 New Jersey collects production volume and end use information under the New Jersey state Toxic Catastrophe Prevention Act ( TCPA), supporting a risk management program for companies that manufacture, process, possess, or use chemicals above certain chemicalspecific threshold levels. The threshold levels are developed for each individual chemical covered under the program based on volatility and toxicity and may range from as low as 100 pounds to greater than 100,000 pounds. The information collected is specific only to production and end uses within the state of New Jersey. Although companies are required to report chemical information as part of the state's risk management program, chemicals shipped in or out of a site as product are not tracked. Information reported primarily relates to release scenarios ( i. e., quantity of chemical released from the site into the air or water or as solid/ hazardous waste). Additionally, no worker exposure data are collected under this program ( Larmee, 1996).

 Oregon gathers facility and chemical specific data on the volume of toxic materials used or brought on site as part of the Toxics Use Reduction and Hazardous Waste Reduction Act ( TURHWRA) of 1989. The primary component of this law is that all facilities in Oregon that report under the Federal Community Right to Know TRI requirements or are hazardous waste generators must develop and submit facility plans to reduce toxic chemicals use and hazardous waste generation. TURHWRA does not contain information on the number of potentially exposed workers or provide detailed information on chemical production or use pathways. However, the requirements under TURHWRA do provide a snapshot of on site use of toxic chemicals for key facilities in Oregon ( Rozell and Brower, 1993; OSPIRG, 1993). B 4 B. 8 Other Federal Agencies and Data Collection  The Emergency Response Notification System ( ERNS) is maintained by the U. S. Department of Transportation and is used to store information on notifications of releases of oil and hazardous substances into the environment. ERNS combines data from the National Response Center's Database with data from the ten EPA Regions ( EPA, 1996a). Release reports are available for ( 1) substances designated as hazardous under the Comprehensive Environmental Response, Compensation, and Liability Act ( CERCLA), as amended; ( 2) oil and petroleum products, as defined by the Clean Water Act of 1972 ( CWA) and amended by the Oil Pollution Act of 1990; and ( 3) all other types of materials. Information that can be found in the ERNS database includes, but is not limited to, the following: the material and quantity released, where and when the release occurred, the agency notified, and any information about property damage, injuries, and/ or deaths that occurred due to the release. However, there are several limitations to these data. ERNS data are focused on information about releases and not on manufacturing and use of chemicals. Secondly, the data are subject to a certain degree of uncertainty because ERNS contains primarily initial accounts of releases made when exact details are often unknown. Lastly, these data are usually not updated unless an EPA region is involved in the response action.

 The Occupational Safety and Health Administration ( OSHA) maintains data on the safety and health of workers, including worker exposure to potentially hazardous chemicals used in the workplace. These data focus primarily on site specific/ problematic worker exposures. The data do not contain information regarding the number of workers across an industry that may be exposed to toxic chemicals in the workplace and do not track chemical use information. Further, the data do not track chemicals in every workplace where they may be used and only focus on those where problems may have occurred in the past.

 The U. S. Consumer Product Safety Commission ( CPSC) collects information on the safety and potential product hazards of more than 15,000 types of consumer products used in and around the home. Generic safety information, such as product labeling and packaging requirements, is collected, but the CPSC does not maintain the type or level of information that will be required under the IURA. It is not within CPSC's jurisdiction to develop information on production volume and actual concentration of a chemical that is contained within a product. CPSC has indicated interest in the information on consumer use and potential exposure to chemicals that EPA will collect under the IURA.

 The Department of Energy ( DOE) maintains data on natural gas exports and imports, including volume, price, and point of entry or exit of the natural gas. The information is collected and made available to the public quarterly. Data are not collected for natural gas after it moves beyond the importation site or for natural gas that is both produced and used within the United States. Additionally, data are not collected on types of use or exposures and cover only a small subset of the chemicals potentially subject to the IURA reporting ( Glynn, 1996). DOE also maintains data on petroleum products at the state level using broad categories such as motor gasoline and residual fuel.

