution, or use.Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 21 Economic and Policy Analysis Branch 

### 6. REFERENCES

15 U.S.C. 272, National Technology Transfer and Advancement Act of 1995 (NTTAA), Public Law 104– 113, Section 12(d).

19 CFR 12, Customs Duties: Special Classes of Merchandise, Code of Federal Regulations

, Part 12, Title 19, August 1, 1983.

40 CFR 707, Chemical Imports and Exports , Code of Federal Regulations

, Part 707, Title 40, July 1,

2003.

40 CFR 720, Premanufacture Notification , Code of Federal Regulations

, Part 720, Title 40 , July 1, 2003.

40 CFR 721, Significant New Use of Chemical Substances , Code of Federal Regulations

, Part 721, Title 40, July 1, 2003.

59 FR 7629, Federal Actions to Address Environmental Jus tice in Minority Populations and Low-Income Populations , Federal Register, Volume 59, February 16, 1994.

59 FR 22951, Consultation and Coordination with Indian Tribal Governments , Federal Register, Volume 59, November 6, 2000.

62 FR 19885, Protection of Children from Environmental Health Risks and Safety Risks, Federal Register, Volume 62, April 23, 1997.

64 FR 43255, Federalism , Federal Register, Volume 65, August 10, 1999.

66 FR 28355, Actions Concerning Regulations that Significantly Affect Energy Supply, Distribution, or

Use , Federal Register, Volume 66, May 22, 2001.

71 FR 66234, Export Notification; Change to Reporting Requirements, Final Rule, Federal Register

, Volume 71, November 14, 2006. Avai lable in docket EPA-HQ-OPPT-2005-0058 at http://www.regulations.gov.

BLS, 2006a. U.S. Bureau of Labor Statistics, Employer Costs for Employee Compensation: Changes to NAICS and SOC, Table 2. ECEC Occupational Comparability between SOC and OCS. Downloaded February 2006 from http://www.bls.gov/ncs/ect/sp/ecsm0003 .htm.

BLS, 2006b. U.S. Bureau of Labor Statistics, Employment Cost Index News Release Text: Employment Cost Index, March 2006 (April 28, 2006), at http://www.bls.gov

. BLS, 2006c. U.S. Bureau of Labor Statistics. Change has Come to the ECI (June 14, 2006) at http://www.bls.gov/ncs/ect/sp/ecsm0001.htm

BLS, 2010a. U.S. Bureau of Labor Statistics. Employer Costs for Employee Compensation Supplementary

Tables December 2009. March 10, 2010. Available at: http://www.bls.gov/ncs/ect/sp/ecsuptc13.pdf. (Note: The BLS report title and content is updated periodically to include more recent data, on the same website.)Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 22 Economic and Policy Analysis Branch BLS, 2010b. U.S. Bureau of Labor Statistics. Employment Cost Index – Total Compensation: Professional and Related Private Industry, Not Seasonally Adjusted. (Series ID: CIU2010000120000I) . Accessed April 12, 2010.

Branch, 2006. Raphael E. Branch and Lowell Mason. U.S. Bureau of Labor Statistics, “Seasonal adjustment in the ECI and the conversion to NAICS and SOC.” Monthly Labor Review . Vol. 129, No. 4, April 2006. Available at www.bls.gov

.

CPIA. 2009. Chlorinated Paraffins Industry Association. Chlorinated Paraffins: A Status Report

. Available at: http://www.regnet.com/cpia/s tatus_report.html. Accessed April1, 2009.

EC. 1999. European Commission. European Union Risk Assessment Report Alkanes, C 10 - 13 , chloro, CAS

No. 85535-84-8. Volume 4. EUR 19010EN. Office for Official Publications of the European Communities: Luxembourg, 2008.

EC. 2005. European Commission. Updated Risk Assessment of Alkanes, C14-17, chloro, (MCCP), Part I Environment, CAS No. 85535-85-9. Volume 58. EUR 21640 EN. Office for Official Publications of the European Communities: Luxembourg, 2005.

EC. 2007. European Commission. European Union Risk Assessment Report Alkanes, C14-17, chloro, (Medium-Chain Chlorinated Paraffins), CAS No. 85535-85-9 . Draft Environment Addendum of August 2007. R331_080 7_env. Available at: http://ecb.j rc.ec.europa.eu/DOCUMENTS/ExistingChemicals/RISK_ASSESSMENT/ADDENDUM/mcc p_add_331.pdf. Accessed December 22,

2009.

