*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

ECONOMIC ANALYSIS OF THE PROPOSED SIGNIFICANT NEW USE RULE FOR 14 GLYMES (EPA DOCKET EPA-HQ-OPPT-2009-0767)



### April 8, 2010

—Does not contain TSCA CBI—

Prepared by:

Economic and Policy Analysis Branch Economics, Exposure and Technology Division
Office of Pollution Prevention and Toxics

U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ****** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch i CONTRIBUTORS

The EPA analyst responsible fo r this report was Nishkam Agar wal. Analytical and draft preparation support was provided by Abt Associates Inc. under EPA Contract No. EP-W-08-010.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch ii ABSTRACT

This report estimates the costs of the pr oposed Significant New Use Rule (SNUR) that applies to 14 chemicals, collec tively known as “glymes” ([poly]et hylene glycol diethers). The specific glymes subject to the proposed S NUR are monoglyme, diglyme, ethylglyme, ethyldiglyme, triglyme, butyldiglyme, tetrae thylene glycol dibutyl ether, tetraglyme, pentaethylene glycol diethyl ethe r, polyglyme, tetraethylene glyc ol diethyl ether, polyethylene glycol dibutyl ether, pentaet hylene glycol dibutyl ethe r, and butyltriglyme.

The proposed SNUR applies to all proposed si gnificant new uses of 14 glymes that are defined as use in a consumer product of 12 glym es (monoglyme, diglyme, triglyme, tetraglyme, polyglyme, ethylglyme, ethyldigl yme, butyldiglyme, tetraethyle ne glycol dibutyl ether, pentaethylene glycol diethyl ether, tetraethylene glycol diethyl et her, polyethylene glycol dibutyl ether) with the exception of excluded ongoing consumer uses for five glymes (monoglyme, diglyme, triglyme, tetraglyme, and polyglyme), and any uses (consumer or non-consumer) of two glymes (pentaethylene glycol di butyl ether and butyltriglyme).

All consumer uses that are exempted fr om the proposed SNUR are confirmed ongoing uses of these chemicals in consumer products. A "consumer product" is de fined as: “a chemical substance that is directly, or as part of a mixture, sold or made available to consumers for their use in or around a permanent or temporary househol d or residence, in or around a school, or in recreation.” To identify the c onfirmed ongoing consumer uses, as well as potential industrial uses, EPA relied on the TSCA Inventory Update Reporting (IUR) information combined with
direct communications with manufacturers. EPA has distinguished confirmed uses from unconfirmed or reported uses, wher e the latter are uses identified only in chemical dictionaries and other comparable reference materials.

Of the 14 glymes, five have confirmed consumer uses that are excluded from the proposed
SNUR. These excluded uses are:

• Monoglyme in electrolyte solutions for sealed lithium batteries

• Diglyme as a solvent in printi ng inks for consumer products

• Triglyme as a solvent in consumer adhesives, as a component of consumer brake fluids, as a component of consumer paint/graffiti removers, and in consumer paints

• Tetraglyme as a hydrofluor ocarbon/chlorofluorocarbon (H FC/CFC) lubricant, as a solubilizing agent for consumer printing inks , and as a coalescing agent in consumer paints

• Polyglyme in consumer paint strippers

Glymes are used mostly as industrial solvents, reaction solvents, or pr ocessing aids, but they have been used in some consumer products. The U.S. Environmental Protection Agency (EPA) is proposing the SNUR because it is concerned about the repr oductive and/or developmental toxicity of monoglyme, diglyme, and ethylglym e and believes that i ndividuals could suffer adverse effects from their use. In addition, due to the absence of use, exposure, and toxicity data to suggest otherwise, EPA remains concerned ab out the other 11 glymes. A firm intending to manufacture, import, and/or process any of these 14 glymes for any significant new use*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch iii (described in Section 1.2) w ould be required to submit a Sign ificant New Use Notice (SNUN), incurring an estimated submi ssion cost of $8,455 per chemical.

The proposed SNUR would require persons to notify EPA at least 90 days before commencing the manufacture, import, or processi ng of glymes for any significant new use as
described in the SNUR.

To submit this SNUN, a firm incurs a modest submission cost. 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 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.

In addition to the firms that make a SNUN submission, the proposed SNUR may also impact firms that do not make a submission. By avoi ding a significant new use, a firm can avoid submission and testing costs but may incur other compliance costs. The firm may also incur “hidden” costs; for example, it could forego pr ofitable opportunities to us e the chemical in an application that would be a significant new use or limit production volume to avoid a significant

new use.

Costs are estimated at the firm level and reflec t the burden of a SNUR on the firms that make
a submission. The hidden costs to the firms th at do not make a submission are not quantified. EPA receives only a handful of SNUNs per year due to SNURs. However, the number of firms affected by not making submissions to EPA is not known; therefore, costs are not aggregated
across the affected entities.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch iv TABLE OF CONTENTS

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

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

LIST OF TABLES................................................................................................................. ......... v
1. INTRODUCTION ................................................................................................................ ... 1 1.1 Uses of 14 Glymes ......................................................................................................... 2 1.2 Consumer Uses Excluded by the proposed SNUR ........................................................ 4 1.3 Potentially Affected Industries....................................................................................... 6 1.4 Impact of a SNUR.......................................................................................................... 7

2. COSTS OF A SNUR, BY OPTION........................................................................................ 8 2.1 Submit a SNUN (Option 1)............................................................................................ 8 2.2 Decide Not to Produce Chemical (Option 2) ................................................................. 9
2.3 Likelihood of a SNUN Submission ............................................................................... 9 2.4 Potential for Subseque nt Regulatory Actions .............................................................. 10 2.5 Agency Costs ............................................................................................................... 11

3. EXPORT NOTIFICATION COSTS ..................................................................................... 11 3.1 Estimated Number of Exporte rs and Export Notifications .......................................... 11 3.2 Exporter Costs............................................................................................................. . 12 3.3 Agency Costs ............................................................................................................... 15

4. ADDITIONAL ANALYSES................................................................................................. 19 4.1 Regulatory Flexibility Act ........................................................................................... 19
4.2 Unfunded Mandates Reform Act ................................................................................. 20 4.3 Paperwork Reduction Act ............................................................................................ 20 4.4 National Technology Transfer and Advancement Act................................................. 20 4.5 Executive Order 12866: Regulat ory Planning and Review ......................................... 20
4.6 Executive Order 12898: Environmental Justice........................................................... 20
4.7 Executive Order 13045: Protection of Children........................................................... 20
4.8 Executive Order 13132: Federalism ............................................................................ 21
4.9 Executive Order 13175: Tribal Governments.............................................................. 21 4.10 Executive Order 13211: Energy S upply, Distribution, or Use .................................... 21

A. INFLATORS AND WAGE RATES................................................................................... A-1

B. COSTS FOR SNUN ............................................................................................................ B- 1

C. AGENCY COSTS ............................................................................................................... C -1

D. REFERENCES .................................................................................................................. .. D-1*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch v LIST OF TABLES

Table 1: CAS Number and Co mmon Name for Glymes Covered by the Proposed SNUR ........... 2 Table 2: Proposed Excluded Consumer Uses by Chemical............................................................ 5 Table 3: Industries Potentially affect ed by the proposed SNUR, by NAICS Code........................ 7 Table 4: Costs of Requirement to Submit a SNUN (2008$) .......................................................... 9 Table 5: Compliance Options and Associated Co sts Incurred by a Firm Due to the proposed
SNUR........................................................................................................................... ................. 10 Table 6: Estimated Number of Exporters and Ex port Notifications Submitted to EPA as a Result of the Proposed SNUR........................................................................................................... ....... 12 Table 7: TSCA 12(b) Export Notification Cost: Annual Burden per Respondent Facility (2008$)

............................................................................................................................... ........................ 13 Table 8: Derivation of Total Mailing Cost for 12 Notices............................................................ 14 Table 9: Industry Total Cost Estimate per Year (2008$).............................................................. 14 Table 10: Three Year Industry Costs (2008$) .............................................................................. 15 Table 11: Estimated Number of Export Notifications Submitted to EPA and Notifications sent to Importing Countries............................................................................................................ .......... 16 Table 12: TSCA 12(b) Export Notification Cost: Annual Agency Burden (2008$) .................... 17 Table 13: Derivation of Agency Mailing Cost for 35 Notices...................................................... 18 Table 14: Agency Total Cost Estimate per Year (2008$)............................................................. 18 Table 15: Three Year Agency Costs (2008$) ............................................................................... 19

Table A-1: Derivation of Loaded Wage Rates ........................................................................... A-3
Table A-2: Derivation of Inflation Factors ................................................................................. A-5 Table B-1: Industry Costs for SNUN.......................................................................................... B-1 Table C-1: Agency Costs for SNUN and Ot her Submission Review and Processing................ C-2*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 1 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 1. INTRODUCTION

Glymes ([poly]ethylene glycol diet hers) are clear, colorless, li quid ethers that are primarily used as solvents or processing aids in a wide va riety of industrial applicat ions. Glymes are polar aprotic in nature, miscible in water, and hydr ocarbon type solvents (Cheremisinoff, 2003). These properties make them excellent solven ts for organic and inorganic compounds and polymers (Clariant, 2008). In a ddition, they are chemically stable in a wide pH range and may be used in several high-temperatur e applications (Clariant, 2008).