 The U. S. Geological Survey ( USGS) collects information on over 90 minerals and materials and publishes it in two annual publications, the Mineral Commodity Summaries and the Mineral Yearbook. The Mineral Commodity Summaries provide data sheets on domestic industry structure, government programs, tariffs, and five year salient statistics for each mineral and material. The Minerals Yearbook, published in three volumes, also includes essential statistical data on minerals and materials and supplements it with local and global production and development information and trends. Data collected in the Minerals Yearbook include production, consumption, technical trends, environmental issues, summary outlooks, and their accompanying narratives. The USGS does not cover those chemical compounds that B 5 are not geological phenomena. They also do not provide information on minerals and materials usage in various production stages or their release to the environment, handling, storage, or transfer. The type and level of environmental information that will be required to be collected under the IURA is beyond the scope of USGS's mission.

 United Nations Environment Programme ( UNEP) maintains the International Register of Potentially Toxic Chemicals ( IRPTC), a database of more than 8,000 chemical profiles covering subject areas ranging from hazard identification to risk assessment. Chemical and product type, use, and production information are among the 17 categories of data entered into the register for each chemical profile. However, the data are international in focus and coverage is spotty. In addition, site specific information is not included.

B. 9 Publicly Available Databases  Publicly available chemical data sources include chemical industry journals ( e. g., Chemical Engineering News and the Chemical Marketing Reporter), chemical and business directories ( e. g., the Directory of Chemical Produces and the Thomas Register), chemical reference documents ( e. g., the Kirk Othmer Encyclopedia of Chemical Technology, SRI International's Chemical Economics Handbook, the Freedonia Market Research database, and the Frost & Sullivan Market Intelligence Database), and publications from chemical trade associations ( e. g., the CMA and the American Chemical Society). These sources can sometimes be somewhat useful for characterizing production volume, chemical function, and use category information once individual chemicals have been identified, but this information is often either too general to be used to determine production and use at the plant level or too specific to provide data on industry wide chemical production. In addition, often the information in these databases is outdated. In general, these sources do not contain the type of worker and consumer exposure information that will be collected under the IURA. Publicly available databases are described in more detail in the EPA report entitled A Review of Existing Exposure Related Data Sources and Approaches to Screening Chemicals: A Response to CMA ( EPA, 1998a). APPENDIX C DEVELOPMENT OF THE ESTIMATED NUMBERS OF EXPECTED SUBMISSIONS FOR THE CURRENT IUR AND IURA REPORTING 1Data maintained by EPA in the CUS database system.

2The CUS databases maintained by the Agency contain information collected under the IUR every four years. Four data collection cycles have been completed   1986, 1990, 1994, and 1998. The databases contain information on company and chemical identification, site location, and annual production volume. The 2002 reporting cycle concludes in December 2002 and resulting information will be available in 2003.

3The Chemicals in Commerce Information System ( CICIS) database maintained by the Agency contains information collected by EPA on chemicals in commerce in the United States in 1977. The data include company and chemical identification, site location, manufactured or imported status, and production volume in ranges for both organic and inorganic chemicals. The TSCA Inventory of chemicals is updated twice a year based on information from the Master Inventory File, which is maintained by CAS. Chemicals are added periodically to the Master Inventory File through the New Chemicals Program.

C 1 This appendix describes the process used to develop estimates of the number of reports that will be submitted under the IURA. The total number of reports was estimated for several thresholds based on data submitted in 1998 under the current IUR reporting requirements. 1 This appendix describes the input data and data sources that were used as a basis for the estimated number of reports and presents the methodology used to develop the estimates. It also presents the estimated number of reports for each of the options considered.

C. 1 Input Data and Methodology Data compiled from EPA's CUS2 and EPA's CICIS3 were used to determine the estimated number of reports expected under the IURA. The categories of input data refer to chemicals reported in the current IUR and organic and inorganic chemicals reported under CICIS. When referring to the CICIS data, organic chemicals refers to all noninorganic chemicals reported under CICIS.

The CUS database was used to determine the total number of reportable chemicals under the IUR,

while the CICIS database was used to develop information on the relative number of inorganic chemicals in commerce as compared to the number of organic chemicals. This ratio was then used to estimate the number of reports for inorganic chemicals that will be submitted under the IURA.

C. 1.1 Organic Chemicals and Multiple CAS Number Petroleum Stream Chemicals Data from the CUS database were used to generate the estimates of expected reports for organic chemicals and petroleum stream chemicals. The data are based on the actual numbers of reports, by threshold cut off, received during the 1998 reporting cycle. These input data include the number of individual reports, the number of discrete chemicals reported, the number of Form Us, and the number of reporting sites. The values were derived for each of the various production volume thresholds to facilitate analysis of the threshold options considered for the IURA. The data are presented in Tables C 1 and C 2.