ECHA. 2008a. European Chemicals Agency. Data on Manufacture, Import, Export, Uses and Releases of Alkanes, C 10 - 13 , chloro, SCCPs as well as Informatio n on Potential Alternatives to Its Use

. Available at: http://echa.europa.eu/doc/consultations/recommenda tions/tech_reports/tech_rep_alkanes_chloro. pdf. Accessed December 11, 2009.

EPA, 1992. U.S. EPA, Office of Policy, Planning, and Evaluation. Instructions for Preparing Information Collection Requests (ICRs). Washington, DC, June 1, 1992.

EPA, 1994. US EPA, Office of Toxic Substances, Regulatory Impacts Branch. Regulatory Impact Analysis of Amendments to Regulations fo r TSCA Section 5 Premanufacture Notifications

. Washington, DC: U.S. EPA/OPPT/EETD/RIB, Sept ember 9, 1994. (OTS/RIB later became OPPTS/EPAB.)

EPA, 2000. U.S. EPA, Office of Pollution Prevention and Toxics, ICR No. 1139.06. [Information Collection Request for] TSCA Existing Chemical Test Rules, Consent Orders, Test Rule Exemptions, and Voluntary Test Data Submissions: Supporting Statement for Request for OMB Review under the Paperwork Reduction Act . Attachment 5, Wage Rates Estimation, August 29,

2000.

EPA, 2002a U.S. EPA, 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.Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 23 Economic and Policy Analysis Branch EPA, 2002b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis

Branch. Wage Rates for Economic Analysis of the Toxics Release Inventory Program. Washington, DC, June 10, 2002.

EPA, 2003. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Economic Analysis of Expedited Significant New Use Rules for 65 Chemical Substances

. Washington, DC, 2003. Available in docket EPA-HQ-OPPTS-2002-0078 at: http://www.regulations.gov.

EPA, 2005. Office of Pollution Prevention and To xics, Economic and Policy Analysis Branch. Economic Analysis of the Proposed Change to TSCA Section 12(b) Export Notification Requirements, November 2005. Available in Federal Docket Management System as EPA-HQ-OPPT-2005- 005 8-0017 at: http://www. regulations.gov.

EPA, 2006a. Inventory Update Reporting (IUR): Non-C onfidential 2006 TSCA Inventory Update Rule (IUR) Records . Available at: http://cfpub.epa.gov/iurs earch/index.cfm?s=che m. Accessed April 9, 2009.

EPA, 2007a. U.S. EPA, Office of Pollution Preven tion and Toxics, Economic and Policy Analysis

Branch. Economic Analysis of Expedited Significant New Use Rules for 38 Chemical Substances (EPA Docket OPPT- 2006-0898 ), August 17, 2007.

EPA, 2007b. U.S. EPA, Office of Pollution Prevention and Toxics , ICR No. 0574.14. [Information Collection Request for] Pre-Manufacture Review Reporting and Exemption Requirements for New Chemical Substances and Significant New Use Reporting Requirements for Chemical Substances: Supporting Statement fo r a Request for OMB Review under The Paperwork

Reduction Act , December 6, 2007.

EPA, 2009a. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis
Branch . Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule

. (EPA-HQ-OPPT-2008-0296). July 13, 2009.

EPA, 2009b. U.S. EPA, Office of Pollution Prevention and Toxics. ICR No.: 0795.13 [Information Collection Request for] Notification of Chemic al Exports - TSCA S ection 12(b) Supporting Statement for Request for OMB Review under the Paperwork Reduction Act . Available at http://www.regulations.gov . Accessed March 6, 2009.

EPA, 2009c. U.S. EPA, Office of Chemical Safety and Pollution Prevention. Short-Chained Chlorinated Paraffins (SCCPs) and Other Chlorinated Paraffins Action Plan. Available at: http://www.epa.gov/opptintr/existingchemicals/ pubs/actionplans/sccps_ap_2009_1230_final.pdf

Government of Canada. 2008. Order Adding Toxic Substances to Schedule 1 to the Canadian Environmental Protection Act, 1999 . Canada Gazette. September 20, 2008, 142 (38).

HELCOM. 2002. Helsinki Commission. Baltic Marine Environment Protection Commission. Project Team for the Implementation of the HELCOM Ob jective with regard to Hazardous Substances 7th Meeting. March 11-13, 2002. Final Report.

IARC. 1990. International Agency for Research on Cancer. Monographs on the Evaluation of Carcinogenic Risks to Humans. Volume 48. Some Flame Retardants and Textile Chemicals,andEconomic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 24 Economic and Policy Analysis Branch Exposures in the Textile Manufacturing Indust ry Summary of Data Reported and Evaluation. World Health Organization: Paris, France.