This report estimates the costs of the pr oposed Significant New Use Rule (SNUR) that applies to 14 glymes. These glymes are either ethy lene glycol dialkyl ethers or dialkyl ethers of repeating units of oxyethylene (such as dialkyl ethers of diethylene glycol or triethylene glycol, etc.) where both alkyl groups ar e the same as shown in the following structure: R-(OCH 2 CH 2 )nOR, where n=(i) a discrete value of 1,2,3,4, or 5 or (ii) a range of valu es (as in polyethylene glycol) with both R’s = CH 3 , C 2 H 5 , or C 4 H 9

. The specific glymes subject to the proposed SNUR are: monoglyme, diglyme, ethylglyme, ethyldiglyme, triglyme, butyldiglyme, tetrae thylene glycol dibutyl ether, tetraglyme, pentaethylene glycol diethyl ethe r, polyglyme, tetraethylene glyc ol diethyl ether, polyethylene glycol dibutyl ether, pentaethylene glycol dibutyl ether, and butylt riglyme. For the purposes of this SNUR, a significant new use is defined as use in a consumer product of 12 glymes (monoglyme, diglyme, triglyme, tetraglyme, polyglyme, ethylglyme, ethyldiglyme, butyldiglyme, tetraethylene glycol dibutyl ether, pentaet hylene glycol diethyl ether, tetraethylene glycol diethyl ether, polyethylen e glycol dibutyl ether, pentaet hylene glycol dibutyl ether, and butyltriglyme) with the exception of the excluded ongoing consumer uses for five of the glymes (monoglyme, diglyme, triglyme, tetraglyme, and polyglyme). For the remaining two glymes (pentaethylene glycol dibutyl ethe r and butyltriglyme), a signifi cant new use is defined as any use (consumer or non-consumer) of these glymes.

To identify the ongoing uses in consumer uses of these glymes, as well as potential industrial products of these glymes, EPA used informa tion reported under the 2006 Inventory Update Reporting (IUR) rule, contacted manufacturers, searched business periodicals, and searched
other available sources. A ll uses exempted from the pr oposed SNUR are confirmed ongoing uses of these chemicals in consumer products. A "consumer product" is de fined as: “a chemical substance that is directly, or as part of a mixture, sold or made available to consumers for their use in or around a permanent or temporary househol d or residence, in or around a school, or in recreation.” To identify these confirmed uses, EPA relied on the IUR information combined
with direct communications with manufacturers. EPA has distinguished confirmed uses from unconfirmed (reported) uses, where the latter are uses identified only in chemical dictionaries and other comparable reference materials. EP A is not proposing exclusions to the proposed significant new uses based only on the existence of a use being reported.

Table 1 lists the CAS number, synonym, and Chemical Abstract Index name for the 14 glymes subject to the proposed SNUR.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 2 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch Table 1: CAS Number and Common Name for Glymes Covered by the Proposed SNUR

CAS RN Common Name Chemical Abstract Index Name Chemicals with Consumer Use as the Significant New Use

110-71-4 Monoglyme or Monoethylene glycol dimethyl ether Ethane, 1,2-dimethoxy111-96-6 Diglyme or Diethylene glycol dimethyl ether Ethane, 1,l'-oxybis[2-methoxy629-14-1 Ethylene glycol diethyl ether Ethane, 1,2-diethoxy112-36-7 Ethyldiglyme or Diethylene glycol diethyl ether Ethane, 1,l'-oxybis[2-ethoxy112-49-2 Triglyme or Triethylene glycol dimethyl ether 2, 5, 8, 11-Tetraoxadodecane112-73-2 Butyldiglyme or Diethylene glycol dibutyl ether Butane, 1,1'-(oxybis(2,1-ethanediyloxy)]bis112-98-1 Tetraethylene glycol dibutyl ether 5, 8, 11, 14, 17-Pentaoxaheneicosane 143-24-8 Tetraglyme or Tetraethylene glycol dimethyl ether 2, 5, 8, 11, 14 -Pentaoxapentadecane 23601-39-0 Pentaethylene glycol diethyl ether 3, 6, 9, 12, 15, 18-Hexaoxaeicosane

24991-55-7 Polyglyme or Polyethylene glycol dimethyl ether Poly(oxy-l,2-ethanediyl), .alpha,-methyl.omega.-methoxy4353-28-0 Tetraethylene glycol diethyl ether 3, 6, 9, 12, 15-Penta oxaheptadecane

31885-97-9 Tetraethylene glycol diethyl ether Poly(oxy-1,2-ethanediyl), alpha.-butyl-.omega.-butoxyChemicals with Any Use as the Significant New Use
51105-00-1 Pentaethylene glycol dibutyl ether 5, 8, 11, 14, 17, 20-Hexaoxatetracosane 63512-36-7 Butyltriglyme or Triethylene glycol dibutyl ether 5, 8, 11, 14-Tetraoxaoctadecane

Source: Chemical Abstract Service (CAS)

1.1 Uses of 14 Glymes

Monoglyme (CASRN 110-71-4) has one confir med use in a consumer product, as an electrolyte solvent (1-5 percent) in sealed lith ium ion batteries (ERG, 2009a). The chemical is also reported to be included in a process to treat aluminum surfaces to ensure surfaces are less reactive (Clariant, 2008). Monoglyme is also reportedly used in th e inner and outer layer etching of printed circuit board manuf acturing (Scorecard, 2005); in reac tions with strong bases (Ferro, 2009); in mixtures where solvent separation and rec overy is necessary; as an inert special solvent for certain organo metallic reactions (Clarian t, 2008); and as a solvent for oligo- and polysaccharides; and in sugar and carbohydrate ch emistry (Clariant, 2008). The confirmed nonconsumer use of monoglyme is its use as a solven t in pharmaceutical produc tion (ERG, 2009a).

Diglyme (CASRN 111-96-6) has only one confirme d use in a consumer product, as a solvent in printing inks for consumer products (ERG , 2009a). Reported uses for diglyme under the commercial/consumer category of the 2006 IUR in clude use in automotive care products as a component of brake fluid, paints and coatings , and adhesives and sealants (EPA, 2006b). One confirmed non-consumer use for diglyme is as a solvent in the production of pharmaceutical products (ERG, 2009a). The reported non-consumer us es of diglyme include its use as a solvent for lithium aluminum hydride and sodium bor ohydride reductions and in the production of pharmaceutical products (Clariant, 2008).

While EPA has been unable to confirm thr ough the 2006 IUR and company contact that there are any uses of ethylglyme (CASRN 629-14-1) in a consumer product, there has been reported use of ethylglyme as a solvent in consumer pa int production (Ash, 2009), as well as use as an*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 3 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch adhesive solvent and polycarbonate swelling agen t (Ferro, 2009). Another potential use in a consumer product is in the preparation of “oth er” polishes and related products (Score Card, 2005). Other reported uses of ethylglyme include use as a solvent for ester gum, shellac and some resins and oils, use as a re action medium for organi c synthesis, use as a solvent and diluent for detergent and dye solvents in non-g rain-raising stains (HSDB, 2009a).

Triglyme (CASRN 112-49-2) has several confirme d uses in consumer products, including in consumer brake fluids, as a solvent in consumer adhesives, as a component of consumer paintand graffiti removers and in consumer paints (ERG, 2009b and ERG, 2009a). Confirmed nonconsumer uses include generation of chemicals, use as a selective solvent for methylation reactions, use as a binding agent in porcelai n powders and as a reaction solvent for the manufacture of sodium cyanide (ERG, 2009a).

Tetraglyme (CASRN 143-24-8) has several confirmed uses in consumer products as a solubilizing agent for consumer prin ting inks, as a coalescing agent in consumer paints, and as an HFC/CFC lubricant which may be used in c onsumer air conditioners (ERG, 2009b and ERG, 2009a). Confirmed non-consumer uses include us e as a solubilizing agent in textiles and plastics, as a dye fixation additi ve for cotton textiles, and as a fungicide process solvent (ERG, 2009a). Tetraglyme has a reported use in fabric s, textiles and apparel (EPA, 2006b) and as a gas scrubbing agent and has been shown to effectively remove CO, CO 2 , H 2 S, and other sour-gas components from natural, synthetic, or ammonia gas streams (Ferro, 2009).

Polyglyme ( CASRN 24991-55-7) has a confirmed use in consumer paint strippers (ERG, 2009a). Reported consumer uses include use in adhesive removers, frag rance production, antifog compounds, brake fluid (Ferro, 2009), auto motive care products and paper products (EPA, 2006a). Polyglyme is often used as special, high boiling solvents for several chemical reactions including depolymerization and hydrogenation. Confirmed non-consumer uses for polyglyme include use as a solubilizing agent for plastic, textile, and paper proc esses (ERG, 2009a). A reported non-consumer use is in removing sour gas compounds from gas streams, absorbing hydrogenated liquids, and scrubbing gas stacks (Ferro, 2009). Other reported non-consumer uses include use in paper products and automotive care products (EPA, 2006b).

Ethyldiglyme (CASRN 112-36-7) has several reported consumer uses in paint and paint varnishes, in coatings (Score Card, 2005) a nd adhesives manufacturing and as a solvent in printing ink production (Ash, 1996). Reported non-consumer uses include use as a high-boiling
solvent for nitrocellulose , resins, and lacquers; as a solubiliz er in organic synthesis (Ash, 2009); in manufacturing processes as a solvent in the production of plastic resins, compounds, and rubber chemicals (HSDB, 2009b).

Butyldiglyme (CASRN 112-73-2) has no confir med or reported consumer uses. Confirmed
non-consumer uses include use as a solvent for conductive printing ink and in the production of printed circuit etchants (ERG, 2009a). Repor ted non-consumer uses include use in the preparation of and reaction with Grignard reagents, and use in me tal extractions (Clariant, 2008).