C. 1.2 Inorganic Chemicals The number of inorganic chemicals likely to be reported under the IURA was derived from the CICIS data presented in Table C 3. The CICIS data are based on data for organic and inorganic chemicals and are presented by the production volume categories used in the original data collection. C 2 Those reported production volume categories are different than those required to evaluate the various IURA options. Therefore, it was necessary to manipulate the data to reflect the thresholds examined by the IURA reporting options ( e. g., greater than 10,000 pounds, greater than 25,000 pounds, greater than 300,000 pounds). To perform this manipulation, the ratio of inorganic chemicals to organic chemicals in the CICIS data for each reported threshold was applied to the projected numbers of chemicals and reports developed from the CUS 1998 data, generating the numbers of reports and chemicals for inorganic chemicals corresponding to the IURA threshold categories.

C. 2 Estimated Number of Reports in Future Reporting Cycles Estimates of the number of reports expected under the IURA in future reporting cycles were generated based on CUS data from 1998. Because the number of reports has remained fairly constant over time and 1998 is the most recent submission period, it was assumed that 1998 is a representative Table C 1. Organic Chemicals Reporting Data from EPA's CUS Database ( 1998)

Threshold ( lbs) Reports Discrete Chemicals Form Us Sites Total Reported 20,840 8,569 3,860 2,122 PV > 25K 17,557 7,326 3,711 2,039 PV > 100K 12,946 5,445 3,387 1,828 PV > 300K 9,759 3,977 2,776 1,619 PV > 500K 8,535 3,382 2,724 1,521 PV > 1M 7,052 2,669 2,390 1,398 Source: CUS Database. 2000. Information from the Chemical Update System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency, Washington, DC.

Table C 2. Multiple CAS Number Petroleum Stream Chemicals Reporting Data from EPA's CUS Database ( 1998)

Threshold ( lbs) Reports Discrete Chemicals Form Us Sites Total Reported 4,830 426 478 464 PV > 25K 4,703 422 456 443 PV > 100K 4,535 417 414 404 PV > 300K 4,416 412 381 372 PV > 500K 4,364 412 368 360 PV > 1M 4,296 409 356 248 Source: CUS Database. 2000. Information from the Chemical Update System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency, Washington, DC. C 3 year. The number of reports from the past four reporting cycles is presented in Table C 4.

The CICIS data were used to determine a ratio of the historical number of organic chemicals to the number of inorganic chemicals. This ratio, when applied to the information available through the CUS database, enabled EPA to estimate the expected number of inorganic chemicals that would be reported under the IURA. First, the number of discrete inorganic chemicals was estimated as if these chemicals had been reported in 1998. This was accomplished by multiplying the ratio of inorganic to organic chemicals reported to the CICIS database in 1986 by the total number of chemicals reported to the CUS database in 1998 ( see Eq. [ C. 1]). This estimate ( i. e., the number of discrete inorganic chemicals in 1998) was then used to determine the number of reports for inorganic chemicals as if they had been reported in 1998, based on the ratio of inorganic reports to inorganic chemicals in the 1986 CICIS data ( see Eq. [ C. 2]). Based on this methodology, estimated numbers of discrete chemicals and reports for inorganic chemicals were developed, as presented in Table C 5. Table C 3. Reporting Data From EPA's CICIS Database ( 1986)

Threshold ( lbs) Inorganic Chemicals Organic Chemicals Reports Discrete Chemicals Sites Reports Discrete Chemicals Sites PV < 1K 6,338 2,595 811 52,799 32,520 2,433 PV 1K   10K 1,364 649 458 11,219 7,557 1,391 PV 10K   100K 1,614 651 660 11,586 7,352 1,709 PV 100K   1M 2,103 621 985 8,568 4,933 2,073 PV 1M   10M 2,115 497 1,211 5,661 2,532 2,011 PV 10M   50M 1,539 283 987 3,624 1,069 1,477 PV 50M   100M 616 148 462 1,595 431 792 PV 100M   500M 1,292 150 758 3,421 436 1,008 PV 500M   1B 333 64 270 1,261 184 421 PV > 1B 408 52 239 1,589 169 370 Source: CICIS Database. 1986. Information from the Chemical in Commerce Information System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency, Washington, DC.