Klaunig, J.E., Babich, M.A., Baetcke, K.P. Cook, J. C., Corton, J.C., David, R. M., DeLuca, J.G., Lai, D.Y., McKee, R. H., Peters, J.M., Robert s, R.A. and Fenner-Crisp, P.A. (2003). PPAR α AgonistInduced Rodent Tumors: Modes of Action and Human Relevance . Crit. Rev. Toxicol. 33: 655-

780. NTP. 1986a. National Toxicology Program. Depa rtment of Health and Human Services. Toxicology and Carcinogenesis Studies of Chlorinated Paraffins(C 12 , 60% Chlorine) in F344/N Rats and B6C3F 1 Mice. May 1986. Available at: http://ntp.niehs.n ih.gov/ntp/htdocs/LT_rp ts/tr308.pdf. Accessed December 11, 2009.

NTP. 1986b. National Toxicology Program. De partment of Health and Human Services. Toxicology and Carcinogenesis Studies of Chlorinated Paraffins(C 23 , 43% Chlorine) in F344/N Rats and B6C3F 1 Mice. May 1986. Available at: http://ntp.niehs.n ih.gov/ntp/htdocs/LT_rp ts/tr305.pdf. Accessed December 11, 2009.

NTP. 2005. National Toxicology Program. Depa rtment of Health and Human Services. Report on Carcinogens, Eleventh Edition; Substan ce Profiles: Chlorinated Paraffins (C 12 , 60% Chlorine)

CAS No. 108171-26-2. 2005. Available at: http://ntp.niehs.nih.gov/ntp/ro c/eleventh/profiles/s034chlo .pdf. Accessed Dec 11, 2009.

OPM, 2009. Office of Personnel Management, Salary Table 2009-DCB, Washington-Baltimore/Northern Virginia, DC-MD-PA-VA-WV. Available at: http://www.opm.gov/oca/09tables/pdf/DCB.pdf.

Rawie, Carol. 2009. EPA Office of Pollution Preven tion and Toxics. Personal communication with Tulika Narayan and Kimberly Wilson of Abt Associates via e-mail. February 5, 2009.

Sleemi, 2006. Fehimida Sleemi. U.S. Bureau of Labor Statistics, “Employment Cost Index Publication Plans”. Monthly Labor Review. Vol. 129, No. 4, April 2006. available at www.bls.gov/opub/mlr/2006/04/art2full.pdf

UNECE. 2006. United Nations Economic Commission for Europe. Short Chain Chlorinated Paraffins Track B Review for the UNECE LRTAP Task Force on Persistent Organic Pollutants – Final Report . May 2006.

UNEP. 2009. United Nations Environment Programme . Stockholm Convention on Persistent Organic Pollutants (POPs). Persistent Organic Pollutants Review Committee. Revised Draft Risk Profile: Short-Chained Chlorinated Paraffins . 9 July 2009. UNEP/POPS/POPRC.5/2. Available at: http://chm.pops.int/Convention/POPsReview Committee/hrPOPRCMee tings/POPRC5/POPRC5D ocuments/tabid/592/language/en-US/Defau lt.aspx. Accessed December 11, 2009.

USPS, 2010. U.S. Postal Service Mailing and postage rates. Available at: 

### http://www.usps.com/prices

. Accessed August 16, 2010.

Weinstein, 2004. Harriet G. Weinstein and Mark A. Loewenstein, U.S. Bureau of Labor Statistics.

C omparing Current and Former Indu stry and Occupation ECEC Series. Originally posted August 25, 2004 at h ttp://www.bls.gov/opub/cwc/cm20040823ar01p1.htmEconomic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 25 Economic and Policy Analysis Branch APPENDIX A
INFLATORS AND WAGE RATESEconomic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 26 Economic and Policy Analysis Branch 

### A. INFLATORS AND WAGE RATES

This appendix describes the derivation of the fully lo aded labor rates and inflation factors used in calculating costs of labor, materials, and other in puts. Costs for this report are for year-end 2008.

A.1 Derivation of Loaded Wage Rates

Unit labor costs are calculated by adding fringe benef its and overhead to the wage or salary to derive a fully loaded labor cost. The basic method is describ ed in Wage Rates for Economic Analysis of the Toxics Release Inventory Program (EPA, 2002b). The r esulting loaded labor rates are given in Table 14. Costs are calculated for several labor categories: Managerial, Professional/Technical, Clerical, and EPA

staff.

In March 2004, BLS began using the North American Industry Classification System (NAICS) codes

instead of the Standard Industrial Classificati on (SIC) System, and the Standard Occupational Classification (SOC) system instead of the Occupational Classification System (OCS). Table 13 shows the crosswalk between old and new occupational titles.