Polyethylene glycol dibutyl et her (CASRN 31885-97-9) has only one reported consumer use, in the production of gel laundry detergents (Uni lever, 2007). The chemical has several reported*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 4 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch non-consumer uses, including use as a solvent in several pharmaceutical syntheses including antiviral and blood pressure medication (Clariant, 2008), use as a gas scrubbing liquid (Clariant, 2008), use in the production of various coatings and in the soldering of electronic components (Multicore Solders Limited, 1990).

Tetraethylene glycol diethyl ether (CASRN 4353 -28-0) has no confirmed consumer uses. There has been a reported consumer use as an in gredient in brake fluid and may contain between 10 and 50 percent of the chemical (Wagner, 1998) . There are no confirmed non-consumer uses for this chemical. It has a reportedly non-consum er use in the production of a heat resistant resin, which in turn is used in the producti on of electronic circuit boards and semiconductor devices (Hitachi Chemical Company, 1992 and 2006).

Tetraethylene glycol dibutyl ether (CASRN 112-98-1) has no confirmed consumer uses but there is a reported consumer use as a brake flui d ingredient and may co mprise between 10 and 50 percent of the product (Wagner, 1998). The chemical does not have any confirmed nonconsumer uses but it has a reported non-consumer use in the production of heat resistant resin pastes. These pastes are used to produce elec tronic circuit boards and semiconductor devices (Hitachi Chemical Company, 1992 and Hitachi Chemical Company, 2006).

Pentaethylene glycol diethyl ether (CASRN 23601-39-0) has no confirmed consumer uses but has a reported consumer use as an ingredie nt in brake fluid (Cross Packaging, 2008) and use in the soldering of electroni c circuit boards (US Patent 4871 109). There are no confirmed nonconsumer uses.

Pentaethylene glycol dibutyl ether (CASRN 51105-00-1) ha s no confirmed or reported consumer uses, nor any confirmed non-consumer uses. A 1967 reference suggests that this glyme was reportedly used in the production of methacrylic acid, but it is unknown if the chemical is still used for that purpose (LONZ A AG, 1967). Methacrylic acid was used in the production of polymers, resins, and adhesives.

Butyltriglyme (CASRN 63512-36-7) has no confir med or reported consumer uses. There
were no confirmed non-consumer uses but ther e was a 1992 reference that the chemical was reportedly used as a scrubbing liquid in the remo val or recycling of various components of gas streams (Schiller and Gmehling, 1992), and there is a 1967 reference to use in the production of methacrylic acid. It is unknown if butyltriglyme is still used in these applications (LONZA AG, 1967).

1.2 Consumer Uses Excluded by the proposed SNUR

As mentioned above, the proposed SNUR app lies to all uses (both consumer and nonconsumer uses) of two glymes and all consumer uses of 12 glymes with the exception of the specific excluded consumer uses listed in Table 2. It is important to note that each proposed excluded consumer use is only for a specific glym e. For example, the proposed excluded use as an electrolyte solution in sealed lithium ba tteries is only an excluded consumer use for monoglyme. It is a proposed significant new use for all other glymes; ther efore, the use of any other glyme as an electrolyte so lution in sealed lithium batte ries would be subject to the proposed SNUR.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 5 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch Of the 14 glymes, nine have no proposed exclud ed consumer uses: ethylglyme, ethyldiglyme, butyldiglyme, tetraethylene glycol dibutyl ether, pentaet hylene glycol diethyl ether, tetraethylene glycol diethyl ether, polyethylen e glycol dibutyl ether, pentaet hylene glycol dibutyl ether, and butyltriglyme. Five glymes have proposed excluded consumer uses: monoglyme, diglyme, triglyme, tetraglyme, and polyglyme (Table 2).

Table 2: Proposed Excluded Consumer Uses by Chemical

Glyme CAS RN Proposed Excluded Consumer Uses

Monoglyme 110-71-4 In electrolyte solutions for sealed lithium
batteries

Diglyme 111-96-6 As a solvent in printing inks for consumer products

Triglyme 112-49-2 As a solvent in consumer adhesives; As a component of consumer brake fluids; As a component of consumer paint/graffiti

removers; In consumer paints

Tetraglyme 143-24-8 As an hydrofluorocarbon/chlorofluorocarbon (HFC/CFC) lubricant; As a solubilizing agent for consumer printing inks; As a coalescing agent in consumer paint Polyglyme 24991-55-7 Use in consumer paint strippers

Sources: Novolyte Technologies, 2008a-d; personal communication between Eastern Research Group and Joe Valcho (Novolyte Technologies), June 2009; personal communication between Eastern Research Group and Terry Wells (Clariant Corporation), June 2009.

• Proposed Excluded Consumer Uses for Monoglyme: Monoglyme is used as an electrolyte in sealed lithium batteries (Blomgren and Hunter , 2000) or as a solven t for electrolytes of sealed lithium batteries (ERG, 2009a, 2009b). Ba tteries may contain between one and five percent monoglyme and may be sold directly to consumers through battery distributors or as components of products containi ng these batteries (ERG, 2009a).

• Proposed Excluded Consumer Uses for Diglyme: Diglyme is currently used as a solvent in printing inks for consumer products (PNEAC, 19 96). Printing inks containing between one and five percent diglyme may be sold dire ctly to consumers through distributors (ERG, 2009a).

• Proposed Excluded Consumer Uses for Triglyme: Triglyme is currently used as a solvent in
consumer adhesives. In addi tion, Triglyme has confirmed uses as a solvent in consumer paints (Yamaguchi et al., 1999). Consumers ma y be able to purchase paint and adhesives solvents, each containing betw een one and five percent trig lyme, through distributors (ERG, 2009a). In addition, triglyme is used as a com ponent of consumer brake fluids and consumer paint and graffiti removers (ERG, 2009b).

• Proposed Excluded Consumer Uses for Tetraglyme: Tetraglyme is used as an HFC/CFC lubricant and may be present as a CFC lubr icant in consumer air conditioners, in a concentration between one and two percent (ERG , 2009a). In addition, the glyme is used as a solubilizing agent for printing inks, which may contain one to five percent tetraglyme and*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 6 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch be sold to consumers through distributors (E RG, 2009a). Tetraglyme is also used as a coalescing agent in paint formulations (Clarian t, 2008). Coalescing agents serve to separate the sticky molecules of resin while the product is being stored and applied, and the final paint product may be used by consumers (ERG, 2009b).

• Proposed Excluded Consumer Uses for Polyglyme : Polyglyme is used to formulate paint strippers, adhesive removers, and delacquer formulations and may be present in paint strippers accessible by consumers (ERG, 2009b).

1.3 Potentially Affected Industries

EPA may promulgate a SNUR for a substance wh en potential use could result in significant changes in human exposure or environmental releas e levels and/or that co ncern exists about the substance’s health or environmental effects ( 40 CFR §721.170). In contra st to Premanufacture Notification (PMN) requirements , which apply mainly to manuf acturers and importers (40 CFR §720.22), the SNUR can also apply to processors as well as to manufacturers and importers (40 CFR §721.5).

This proposed SNUR would requ ire manufacturers, importers, and processors to notify EPA at least 90 days before commencing the manufactu re, import, or processing of any of the 14 glymes for any uses not excluded in th e proposed SNUR (see Section 1.2).

Table 3 provides summary information on the indu stries potentially affect ed by this proposed
SNUR. Note that the table is no t intended to be entirely compre hensive; rather it provides a sample of the potentially affected industries for illustration purposes.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 7 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch Table 3: Industries Potentially affected by the proposed SNUR, by NAICS Code

NAICS Name Description Primary Manufacturers of the Glymes

325199 All Other Basic Organic Chemical Manufacturing This U.S. industry comprises establishments primarily engaged in manufacturing basic organic chemical products (except aromatic petrochemicals, industrial gases, synthetic organic dyes and pigments, gum and wood chemicals, cyclic crudes and intermediates, and ethyl alcohol). Industries Using the Glymes

335912 Primary Battery Manufacturing This U.S. industry comprises establishments primarily engaged in manufacturing wet or dry primary batteries.

325910 Printing Ink Manufacturing This industry comprises establishments primarily engaged in manufacturing printing and inkjet inks and inkjet cartridges.

325510 Paint and Coating Manufacturing This industry comprises establishments primarily engaged in (1) mixing pigments, solvents, and binders into paints and other coatings, such as stains, varnishes, lacquers, enamels, shellacs, and water repellent coatings for concrete and masonry, and/or (2) manufacturing allied paint products, such as putties, paint and varnish removers, paint brush cleaners, and frit.

325520 Adhesive Manufacturing This industry comprises establishments primarily engaged in manufacturing adhesives, glues, and caulking compounds.

336340 Motor Vehicle Brake System Manufacturing This industry comprises establishments primarily engaged in manufacturing and/or rebuilding motor vehicle brake systems and related components.

Source: DOC, 2003, U.S. Department of Commerce, Census Bureau, “2002 NAICS Definitions.”