Table C 4. Number of Reports Submitted Under the IUR in 1986, 1990, 1994, and 1998 Submission Period Number of Reports 1986 26,250 1990 25,535 1994 25,058 1998 26,667 Average 25,878 Source: CUS Database. 2000. Information from the Chemical Update System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency, Washington, DC. 4Ratios were calculated using data for production volumes greater than 10,000 pounds.

C 4 Determination of the Estimated Number of Discrete Inorganic Chemicals as if Reported in 1998 IC 1 = ( IC 2/ OC 2) × OC 1 ( C. 1)

Determination of the Estimated Number of Inorganic Chemical Reports as if Reported in 1998 RIC 1 = ( RIC 2/ IC 2) × IC 1 ( C. 2)

IC 1 = Estimated number of discrete inorganic chemicals as if reported in 1998 IC 2 = Discrete inorganic chemicals reported to the CICIS database OC 1 = Total number of discrete chemicals reported to the CUS ( organic and multiple CAS number petroleum stream chemicals)

OC 2 = Discrete organic chemicals reported to the CICIS database RIC 1 = Estimated number of reports for inorganic chemicals as if reported in 1998 RIC 2 = Reports for inorganic chemicals reported to the CICIS database Ratios4: ( IC 2)/( OC 2) = CICIS inorganic chemicals/ organic chemicals = 0.144 ( RIC 2)/( IC 2) = CICIS inorganic reports/ inorganic chemicals = 4.063 Table C 5. Estimated Number of Chemicals and Reports Expected for Inorganic Chemicalsa Threshold ( lbs) Total Number of Discrete Chemicals Reported to the CUS in 1998 Inorganic Discrete Chemicals ( Estimated as if reported in 1998) Inorganic Reports ( Estimated as if reported in 1998)

PV > 10K 8,915 1,284 5,216 PV > 25K 7,754 1,117 4,537 PV > 100K 5,868 845 3,433 PV > 300K 4,395 633 2,571 PV > 500K 3,800 547 2,223 PV > 1M 3,084 444 1,804 aNumbers may not calculate exactly because of rounding.

Sources: CUS Database. 2000. Information from the Chemical Update System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency, Washington, DC.

CICIS Database. 1986. Information from the Chemical in Commerce Information System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency, Washington, DC.

U. S. EPA estimates. C 5 C. 2.1 Calculation of Total Expected Numbers of Reports Under the IURA The IURA will require reporting for both organic and inorganic chemicals and will provide a partial exemption for certain chemicals ( e. g., multiple CAS number petroleum stream chemicals) from reporting requirements. Eq. ( C. 3) was used to calculate the total number of reports expected under the IURA for all types of subject chemicals:

Determination of the Total Expected Number of Reports T = ROC 1 + RIC 1 + RPS 1 ( C. 3)

T = Total expected number of reports ROC 1 = Reports for organic chemicals RIC 1 = Reports for inorganic chemicals RPS 1 = Reports for petroleum stream chemicals APPENDIX D BASELINE COSTS 1Note that the analysis of burden is segmented between organic chemicals and inorganic chemicals to indicate the differential impact of the IURA on the reporting requirements for each chemical type.

2The current Form U does not include Part III; therefore, the baseline burden for this category is zero.

3The time required to report this information was assumed to be incurred per form and was therefore allocated across all the chemicals reported on an average form to obtain per chemical costs associated with this information. Thus, different numbers of reports per form lead to different per report costs.

D 1 D. 1 Industry Baseline Costs The costs of reporting under the current IUR are defined as the " baseline" costs. These costs consist of the four steps for compliance with the requirements of the rule, as defined in Section <IP_ADDRESS>: ( 1) compliance determination; ( 2) rule familiarization; ( 3) preparation and submission of reports,

including CBI determination and substantiation; and ( 4) recordkeeping.