Table 13 : Detail of Labor Categories Used in the Analysis

EPAB Reports Labor Category BLS Old Title (OCS) 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 Office 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 Manag erial, Professional/Technical, Clerical, and

Production Labor

Wages and fringe benefits for managerial, professiona l/technical, clerical and production labor were taken from the Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation (ECEC) data, 21
for December, for manufacturing industries. 22

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 perc ent of wages are calculated separately for each labor category. For example, for December 2009, th e average wage rate for professional/technical 23 labor was $35.96; the average fringe benefit was $17.42. Fringe benefits as a percent of wages were $17.42/$35.96, or approximately 48.4 percent.

21 This follows the approach introduced in Economic Analysis of Expedited Significant New Use Rules for 65 Chemical
Substances: EPA Do cket OPPT-2003-0063 (EPAB, 2007a).

22 Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006 – December 2008. (BLS, 2009a). This follows the approach introduced in EPAB, 2007a. Earlier PMN S NUR economic analyses, such as EPA, 2003a, used ECEC data for “A ll Goods Producing” sectors (manufacturing, mining, and construction). However, the manufacturing sector data seem more relevant since the SNURs mainly affect the chemicals industry.

23 This follows terminology introduced in EPAB, 2007a. Earlier SNUR economic analyses used the term “technical” labor. Here the category is called “professi onal/technical” labor, to make clear how it relates to BLS categories. In 2004, BLS changed from the Occupational Classificati on System, OCS, to the Standard Occupational Classification system, SOC. In the process, the “Professional specialty and te chnical” category became the “Professional and related” catego ry. However, the coverage of the old and new occupational groups is appr oximately the same. See the BLS article, C omparing Current and Former Industry

and Occ upation ECEC Series (Weinstein, 2004).Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 27 Economic and Policy Analysis Branch An additional loading factor of 17 percent is applie d to wages to account for overhead. This approach is used for consistency with Office of Pollution Prev ention and Toxics economic analyses for two major rulemakings: Wage Rates for Economic Analyses of the Toxi cs Release Inventory Program (EPA, 2002b), and the Revised Economic Analysis for the Am ended 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 loaded wage. For example, the December 2009 fully loaded wage for professional/technical labor is $35.96 × (1+0.4844 + 0.17) = $59.49..

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

shown in Table 14.

A.1.3 Derivation of Labor Rates for EPA Staff

Agency labor costs are calculated based on annua l Federal salaries for the Washington-Baltimore area published by the Office of Personnel Management effective January 2008 (OPM, 2008). The average salary for one FTE staff member is estimated as the salary for a GS-13 Step 5 employee

. 24

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 $150,440.

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

“The annual costs per FTE are derived by multiplyin g the annual pay rate by 1.6 (the benefits multiplication factor). The multiplication factor u sed is recommended in EPA’s Office of Policy, Planning, and Evaluation’s Instructions for Pr eparing 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 only benefits but also overhead.” (ICR No.1139.06)

24 The GS-13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007), which covers PMN SNURs. Use of this grade level follows the approach introduced in EPAB, 2007a. That repor t represented a change from th e earlier PMN SNUR economic analysis (EPA, 2003a), which used an average of GS-12 Step 1 and GS-12 Step 10 salaries.Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics(CAS RN): 71011-12-6) 28 Economic and Policy Analysis BranchTable 14: Derivation of Loaded Wage RatesEPAB LaborCategoryData SourcesDateWageFringeBenefitFringes as% WageOver-head %Wage2Fringe +OverheadFactorLoaded Wages1(a)(b)(c) =(b)/(a)(d)(e)=(c)+(d)+1(f)=(a) x (e)ManagerialBLSECEC, PrivateManufacturingindustries,“Mgt, Business, andFinancial”3Dec-09 $42.36 $18.68 44.10% 17% 1.61 $68.24Professional/TechnicalBLSECEC, PrivateManufacturingindustries, “Professional andrelated“3Dec-09 $35.96 $17.42 48.44% 17% 1.65 $59.49ClericalBLSECEC, PrivateManufacturingindustries,“Office andAdministrative Support”3Dec-09 $17.21 $8.17 47.47% 17% 1.64 $28.31EPA staffFTEAnnual Federal staff cost: OPMWashington-Baltimore-NorthernVirginia, DC-MD-PA-VA-WV, area,GS-13 Step 5 pay rates, with 60%overhead.3Dec-09 $98,518(annual) --[Included in60%overhead]60% 1.6 $157,629 (annual)Notes:1Wage data are rounded to the closest pennyin this table; however, in calculationsusing these numbers for this report, unrounded values were used.2An overhead rate of 17% was used based on assumptions inWage Rates for Economic Analyses of the Toxics Release Inventory Program(EPA, 2002b), and theRevised Economic Analysisfor the Amended Inventory Update Rule: Final Report(EPA, 2002a).3The salary is unloaded Federal GS-13 Step 5 salary for calendar 2009, from the Office of Personnel Management salary table forWashington-Baltimore-Northern Virginia (OPM, 2009).The 60% fringes-and-overhead rate is from an EPA guide,Instructions for Preparing Information Collection Requests (ICRs)(EPA, 1992, page 30, footnote 9).Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 29 Economic and Policy Analysis Branch A.2 Derivation of Inflation Factors