1.4 Impact of a SNUR

The proposed SNUR discussed in this report specifies that any ma nufacture, import, or processing of two glymes for any use, and 12 gl ymes for consumer uses other than excluded consumer uses would be considered a significan t new use and require reporting under section 5(a)(1)(A) of TSCA. Therefore, a firm intending to manufacture, import, and/or process this chemical for these applications must submit a SNUN. Alternatively, a firm can decide not to manufacture, import, and/or process this chem ical. The firm, therefore, has two options:

• Option 1: Submit a SNUN. A SNUN indicates to EPA th at the firm would like to manufacture, import, and/or process the chemi cal for a significant new use, which, in this case, means any manufacture, im porting, and/or processing of this chemical for purposes that are not excluded (see Table 2 for a list of exclus ions by chemical). 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 provide s EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or li mit that activity before it occurs. If EPA allows the manufacture, import, and/or processi ng of any of the 14 glym es for a significant new use, then the costs associated with th is option are the costs of submitting the SNUN (including a user fee) plus, if there is any export of these ch emicals, the ex port notification costs that result from TSCA Section 12 (b) requ irements that are automatically triggered for chemicals regulated under TSCA Sec tion 5 (see Section 3 for details).*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 8 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch • Option 2: Decide not to manufacture, import, and/or process the chemical. The firm may simply decide to not manufacture, import, and/ or process any one of the 14 listed glymes for a significant new use. While this option avoids the costs of submitting a SNUN, it entails the “hidden” cost of the foregone profit as a resu lt of not engaging in the commercial activity originally planned. Similarly, if the firm w ould have used a given amount of one of the glymes in the production of another product a nd must substitute that glyme with a more costly substance, it will incur those additional “hidden” costs of production. If the firm elects to produce the glyme for research and devel opment (R&D) purposes only (an exemption for R&D purposes is provided in 40 CFR §721.47), it may have costs associated with R&D recordkeeping. In addition, if the firm exports any existing stockpiles of the chemicals, it will incur the export notification costs (see Section 3 for details).

The remainder of this report estimates the qua ntified portion of costs associated with the proposed SNUR for these uses of glymes. Secti on 2 presents estimates of the costs incurred by manufacturers, importers, and/or processors unde r the SNUR options. Section 3 addresses onetime export notification costs. Section 1 addresses costs to EP A of administering the SNUR, while Section 4 presents an anal ysis of other impacts, as re quired by various statutes and executive orders. The appendices provide cost estimation details.

2. COSTS OF A SNUR, BY OPTION

To meet the requirements of the proposed S NUR, a firm may choose to follow only one of the options previously described: submit a SNUN or decide not to manufacture, import, and/or process the chemical. The costs of these options are described below. Appendix A provides the wage rates and inflators us ed in this analysis.

2.1 Submit a SNUN (Option 1)

Under 40 CFR §721.5, manufacturers, importers, and/or processors that would like to undertake a significant new use of a substance listed in a SNUR are required to submit a SNUN at least 90 days before the firm plans to comm ence the manufacture, import, and/or processing of the substance. Because the proposed SNUR discussed in this report specifies that any manufacture, importation, and/or pr ocessing of glymes for any uses other than the excluded uses constitutes a significant new use, a firm wishi ng to manufacture, import, and/or process any volume of glymes for any significant new use w ould have to submit a SNUN. The notice form
used to submit a SNUN is the same as that for a PMN, so the costs of submitting a SNUN are estimated based on the costs estimated for submitting a PMN (EPA, 1994).

This option could have the following costs:

• Costs of preparing the SNUN and the $2,500 user fee.

• Costs of avoiding production wh ile the SNUN is being processe d; costs of recordkeeping and complying with any restrictions resulting from the SNUN review.

• Costs for the development of test data. EP A does not require the development of test data for submission of a SNUN, although a fi rm may submit test data already in its possession and/or describe any other available data. Becau se 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.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 9 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch • Costs for export notification, if the chemical is exported (see S ection 3 for details)

Table 4 shows the costs of preparing a S NUN; details are presented in Appendix B.

Table 4: Costs of Requirem ent to Submit a SNUN (2008$)

Cost Element Cost (2008$) 1

Costs of preparing submission (110 labor hours) $5,955

User fees $2,500 2

TOTAL $8,455

Notes:

1 Figures are rounded to whole dollars (see Appendix B for derivation).

2 Small businesses with annual sales of less than $40 milli on when combined with those of the parent company (if any) are subject to a re duced user fee of $100.

In addition, as was mentioned above , there could be testing costs, delay costs, or other costs not included here. Another option available to firms be fore the SNUR is promulgated is to seek an advance compliance exemption under 40 CFR §721.45(h). The submission cost for this option is the same as that for a SNUN, but by negotiatin g an advance compliance agreement with EPA, a firm can diminish the loss of profits due to delay. This option is not ava ilable after the SNUR is promulgated.

2.2 Decide Not to Produce Chemical (Option 2)

Some firms may find that the cost s of preparing a SNUN are financ ially unattractive. In this case, the firm could choose not to manufacture, import, and/or process the glyme for any significant new consumer uses. While this option avoids the costs of mee ting the specifications in the SNUR or submitting a request for some alte rnative, it entails the “hidden” cost of the foregone profit as a result of not engaging in th e commercial activity orig inally planned. For example, if the firm does not produce the substan ce, then it will forego the profit it would have achieved by producing it. That fore gone profit is a potential hidde n cost of Option 2. Similarly,
if the firm would have used the substance in the production of another product and must substitute a more costly substan ce, it will incur those additional costs of production. If the firm elects to produce the glyme for R&D purposes only, it may have costs associated with R&D recordkeeping attributable to the SNUR. These costs were not quantified because of lack of
information on the number of firms that exercise th is option and the lack of data to estimate their foregone profits. Firms that exercise option 2 ma y still incur expor t notification co sts, if they export any existing stockpiles of the product. Th is cost is quantified in Section 3 below.

2.3 Likelihood of a SNUN Submission

Given that all current consum er uses of the 14 glymes are excluded from the proposed SNURs applicability, the likelihood that ma nufacturing companies will submit SNUNs is expected to be low and limited to consumer uses that are discovered in the future. In addition to manufacturers, other companies, such as pr ocessors may also submit SNUNs, depending on how they use these glymes.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 10 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 2.4 Potential for Subsequent Regulatory Actions

EPA recognizes that if submission of a SNUN does result from the proposed SNUR, the Agency may take additional regulatory actions un der TSCA. These additional regulatory actions might be necessary to further evaluate an inte nded new use and associated activities, or to prohibit or limit that activity befo re it occurs to prevent unreas onable risk of injury to human
health or the environment. It is not known wh at specific subsequent regulatory actions, if any, the Agency may determine are ne cessary after reviewi ng a SNUN. Any such actions are highly dependent on the circumstances surrounding the individual SNUN (e.g., available information and scientific understanding of the chemical and its risks at the time the SNUN is being reviewed).

Should EPA’s review of the SNUN result in fu rther regulatory actions, the Agency will initiate and follow the appropriate procedures for taking those actions . Included in those procedures would be an assessment of th e costs and benefits of those actions.

Table 5 summarizes the costs associated with ea ch option, other than the export notification costs that are discussed sepa rately in Section 3.

Table 5: Compliance Options and Associated Costs Incurred by a Firm Due to the proposed SNUR

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

1. Submit a SNUN. Costs of submitting a SNUN, including testing costs, associated recordkeeping, and user fee. $8,455 submission cost (including SNUN recordkeeping and $2,500 fee) plus ongoing recordkeeping costs of under $1,133. EPA usually receives well under ten SNUNs per year. Based on review of recent SNUNs, it appears that firms rarely conduct toxicity or fate testing to support a SNUN (such testing would be voluntary). 3

2. Decide not to manufacture, import, or process the
chemical. Cost of the profit foregone as a result of not engaging in the commercial activity originally planned, and recordkeeping costs only if manufacturing for research and development. Costs not quantified.

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

2 Quantified costs are attributable to the SNUR only if a fi rm would not otherwise follow the specified practices. Costs are detailed in Table A-1 and Appendix A.

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 descri be 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.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 11 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 2.5 Agency Costs

EPA’s costs to review and process SNUNs are assumed to be the same as EPA costs to review PMNs. These costs are estimated at $5,693 per case. The required Agency steps, fulltime equivalent (FTE) staff needs, and extramur al costs such as for contractor support are derived in Appendix C from EPA’s analysis of Agency costs of processing PMN submissions (EPA, 1994), with adjustments to reflect inflati on and changes in Agency staff levels. The original EPA analysis used a range of salaries , but this analysis uses one typical salary.

The PMN costs reflect estimates developed in 1994, in Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications (EPA, 1994). The average costs to review a SNUN may be differe nt from those estimated for PMNs, both because of differences between PMNs and SNUNs, and b ecause the hours required to review a PMN may have changed since 1994. Resources were not av ailable to re-estimate costs for SNUNs. See Appendix C for details.

3. EXPORT NOTIFICATION COSTS

Under Section 12(b) of TSCA, exporters must notify EPA if they export or intend to export a chemical subject to various TSCA sections (40 CFR §707.60 through 75). For TSCA 5(a)(2) (the section under which EPA prom ulgates significant new use ru les) and certain other TSCA sections, this is a one-time notification requirement 1 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 St ate Department (40 CFR §707.70).