Costs associated with compliance determination and rule familiarization are incurred by each site,

regardless of the number of reports submitted. Costs for preparation and submission of reports, as well as recordkeeping costs, are incurred separately for each report that is submitted. The current reporting form,

the Form U, may consist of a number of individual chemical reports from one site ( see discussion in Section <IP_ADDRESS>). Table D 1 presents the baseline burden1 of compliance determination per site of between one and four technical staff hours for organic chemicals ( including petroleum process stream chemicals). These burden estimates are presented as a range to reflect the variation in the reporting community. Sites that produce fewer chemicals may only need one hour to determine compliance, while sites that produce numerous chemicals may require up to four hours ( EPA, 1990). The baseline cost of compliance determination is between $ 65.96 and $ 263.84 per site for organic chemicals. Inorganic chemicals are not required to report under the current IUR; therefore, the baseline burden and cost of all reporting requirements are zero for this chemical type. Table D 2 presents the baseline burden of rule familiarization per site of two technical and two managerial staff hours for organic chemicals and partial exemption chemicals. The total cost of rule familiarization is $ 323.02 per site for organic chemicals.

Table D 3 presents the cost of report preparation and submission for the current IUR. As the table indicates, burden is distributed by labor category among the three parts of the Form U. 2 The total cost is estimated to be between $ 461.51 and $ 681.09 per report. It should be noted that the baseline burden estimates for site identification information are not equivalent to those presented in Table 3 2. This is because of the difference in the number of reports per Form U under the baseline versus the amendments, 3 and because of adjustments made to account for the additional information required under the IURA.

Table D 4 presents the per report recordkeeping burden for the current IUR. Estimated burden is between 0.5 hour and 1 hour of clerical staff time, 1 and 2 hours of technical staff time, and 0.5 hour and 1 hour of managerial staff time. Total cost of recordkeeping is between $ 127.42 and $ 254.84 per report. D 2 Table D 1. Baseline Cost of Compliance Determination ( 2000$)

Clerical ($ 27.37) Technical ($ 65.96) Managerial ($ 95.55)

Low High Low High Low High Organic Chemicals ( including Petroleum Process Stream Chemicals)

Burden per Site ( hours) 0 0 1 4 0 0 Cost per Site ($) $ 0.00 $ 0.00 $ 65.96 $ 263.84 $ 0.00 $ 0.00 Total Cost for Compliance Determination per Site $ 65.96   $ 263.84 Inorganic Chemicals Burden per Site ( hours) 0 0 0 0 0 0 Cost per Site ($) $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Total Cost for Compliance Determination per Site $ 0.00   $ 0.00 Table D 2. Baseline Cost of Rule Familiarization ( 2000$)

Clerical ($ 27.37) Technical ($ 65.96) Managerial ($ 95.55)

Low High Low High Low High Organic Chemicals ( including Petroleum Process Stream Chemicals)

Burden per Site ( hours) 0 0 2 2 2 2 Cost per Site ($) $ 0.00 $ 0.00 $ 131.92 $ 131.92 $ 191.10 $ 191.10 Total Cost for Rule Familiarization per Site $ 323.02   $ 323.02 Inorganic Chemicals Burden per Site ( hours) 0 0 0 0 0 0 Cost per Site ($) $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Total Cost for Rule Familiarization per Site $ 0.00   $ 0.00 D 3 Table D 3. Baseline Cost of Report Preparation and Submissiona ( 2000$)

Clerical ($ 27.37) Technical ($ 65.96) Managerial ($ 95.55)

Low High Low High Low High Reporting Form Part ( hours)

I. Site ID 0.38 0.70 0.90 0.98 1.01 1.08 II. Manufacturing Information 0.75 0.81 3.05 4.41 0.77 1.89 III. Processing and Use Information 0.00 0.00 0.00 0.00 0.00 0.00 Total Hours per Report 1.13 1.51 3.95 5.39 1.78 2.98 Costs per Report $ 31.03 $ 41.36 $ 260.74 $ 355.22 $ 169.74 $ 284.50 Total Cost for Report Preparation and Submission per Report $ 461.51   $ 681.09 a For sites reporting under the current IUR.

Source: Table 3 1 and Table 3 2.

Table D 4. Baseline Cost of Recordkeeping ( 2000$)

Clerical ($ 27.37) Technical ($ 65.96) Managerial ($ 95.55)

Low High Low High Low High Organic Chemicals ( including Petroleum Process Stream Chemicals)

Burden per Site ( hours) 0.5 1 1 2 0.5 1 Cost per Site ($) $ 13.68 $ 27.37 $ 65.96 $ 131.92 $ 47.78 $ 95.55 Total Cost for Recordkeeping per Report $ 127.42   $ 254.84 Inorganic Chemicals Burden per Site ( hours) 0 0 0 0 0 0 Cost per Site ($) $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Total Cost for Recordkeeping per Report $ 0.00   $ 0.00 4A total of 26,667 submissions were received during the 1998 submission period. This total includes some reports for chemicals produced below 10,000 pounds, which some companies voluntarily submitted. Removing reports for chemical submissions that do not meet the 10,000 pound threshold results in 26,365 reports.