Complete information on the derivation of the inflatio n factors used is given in Table 15. In 2006, the Bureau of Labor Statistics (BLS) made several change s 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 overview” (Caroll 2006); “Employment Cost Index Publication Plans” (Sleemi, 2006); and “Seasonal adjustment in the ECI and the conve rsion to NAICS and SOC” (Branch, 2006).

Under a mandate from OMB, BLS changed its classif ication of industries and occupations from the Standard Industrial Classification (SIC) and Occ upational 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 reflect this change.

In addition to changing the industr y and occupational classification syst ems, 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 SIC based series. (Seas onally adjusted indices, including those in Table A-2 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 year s 1975-2005 is the SIC-OCS based series, and for subsequent years, the official ECI is th e NAICS-SOC based series (Sleemi, 2006, p.8). 25

“Starting year” indices in Table 15 continue to be SIC-SOC based. Current year indices are NAICS-SOC

based. We use indices from both the NAICS-SOC a nd the SIC-OCS based ECI series because neither series spans the entire period over which testi ng and other costs need to be inflated.

25 BLS has been publishing the NIACS-SOC based ECI series si nce March 2001 and it became official in March 2006. The SICOCS based series and NAICS-SOC series ha ve different series ID numbers, even wh en they describe essentially the same population. For example the series ID for seasonally adjust ed total compensation for all private industry workers is

ECS10002I for the SIC-OCS series and CIS2010000000000I for the NAICS-SOC series

.Economic Analysis of SNUR for Alkanes, C 12-13 , chloro U.S. EPA Office of Pollution Prevention and Toxics (CAS RN): 71011-12-6) 30 Economic and Policy Analysis Branch Table 15: Derivation of Inflation Factors

Item Inflation Index Source 1 Startin g Year Index for Starting Year (a) Index for

2008

(b) Inflation

Factor (b)/(a) 2

Export notification BLS ECI, not SA, Total comp, Private industry, White Collar

. ECS11102I, 4 th Q [BLS, 2010b] 1993 66.5 110.4 1.660

Agency Extramural costs White collar labor; equipment; supplies BLS ECI, not SA, Total comp, Private industry, White Collar

. ECS11102I, 4 th Q [BLS, 2010b] 1993 67.0 111.4 1.663

Labels, placards etc. BLS CPI, inflation calculator, not SA. Annual [BLS, 2010c] 1997 160.5 214.537 1.337

File cabinet

Photocopies BLS CPI, inflation calculator, Annual [BLS,2010c] 1988 118.3 214.537 1.813 Record keeping materials

Key: BLS = Bureau of Labor Statistics. CPI = Consumer Price Index. ECI = Employment Co st Index. SA = Seasonally Adjusted. Total Comp = Total Compensation (wages/salaries and benefits). 4th Q = Fourth Quarter. “ECS10002I” etc. refer to BLS series Ids.

Notes:

1 In 2006, Bureau of Labor Statistics (BLS) Employment Cost Inde x (ECI) series “were rebased to December 2005 = 100 from June 1989 = 100.” The change is reflected in the i ndices 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 Adju sted (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 Adju sted (SA) CIS2010000000000I for private industry All Workers, and not SA CIU2010000120000I (B) for private industr y Professional, and Related workers.

2 Inflation factors are rounded to three decimal places in this ta ble, but calculations in this report use the unrounded values. BLS CPI values were published with one decimal place through 2006 and with th ree decimal places after that.

3 We began using the ECI for Private Industry All Workers in EPA, 2007b, to better reflect the labor mix for impermeability testing.
Earlier PMN SNUR economic anal yses used the ECI for Private Industry White Collar Workers.

4 Beginning with the report Economic Analysis of Expedite d Significant New Use Rules for 25 Chemical Substances: EPA Docket

OPPT-2009-0922 (EPA, 2010d) we began to use the no t-seasonally adjusted CIU2010000120000I for private industry Professional,and Related workers, instead of SA CIS2010000W00000I for private industry white collar workers because BLS retired the “whitecollar” series.