3.1 Estimated Number of Exporters and Export Notifications

To identify the number of potential exporters of glymes in the United States, EPA relied on the TSCA Inventory Update Reporting (IUR) in formation combined with chemical buyers’ guides, chemical producer databases, and other comparable reference materials. Because a single export notification can include multiple chemi cals, an entity was only counted once, even if it exports multiple glymes. At total of 30 different companies were identified as possible glymes exporters. 2

To estimate the number of export locations, the EPA consulted the U.S. International Trade Commission (ITC) Harmonized Tari ff System (HTS). The ITC tracks U.S. imports and exports of chemicals and other goods unde r distinct Harmonized Tariff Syst em codes. EPA determined that glymes fit under the HTS subheading 2909. 19.6000 [Chapter 29: Articl e IV: Ethers, etheralcohols, ether-phenols, ether-al coholphenols, alcohol peroxides, ether peroxides, ketone peroxides (whether or not chemically defined) , and their halogenated, sulfonated, nitrated or nitrosated derivatives: Acyclic ethers and their halogenated, sulfonated, n itrated or nitrosated derivatives: Ethers of polyhydric al cohols: Other], because glymes are diethers of [poly]ethylene

1 On November 14, 2006, EPA revised the export notifica tion 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). 2 It should be noted that while the Ferro Corporation is liste d as a producer of glymes in the 2006 IUR data it is not included in the count of 30 possible exporters. Ferro has transferred its glymes production to Novolyte Technologies Inc since the last IU R reporting cycle (ERG, 2009).*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 12 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch glycol and are therefore acyclic. Because ITC does not measure imports and exports of glymes within a distinct HTS code (examples of ot her chemicals in this group include triethyl orthoformate (CAS No. 122-51-0), and 2-met hoxyethoxymethyl chloride (CAS No. 3970-21-6)
or other chemicals with more than two ether moieties, ether moieties with non-identical alkyl groups, or halogenated, sulfonated, n itrated or nitrosated derivative s of any of these ethers), EPA
was unable to determine the exact number of e xport locations. Therefor e, for the purposes of this analysis, EPA assumes that glymes are e xported to 12 destinations , reflecting the average number of yearly export notif ications estimated for the 2009 TSCA §12(b) ICR (EPA, 2009). 3

This analysis assumes that each of the 30 potential exporters submits on average 12 notifications per year. This may be an overestim ate, as not all 30 of the potential exporters may choose to export a glyme. In addition, the es timate may be upwardly biased, because a single export notification can include multiple chemicals and/or destination countries. Combining the estimated number of regulated exporters under the proposed ru le and their projected annual number of submissions yields an estimate of 360 export notifications submitted to EPA per year,
shown in Table 6.

Table 6: Estimated Number of Exporters and Ex port Notifications Submitted to EPA as a Result of the Proposed SNUR

Number of
Submitters Export Notifications per
Submitter Total Export Notifications
sent to EPA (a) (b) (c) = (a)*(b)

30 12 360

3.2 Exporter Costs

The 2009 TSCA Section 12(b) ICR, ICR No.: 0795.13 [Information Collection Request for] Notification of Chemical Exports - TSCA Sec tion 12(b) Supporting Statement for Request for OMB Review under the Paperwork Reduction Act (EPA, 2009, page 11, Table 3), estimated the annual export notification cost for an exporter under the one-time export notification requirement. These costs include the cost to the exporter of compiling a list of their products that are subject to TSCA Section 12(b) requirements, writing or revisi ng an export notif ication letter to EPA, checking the outgoing shipments, and sendi ng the notification letters with the associated shipping costs

3.2.1 Compile and Maintain the List of Products

Since TSCA §12(b) information collection activit y has been in place for twenty years, most respondents will have already deve loped a list of their products subject to TSCA §12(b) export notification. Respondents need only check fo r new regulations promulgated and any new products exported by the company. Updating the list is estimated to take an average of one hour of technical time, which may also include some proportion of legal time (EPA, 2009). The total burden can vary from two hours per year up to two hours per month, depending on the number of

3 EPA calculated the average number of export notifications per exporter in 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 by dividing the estimated number of submitted notifications (3,500) by the estimated number of exporters (300).*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 13 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch products exported by the company and the number of their products subject to TSCA §12(b) (EPA, 2009a).

The number of submitters per year who report under TSCA §12(b) has varied over time, rising from around 160 in 1991 to over 460 in 2000, and declining since. In the most recent TSCA §12(b) ICR, EPA estimated there would be approximately 300 submitters per year in near-future years (EPA, 2009a). Of these 300 submitters, EPA estimated that 200 companies
were near the lower burden estimate of 2 hours per year, and 100 companies were near the upper estimate of 24 hours per year. Compiling the list for all respondents was therefore estimated to take 2,800 hours (2 hours x 200 firms plus 24 hour s x 100 firms), or an average of about 9.3 hours of technical time per firm per year (EPA, 2009).

3.2.2 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 initi al preparation of the export notice may vary depending on whether th e company has prior ex perience with this requirement. This step is estimated to take an average of one hour of t echnical time (which may also include some proportion of legal time) per firm per year (EPA, 2009).

3.2.3 Check Orders and Send Notifications

Companies that export chemicals subject to TSCA §12(b) reporting must check outgoing shipments against the list of their products described above. A form letter notifying EPA and providing the required data must be printed and mailed within the required time period. This process is estimated to take an average one half hour of clerical time per export notification, or 6 hours of clerical time per firm per year (assuming exporters submit approximately 12 notifications per year) (EPA, 2009). The burdens and associated costs for each notification activity are provided in Table 7 below:

Table 7: TSCA 12(b) Export Notification Co st: Annual Burden per Respondent Facility (2008$)

Technical Clerical Total

$/Hr Hours 2008$ $/Hr Hours 2008$ 2008$ Hours Compile list $58.84 9.3 $547 -- -- -- $547 9.3

Write letter $58.84 1 $59 -- -- -- $59 1

Check order and send
notice -- -- -- $28.48 6 $171 $171 6

Total per facility ` 10.3 $606 6 $171 $776 16.3

Notes:

1 An average facility is assumed to s ubmit 12 export notifications per year.
Source: Appendix A of this report derives technical and clerical hourly labor costs. Other costs are from 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, 2009, p.10), and are updated to
2008 dollars.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 14 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 3.2.4 Estimated Submission (Mailing) Costs

Regulated companies will also incur mailing costs for export notifications delivered to EPA. Notifications are assumed shipped via the U.S. Po stal Service (USPS) as first-class registered mail with a return receipt. Each shipment is estimated to cost $13.34: $10.60 for registered mail,$2.20 for a return receipt, and $0.44 for first-class postage (USPS, 2009). The estimated pershipment and annual mailing costs incurred by in dividual submitters are detailed in Table 8

Table 8: Derivation of Total Mailing Cost for 12 Notices

Dates that the rates were verified on United States Postal Service web
site: May 2008 December 2009

Postal services costs Registered mail, regular, with $0 declared value $10.00 $10.60 Return receipt, requested at time of mailing (receive by mail) $2.20 $2.30
Postage, regular First Class, up to 1 ounce $0.42 $0.44
Cost per export notice - Subtotal $12.62 $13.34

×12 × 12
Total Mailing Cost for 12 Notices $151.44 $160.08

Notes:
Information in italics shows the exact postal services fo r which the costs were estimated in [Information Collection Request for] Notification of Chemical Exports - TSCA Section 12(b) Supporting Statement for Request for OMB Review under the Paperwork Reduction Act

. ICR No.: 0795.13 (EPA, 2009). These costs are included for comparison with the costs in this report. Costs for the 2009 report were verified in May of 2008, as show in the Economic Analysis of Expedited Significant New Use Rules for 56 Chemical Substances (EPA, 2008).
Source: Mailing rates are from the US Postal Servi ce web site as of May 2008 and December 2009 (http://www.usps.com/prices/).

3.2.5 Estimated Annual Industry Compliance Cost

The aggregate, annual industry compliance cost of the TSCA §12(b) export notification requirement, is the sum of the annual compliance co st across all potentially regulated entities. Assuming a population of 30 submitters, a per-s ubmitter labor cost of $776.91, and a persubmitter mailing cost of $160.08 the annual industry cost will be $936.99. This estimate likely overstates the cost to industry of the proposed rule, as it assumes that exporters will not combine multiple destination countries into a single e xport notification, and it further assumes that exporters will submit 12 notifications each year , following the methodology outlined in the 2009 TSCA Section 12(b) ICR (EPA, 2009), implying growth in exported chemicals and/or export destinations. The export notific ation cost per noti ce is estimated to be $78 ($936.99/12). However, it is expected that the cost per notice may be decreasing in the total number of notices so that the cost per notification may be highe r for an exporter that has only one notification.

Table 9: Industry Total Cost Estimate per Year (2008$)
Labor Cost Mailing Cost Total Cost
Number of
Submitters Per
Submitter Total Industry
Cost Per
Submitter Total Industry
Cost Per
Submitter Total Industry
Cost*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 15 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 30 $776.91 $23,307 $160.08 $4,802 $936.99 $28,110

Source: Table 7 of this report derives industry labor costs and Table 8 derives industry mailing costs

3.2.6 Estimated Three-Year Industry Compliance Cost

Assuming constant annual indus try compliance cost and a seve n percent discount rate, the proposed SNUR imposes a total th ree-year industry cost of $78,932.

Table 10: Three Year Industry Costs (2008$)
Year Industry Cost Present Value Year 1 $28,110 $28,110 Year 2 $28,110 $26,271 Year 3 $28,110 $24,552 Total $84,329 $78,932

3.3 Agency Costs

3.3.1 Methodology for Agency Burden and Cost Analysis

The agency burden and cost incurred as a re sult of the TSCA §12(b) export notification requirement are calculated using estimates of ag ency wage rates; the EPA staff time required to process incoming export notifica tions from industry and outgoi ng notifications to importing countries; and the EPA staff time required to handl e requests for informa tion and clarification from industry, importing countries, and the genera l public. These estimates are derived below
and the annualized costs to EPA ove r three years are then calculated.

3.3.2 Estimated Number of Notifications Submitted to EPA and Sent to Importing

Countries

As previously described there are a total of 30 possible exporters of glymes, each of which is expected to submit 12 export notif ications to EPA approximately each year, for a total estimated 360 additional export notifications submitted to EPA per year. In the 2009 TSCA §12(b) ICR,
EPA further estimated it will deliver a total of 54 notification letters to importing countries per year (EPA, 2009). The marginal effect of th e proposed rule on EPA notification of importing
countries is thus based on an estimate of th e number of countries rece iving U.S. exports of chemicals under the HTS subheading that contains glymes. According to ITC, an average of 35 countries received U.S exports of chemicals unde r HTS subheading that contains glymes (HTS 2909.19.6000 [Chapter 29: Article IV: Ethers, ether-alcohols, ether-phenols, etheralcoholphenols, alcohol peroxides, ether peroxides, ketone peroxi des (whether or not chemically defined), and their halogenated, su lfonated, nitrated or nitrosated derivatives: Acyc lic ethers and their halogenated, sulfonated, nitrat ed or nitrosated derivatives: Ethers of polyhydric alcohols: Other]) per year from 2007 to 2008. Because th is category includes other chemicals besides glymes some of the countries on the ITC list may not import glymes but rather import other chemicals under HTS subheading 2909.19.6000. Theref ore it is likely that the estimate of 35 glyme importing countries is an over estimate, an d all costs in this sect ion are overstated as a
result.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 16 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch Table 11: Estimated Number of Export Notifications Submitted to EPA and Notifications sent to Importing Countries

Additional EPA Incoming Notifications (from Exporting Companies) Additional EPA Outgoing Notifications (to Importing Countries)

360 35

3.3.3 Estimates of Labor Hours (Burden) and Cost

The Agency burden and cost associated w ith TSCA §12(b) export notification can be divided into three parts; 1) re ceiving and processing incoming notifications from exporters, 2) preparing and mailing notif ications to importing countries, an d 3) responding to requests for information and clarification from companies an d importing countries. Th e allocation of burden hours and costs among these three parts is not exact, but the analysis below is expected to be reasonably accurate in terms of the overall burden estimate and the approximate allocation of that burden among these tasks.

In the first task, EPA receives export notifications from compan ies that intend to export one of the chemicals subject to TSCA §12(b). Th ese forms are checked for completeness and the submissions are logged into a document control system. Based on conversations with workers responsible for this task, about ten notifications can be processed per hou r, or one notification every 0.1 hours (EPA, 2009). As a result, Agency staff are estimated to spend a total of 36 hours per year for 360 incoming notificatio ns resulting from the proposed ru le. This estimate includes a certain amount of time spent respondi ng to routine requests for information.

In the second task, EPA staff prepares separa te notification letters that are subsequently reviewed and delivered to importing countries, thei r embassies, or representatives. This activity is estimated to take 0.5 hours per outgoing notif ication for a total of 17.5 hours per year for 35 outgoing notifications.

The third task comprises EPA staff response to public inquiries. The work of responding to non-routine requests for information and clarific ation from industry and importing countries and handling other tasks associated with the TSCA §12(b) program was estim ated to require about 20% of the time of a GS-13, Step 5 FTE empl oyee, or roughly 400 hours per year, in the 2009 TSCA §12(b) ICR. The ICR derived this es timate under the assumpti on of 300 submitters and 54 notified countries per year, fo r a total of 354 potentially inqu iring entities per year (EPA, 2009, pages 12-13). Assuming the same ratio of staff time per inquiring entity (400/354), the additional 30 exporters and 35 impo rting countries estimated to be affected by the proposed rule may require approximately 73 hours of staff time per year. The burdens and for each Agency activity are 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 (150,440), which is derived in Appendix A*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 17 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch Table 12: TSCA 12(b) Export Notificati on Cost: Annual Agency Burden (2008$)

Hours per
Notification Number of
Notifications Hours per
Year FTE per Year Loaded GS-13, Step 5 FTE Wage Rate Total Agency
Costs Agency Activity (a) (b) (c) = (a)*(b) (d) = (c)/2,080 (e) (f) = (d)*(e)

Process
notices from companies 0.10 360 36.00 0.017 $150,440 $2,604

Process
notices to importing
countries 0.50 35 17.50 0.008 $150,440 $1,266

EPA staff responding to
information
requests, etc. (400/354) 65 73.24 0.035 $150,440 $5,297

Total - - 126.74 0.061 -- $9,167

Source: Appendix A of this report derives Agency labor costs. Other burdens are from 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

3.3.4 Estimates of Submission (Mailing) Costs

EPA will incur mailing costs to de liver notifications to importing countries. Notifications are assumed shipped to the importing countries’ embassi es, rather than a foreign address, as the lowest-cost shipping option. Notif ications are further assumed mailed with the U.S. Postal Service (USPS) as first-class regist ered mail with a return receipt. Each shipment is estimated to cost $13.34: $10.60 for registered mail, $2.20 for a return receipt, and $0.44 for first-class postage (USPS, 2009). EPA estimates that the Agency will send notices to 35 countries. The estimated per-shipment and annual mailing costs incurred by the Agency are detailed in Table
13.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 18 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch Table 13: Derivation of Agency Mailing Cost for 35 Notices

Dates that the rates were verified on United States Postal Service web
site: May 2008 December 2009

Postal services costs Registered mail, regular, with $0 declared value $10.00 $10.60 Return receipt, requested at time of mailing (receive by mail) $2.20 $2.30
Postage, regular First Class, up to 1 ounce $0.42 $0.44
Cost per export notice - Subtotal $12.62 $13.34

×35 × 35
Total Mailing Cost for 12 Notices $441.7 $466.90

Notes:
Information in italics shows the exact postal services fo r which the costs were estimated in [Information Collection Request for] Notification of Chemical Exports - TSCA Section 12(b) Supporting Statement for Request for OMB Review under the Paperwork Reduction Act

. ICR No.: 0795.13 (EPA, 2009). These costs are included for comparison with the costs in this report. Costs for the 2009 report were verified in May of 2008, as show in the Economic Analysis of Expedited Significant New Use Rules for 56 Chemical Substances (EPA, 2008).
Source: Mailing rates are from the US Postal Servi ce web site as of May 2008 and December 2009 (http://www.usps.com/prices/).

3.3.5 Estimates of Annual Agency Cost

The annual agency cost of the TSCA §12(b) e xport notification require ment triggered by the proposed SNUR is $9,634, the sum of agency labor and mailing costs. This estimate likely
overstates the cost to EP A of the proposed rule, as it assumes that 35 countries will receive U.S. exports of the glymes.

Table 14: Agency Total Cost Estimate per Year (2008$)

Number of Incoming
Notifications Number of Outgoing
Notifications Labor
Cost Mailing
Cost Total Cost

360 35 $9,167 $467 $9,634

Source: Table 12 of this report derives Agency labor costs and Table 13derives Agency mailing

costs

3.3.6 Estimates of Three-Year Agency Cost

Assuming constant annual agen cy cost and a seven percen t discount rate, the proposed SNUR imposes a total three- year agency cost of $27,051.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 19 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch Table 15: Three Year Agency Costs (2008$)

Year Industry Cost Present Value Year 1 $9,634 $9,634 Year 2 $9,634 $9,003 Year 3 $9,634 $8,414 Total $28,901 $27,051

4. ADDITIONAL ANALYSES

This section presents additional analysis of other potential impacts of this rulemaking, as required under various statutes and executive orders.

4.1 Regulatory Flexibility Act

The Regulatory Flexibility Act (5 U.S.C. 601 et. seq .), as amended by the Small Business Regulatory Enforcement Fairness Act, requires regulators to consid er 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 more than 1,000 chemicals, the Agency receives only a handful of notices per year. For example, the nu mber of SNUNs was four in Federal fiscal year 2005, eight in FY2006, six in FY2007, and eight in FY2008. 4 During this four-year period, one SNUN was submitted by a small entity. 5 The criterion for “small business” was that the company checked the box on page 2 of the PMN form, stating that it was a small business for the purpose of paying the $100 fee in stead of the normal fee.

This leaves open the questi on of how many small busine sses are affected but do not submit SNUNs. For example, businesses may change thei r behavior in order to use a chemical in a manner that avoids triggering significant ne w use notification requirements and make no
submission to EPA. Data and resources were not available to estimate the number of small businesses affected by the current rule.

Small businesses may be affected by SNURs wit hout EPA being aware; for example, if the
firms have made no submissions or comments to EP A. However, even if a small business were interested in supplying a SNUR chemical, the SNUR ’s impact on profits is generally expected to be minor. For example, the firm may have a small expense of keeping records and/or of changing workplace practices to comply with a ny new restrictions. If modifying production practices would be overly costly, or if the firm wishes to engage in a significant new use but believes that expensive testing is needed to s upport a submission to EPA, it may instead forego production, thus sacrificing profits. The amounts of lost profits, if any, were not quantified for this report, but are expected to be low b ecause the proposed SNUR does not apply to nonconsumer uses for 12 out of the 14 glymes, and al l confirmed consumer uses of the glymes are also exempt. Any remaining consumer uses are e xpected to be new so th at they unlikely to be
central to a firm’s business. Based on these considerations and on the limited data available,

4 February 5, 2009 email from Carol Rawie, EPA Office of Pollution Prevention and Toxics, to Tulika Narayan and Kimberly Wilson, Abt Associat es. The counts include both “va lid” and “invalid” SNUNs. SNUN numbering is according to Federal fiscal year, ending September 30.

5 February 5, 2009 email from Carol Rawie, EPA Office of Pollution Prevention and Toxics to Tulika Narayan and Kimberly Wilson, Abt Associates.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 20 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch EPA expects that any compliance with a SNUR w ill not have a significant economic impact on a
substantial number of small entities.

4.2 Unfunded Mandates Reform Act

EPA has determined that this regulatory action does not impose any enforceable duty, contain any unfunded mandate, or ot herwise have any effect on small governments subject to the requirements of sections 202, 203, 204, or 205 of the Unfunded Mandates Reform Act of 1995 (Public Law 104-4).

4.3 Paperwork Reduction Act

According to the Paperwork Reduction Act (PRA), 44 USC 3501 et seq. , an agency may not conduct or sponsor, and a person is not required to respond to, a collectio n of information that requires Office of Management and Budget (OMB ) approval under the PRA, unless it has been approved by OMB and displays a currently va lid OMB control number. The information collection requirements related to this action ha ve already been approved by OMB pursuant to the PRA under OMB control number 2070-0038 (E PA ICR No. 1188). This action does not impose any additional burden requiring OMB approval.

4.4 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), Public Law 104–113, section 12(d) (15 U.S.C. 272 note), doe s not apply to this action.

4.5 Executive Order 12866: Regulatory Planning and Review

Under Executive Order 12866, entitled Regulatory Planning and Review (58 FR 51735, October 4, 1993), the Office of Management a nd Budget (OMB) has determined that this proposed SNUR is a ‘‘significant regulatory action,’’ because it meets the crit eria in section 3(f) of the Executive Order. Accordingly, this ac tion was submitted to the OMB for review under Executive Order 12866 and any changes made based on OMB recommendations have been documented in the public docket fo r this rulemaking as required by section 6(a )(3)(E) of the
Executive Order.

4.6 Executive Order 12898: Environmental Justice

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

4.7 Executive Order 13045: Pr otection of Children

Executive Order 13045, Protection of Children from Envir onmental Health Risks and Safety
Risks (62 FR 19885, April 23, 1997), requires EPA to identify and assess environmental health and safety risks that may disproportionately affect children. This type of analysis is required for rules that will have an impact of $100 million or more only. The impact of the proposed SNUR will be less than $100 million, and therefore no analys is of such impacts on children is required.*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review ***

Economic Analysis of SNUR 21 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 4.8 Executive Order 13132: Federalism

Executive Order 13132, Federalism (64 FR 43255, August 10, 1999), requires EPA to develop an accountable process to ensure “m eaningful and timely i nput by State and local officials in the development of regulatory policies that have fe deralism implications.” This
action will not have a substantial direct effect on States, on the relations hip between the national government and the States, or on the distribution of power and responsibilities among the various levels of government, as specified in Execu tive Order 13132, entitled Federalism (64 FR 43255, August 10, 1999).

4.9 Executive Order 13175: Tribal Governments

Executive Order 13175 is Consultation and Coordination with Indian Tribal Governments (59 FR 22951, November 6, 2000). This rule does not have Tribal implications because it is not expected to have substantial di rect effects on Indian Tribes.

4.10 Executive Order 13211: Energy Supply, Distribution, or Use

This rule is not subject to Executive Order 13211, entitled Actions Concerning Regulations That Significantly Affect Ener gy Supply, Distribution, or Use (66 FR 28355, May 22, 2001), because this action is not expected to a ffect energy supply, distribution, or use.APPENDIX A
INFLATORS AND WAGE RATESEconomic Analysis of SNUR A-1 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch A. INFLATORS AND WAGE RATES

This appendix describes the derivation of the fully loaded labor rates and inflation factors used in calculating costs of labor , materials, and other inputs. Costs for this report are for yearend 2008.

A.1 Derivation of Loaded Wage Rates

Unit labor costs are calculated by adding fringe benefits and ove rhead to the wage or salary to derive a fully loaded labor cost. The basic method is described in Wage Rates for Economic Analysis of the Toxics Release Inventory Program (EPA, 2002b). The resulting loaded labor rates are given in Table A-1. Costs are calcul ated for several labor categories: Managerial, Professional/Technical, Cl erical, and EPA staff.

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

EPAB Reports Labor Category BLS Ol d 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 Manageri al, Professional/Technical, Clerical, and
Production Labor

Wages and fringe benefits fo r managerial, professional/tec hnical, clerical and production
labor were taken from the Bur eau of Labor Statistics (BLS) Employer Costs for Employee Compensation (ECEC) data, 6 for December, for manufacturing industries. 7

The cost of fringe benefits such as paid leav e and insurance, specific to each labor category, are taken from the same ECEC series. Fringe benefits as a percent of wages are calculated separately for each labor category. For exampl e, for December 2008, the average wage rate for

6 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).

7 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 SNUR economic analys es, such as EPA, 2003a, used ECEC data for “All Goods Producing” sectors (manufacturing, mining, and construction). However, the manufacturing sector data seem more relevant since the SNURs mainly affect the chemicals industry.Economic Analysis of SNUR A-2 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch professional/technical 8 labor was $35.29; the average fringe benefit was $17.55. Fringe benefits as a percent of wages were $17.55/$3 5.29, or approximately 49.7 percent.

An additional loading factor of 17 percent is applied to wages to account for overhead. This approach is used for consiste ncy with Office of Pollution Pr evention and Toxics economic analyses for two major rulemakings: Wage Rates for Economic Analys es of the Toxics Release Inventory Program (EPA, 2002b), and the Revised Economic Analys is for the Amended Inventory Update Rule: Final Report (EPA, 2002a). This overhead lo ading factor is added to the benefits loading factor, and the to tal is then applied to the base wage to derive the fully loaded wage. For example, the December 2008 fully load ed wage for professional/technical labor is $35.29 × (1+0.4973+0.17) = $58.84.

Fully loaded costs for managerial, clerical, and production labor are calculated in a similar manner, as shown in Table A-1.

A.1.3 Derivation of Labor Rates for EPA Staff

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

. 9

Multiplying the annual pay by an assumed loadin g 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 percent assumption was labeled “the benefits multiplication factor” in the EPA Guide, but has been used in many EPA
Office of Pollution Prevention and T oxics ICRs to reflect both fringe benefits and overhead for Federal staff. For example, it was used in an August 2000 document supporting ICR No. 1139.06 (EPA, 2000), 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 be nefits but also overhead.” (ICR No.1139.06)

8 This follows terminology introduced in EPAB, 2007a. Earlier SNUR economic analyses used the term “technical” labor. Here the category is called “profession al/technical” labor, to make clear how it re lates to BLS categories. In 2004, BLS changed from the Occupational Classificati on System, OCS, to the Standard Occupational Cl assification system, SOC. In the process, the “Professional specialty and tec hnical” category became the “P rofessional and related” category . 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).

9 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 report represented a chan ge from the 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 SNURA-3U.S. EPA Office of Pollution Prevention and ToxicsFor Non-Exempt Use of 14 GlymesEconomic and Policy Analysis BranchTable A-1: Derivation of Loaded Wage RatesWageFringeBenefitFringes as% WageOver-head %Wage2Fringe +OverheadFactorLoaded Wages1EPAB LaborCategoryData SourcesDate(a) (b) (c) =(b)/(a) (d) (e)=(c)+(d)+1 (f)=(a) x (e)ManagerialBLSECEC, PrivateManufacturingindustries,“Mgt, Business, andFinancial”3Dec-08 $43.22 $19.46 45.03% 17% 1.62 $70.03Professional/TechnicalBLSECEC, PrivateManufacturingindustries, “Professional andrelated“3Dec-08 $35.29 $17.55 49.73% 17% 1.67 $58.84ClericalBLSECEC, PrivateManufacturingindustries,“Office andAdministrative Support”3Dec-08 $17.22 $8.33 48.37% 17% 1.65 $28.48EPA staffFTEAnnual Federal staff cost: OPMWashington-Baltimore-NorthernVirginia, DC-MD-PA-VA-WV, area,GS-13 Step 5 pay rates, with 60%overhead.3Dec-08$94,025(annual)--[Included in60%overhead]60%1.6$150,440(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 Step5 salary for calendar 2008, from the Officeof Personnel Management salary table forWashington-Baltimore-Northern Virginia (OPM, 2008).The 60% fringes-and-overhead rate is from an EPA guide,Instructions for Preparing Information Collection Requests (ICRs)(EPA, 1992a, page 30, footnote 9).Economic Analysis of SNUR A-4 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch A.2 Derivation of Inflation Factors

Complete information on the derivation of the infl ation factors used is given in Table A-2. In 2006, the Bureau of Labor Statistics (BLS) made se veral changes to the Empl oyment 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 ove rview” (Caroll 2006); “Employment Cost Index Publication Plans” (Sleemi, 2006); and “Seasonal adjustment in the ECI and the conversion to NAICS and SOC” (Branch, 2006).

Under a mandate from OMB, BLS changed its classification of industries and occupations from the Standard Industrial Classification (SIC ) and Occupational Classification System (OCS) to the North American Industry Classificati on System (NAICS) and Standard Occupational Classification (SOC) system. In 2006, BLS adjusted all ECI series to re flect this change.

In addition to changing the industry and occ upational classification systems, in 2006, BLS
rebased the ECI from June 1989 = 100 to December 2005 = 100 for all current and historical non-seasonally adjusted series, including the NAICS and SIC based series. (Seasonally 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. S easonal adjustments are explained in Branch, 2006.)

According to BLS, the official ECI for th e years 1975-2005 is the SIC-OCS based series, and for subsequent years, the official ECI is the NAICS-SOC based series (Sleemi, 2006, p.8). 10

“Starting year” indices in Tabl e A-2 continue to be SIC-SOC based. Current year indices
are NAICS-SOC based. We use indices from both the NAICS-SOC and the SIC-OCS based ECI series because neither series spans the entire period over which testing and other costs need to be
inflated.

10 BLS has been publishing the NIACS-SOC based ECI series si nce March 2001 and it became official in March 2006. The
SIC-OCS based series and NAICS-SOC series have different series ID numbers, even when they describe essentially the same population. For example the series ID for seasonally adjusted total compensa tion for all private industry workers is

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

.Economic Analysis of SNUR A-5 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch Table A-2: Derivation of Inflation Factors

Item Inflation Index Source 1 Starting
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, 2008a] 1992 63.2 109.4 1.731

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

. ECS11102I, 4 th Q [BLS, 2008a] 1993 65.5 109.4 1.670

Labels, placards etc.

File cabinet BLS CPI, inflation calculator, not SA. Annual [BLS, 2008b] 1997 160.5 215.303 1.341

Photocopies
Record keeping materials BLS CPI, inflation calculator, Annual [BLS, 2008b] 1988 118.3 215.303 1.820

Key: BLS = Bureau of Labor Statistics. CPI = Consumer Price Index. ECI = Employment Co st Index. SA = Seasonally Adjusted. Total Comp = Total Compensation (wages/salaries an d benefits). 4th Q = Fourth Quarter. “E CS10002I” 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 indice s in this table and expl ained on the BLS website, Employment Cost Index News Release Text: Employment Cost Index, March 2006 (BLS, 2006b). The Consumer Pric e Index (CPI) was not rebased.

“Starting year” ECI indices are SIC-OCS based: ECS10002I for pr ivate industry All Workers, and ECS11102I for private industry White Collar Workers. The indices are Seasonally Adjusted (SA).

After 2006, ECI indices are NAICS-SOC based: CIS2010000000000I fo r private industry All Workers, and CIS2010000W00000I for private industry White Collar Workers. The indices are Seasonally Adjusted.

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.APPENDIX B
COSTS FOR SNUNEconomic Analysis of SNUR B-1 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch B. COSTS FOR SNUN

Estimates of the costs of completing a Signi ficant New Use Notice (SNUN) form are based on the costs of completing a PMN submission, sin ce the data requirements are the same and the same form is used for both. EPA’s 1994 Regulatory Impact Analysis (RIA) for amendments to the PMN regulations relied on indus try estimates of the effort need ed to collect and compile all data required for a PMN submission, prepare the form, and submit the form and data to EPA (EPA, 1994). These estimates were based on a su rvey conducted by the Chemical Manufacturers Association (CMA, 1991), which became the American Chemistry Council.

In the 1994 EPA report, the average effort re quired to prepare and submit a PMN was 95 to 114 hours. This included recordkeeping for the submission, but the recordkeeping cost was not broken out. For this analysis, th e costs of a preparing a SNUN we re derived using the averages of the hours for each type of labor from the 1994 report. The method of calculating hourly loaded labor costs is described in Appendix A. In addition to preparing and submitting a SNUN,
manufacturers must maintain records on the subm ission for five years. Thus, this analysis includes a recordkeeping burden assumed to be fi ve percent of the preparation and submission burden (5.3 hours); this is assumed to be performe d with clerical labor. Thus, the total time burden for SNUN preparation, submission, and reco rdkeeping is estimated to be between 100
and 119 hours.

Table B-1 details the cost of submitting a S NUN, including the $2,500 EPA notification user

fee.

Table B-1: Industry Costs for SNUN

Labor Category Hours Range 1 Average Hours Loaded Wage Rate 2 (2008$) SNUN (Option 1)

Clerical 12 - 14 13 $28.48 $370

Technical 67 - 80 73.5 $58.84 $4,325

Managerial 16 - 20 18 $70.03 $1,260

Subtotal 100.3 – 119.3 109.8 $5,955

User fee (SNUN only) $2,500

TOTAL $8,455

Notes:

1 Hours range for each labor category are fr om the PMN Amendments RIA (EPA, 1994).

2 Loaded wages include fringe benefits and overhead. See Appendix A for derivation. Wage rates presented in this table are rounded values; however, unrounded values are used to calculate total labor costs. For this reason, total labor costs may not equal the product of rounded values.APPENDIX C
AGENCY COSTSEconomic Analysis of SNUR C-1 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch C. AGENCY COSTS

EPA submission review costs are presented in Table C-1. Costs to review and process industry submissions – SNUNs, requests to m odify a SNUR, and requests for equivalency
determination – are assumed to be si milar to EPA costs to review PMNs. 11

The list of review steps, estimates of staff- year full-time equivalents (FTEs), estimates of extramural costs, and the percent of chemicals requ iring a particular review step are derived from the costs for processing PMN submissions in Table VII-1 of a 1994 EPA report, Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications (EPA, 1994).

The GS levels used for Agency staff reflect the judgment of Agency staff familiar with the PMN/SNUN review process. The salary of a Full Time Equivalent EP A staff was calculated using GS-13 Step 5 salary data (OPM, 2008). Th e original PMN cost estimates were for GS-12 and were presented as low and high estimates, ba sed on the most junior (Step 1) and the most senior (Step 10) GS-12 pay rates, respectively. However, this an alysis uses the higher GS-13 staff level and, for simplicity, a single intermediate pay rate (Step 5) within that GS level. A loading factor of 1.6 was applied to the salary to reflect fringe bene fits and overhead (EPA, 1992a). The loaded salary calculations are described in Appendix A.

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

The Extramural Cost column shows costs for co ntractor support and ot her outside purchases for chemicals requiring the selected review ste p, inflated from 1993 pri ces, as explained in Appendix A

. The “percent of cases” is a weighting factor app lied to reflect the fact that not all chemicals require each review step. For example, in the PMN process, all chemicals require Administrative Prescreening, but not all chemicals require the in tensive scrutiny of “Standard Review.” The three types of submissions resu lting from a SNUR may have weighting factors that differ from each other and from the weight ing factors for PMNs. Changes in weighting factors could cause actual review costs to be high er or lower than calculated here. For example, some SNUNs require little review because they are determined to be “invalid” -- i.e., not required in the first place. However, often a SNUN may take more Agency time than a typical
PMN because of factors such as the need to retrieve old PMN records from archives, and the likelihood that more data requiring EPA review is submitted with a SNUN than would be submitted on average with a PMN. Resources were not available to update the review hours to reflect the current review process or to tailor the cost estimates to SNUNs. Therefore, for this analysis, the review steps and we ighting factors are assumed to be the same as those derived in
1994 for PMNs.

11 For an overview of the PMN review process, see the Chemistry Assistance Manual for Premanufacture Notification Submitters, EPA, 1997.Economic Analysis of SNUR C-2 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch The “Weighted Cost” column is calculated by multiplying the unweighted costs (EPA staff cost plus extramural costs) by the percentage of cases requiring this review step. This calculation yields total Agency costs for submis sion review and processing shown in Table C-1.

Table C-1: Agency Costs for SNUN and Ot her Submission Review and Processing

EPA staff (FTE) Cost Extramural
Cost 2

FTE
fraction Cost per

FTE 1 FTE Total (2008$) 1993
dollars 2008
dollars Unweighted
Cost Pct. of
Cases Weighted
Cost Review Steps

(1) (2) (3)=(1)*(2) (4) (5) (6)=(3)+(5) (7) (8)=(6)*(7)

Prenotice Consultation 0.0024 $150,440 $361 $4 $7 $368 41% $151

Administrative Prescreen/ Notice Receipt/User Fee 0.0024 $150,440 $361 $92 $154 $515 100% $515

CRSS (Chemical Review and Search Strategy) 0.0025 $150,440 $376 $268 $448 $824 100% $824

SAT (Structure Activity Team) 0.0006 $150,440 $90 $14 $23 $114 100% $114

Engineering/Exposure 0.0015 $150,440 $226 $56 $94 $319 100% $319
Exposure/Fate 0.0008 $150,440 $120 $0 $0 $120 100% $120

Focus 0.0009 $150,440 $135 $23 $38 $174 100% $174

Standard Review Functions 0.0219 $150,440 $3,295 $511 $853 $4,148 29% $1,203
Division Directors Meeting 0.0129 $150,440 $1,941 $113 $189 $2,129 15% $319
Order Development/ Negotiation Review 0.0171 $150,440 $2,573 $22 $37 $2,609 3% $78

Post Order Data Review 0.0886 $150,440 $13,329 $0 $0 $13,329 3% $400

Order Modification 0.2167 $150,440 $32,600 $0 $0 $32,600 3% $978

New Chemical SNUR Development 0.0277 $150,440 $4,167 $85 $142 $4,309 7% $302

Notices of Commencement 0.0012 $150,440 $181 $40 $67 $247 31% $77
FOIA (Freedom of Information Act) Requests 0.0004 $150,440 $60 $3 $5 $65 100% $65

CBI (Confidential Business Information) Substantiation 0.0004 $150,440 $60 $3 $5 $65 100% $65

TOTAL $5,693

Notes:

1 GS-13 Step 5 salaries loaded with benefits and overhead. See Appendix B derivation.

2 Extramural costs consist of contracting support and other purcha ses directly attributable to the PMN review process inflated f rom 1993 prices as described in Appendix A.

3 Weighted costs were calculated using unrounded unit cost estimates, so results may differ from calculations using the rounded v alues
shown in this table.

Sources: FTEs per review step and 1993 extramural costs are from EPA, 1994. Percents of cases are from EPA, 1994. GS-13 salaries are from OPM, 2008.APPENDIX D
REFERENCESEconomic Analysis of SNUR D-1 U.S. EPA Office of Pollution Prevention and Toxics For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch D. REFERENCES

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

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 Environmen tal Justice 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 Re porting Requirements, Final Rule, Federal Register

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

.

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