D 4 The total cost of compliance was estimated by summing the costs of individual compliance determination, rule familiarization, report preparation and submission, and recordkeeping activities.

Each of the individual component costs was calculated by multiplying the cost per site or report by the total number of sites or reports, depending on whether the cost is incurred on a per site or per report basis.

The total industry baseline cost associated with the current IUR requirements has been calculated based on the number of submissions ( 26,365) received with reported production volumes above 10,000 pounds during the 1998 reporting period from 2,666 sites. 4 The baseline total cost is estimated to be between $ 16.6 and $ 26.2 million. These costs are presented in Table D 5.

Table D 6 presents first year industry costs, present value, and annualized costs for the current IUR. Using a discount rate of three percent, the present value for reporting under the current IUR over a 20 year period is estimated to be between $ 64.4 million and $ 102.0 million, with an annualized cost of $ 4.3 million to $ 6.9 million. If a discount rate of seven percent is used, the present value decreases to between $ 48.4 million and $ 76.7 million, while the annualized cost increases slightly to between $ 4.6 million and $ 7.2 million.

D. 2 Baseline Agency Costs To estimate the cost of tasks performed by Agency personnel, the number of full time equivalents ( FTEs) and the GS level required to perform each task were determined. The salary rates were taken from the 2000 General Schedule Locality Rates of Pay for Washington Baltimore, DC MD VA WV from the U. S. Office of Personnel Management ( OPM, 2000). The salary rates are presented in the OPM table by GS level and Step. For this analysis, a Step 3 is assumed for all FTEs.

The current IUR requires one FTE, GS 12 at a salary of $ 54,618 to perform quality control of data entry. One FTE, GS 13 at a salary of $ 64,949 is required to perform data processing, systems development, and contract oversight and management. The annual cost of tasks performed by Agency personnel sums to two FTEs for a total of $ 119,567. In addition, 0.5 FTE, GS 13 at a salary of $ 32,475 is required to oversee the development of a guidance document for the IUR. The cost associated with this Table D 5. Baseline Cost of Compliance ( 2000$)

Compliance Task Unit of Analysis Cost per Unit Number of Units Total Industry Cost ( millions$)

Low High Low High Compliance Determination Site $ 65.96 $ 263.84 2,666 $ 0.2 $ 0.7 Rule Familiarization Site $ 323.02 $ 323.02 2,666 $ 0.9 $ 0.9 Report Preparation and Submission Report $ 461.51 $ 681.09 26,365 $ 12.2 $ 18.0 Recordkeeping Report $ 127.42 $ 254.84 26,365 $ 3.4 $ 6.7 Total $ 16.6 $ 26.2 Source: Tables D 1, D 2, D 3, and D 4. 5Based on an additional 41 percent of the salary for fringe benefits and 17 percent of the salary plus fringe benefits for overhead ( EPA, 1997a).

D 5 task is a one time cost. After accounting for fringe benefits and overhead, Agency personnel tasks cost $ 197,250 annually, with a one time cost of $ 53,573 ( IMD, 1996; EPA, 1996b). 5 Extramural tasks are described as those performed by contractors. Under the current IUR, annual document receipt and tracking and data entry costs amount to $ 42,642; backup systems operations costs are $ 26,651, annually. Hence, the total annual costs associated with extramural tasks for the current IUR are equal to about $ 69,293. In addition, hardware and software costs, systems development, and the development of a guidance document for the current IUR represented a one time cost of approximately $ 282,000 ( IMD, 1996; EPA, 1996b).

Additional tasks include publication and printing of forms and materials, provision of supplies and materials for the hotline, staffing, and costs associated with mailings. IUR informational materials that will need to be printed include guidance documents, policy letters, and current and past forms. The hotline staff ( contractor) are responsible for responding to phone calls, faxes, letters, and e mail regarding questions about the IUR and requests for materials. In addition, the hotline staff perform all activities associated with mailing requested materials and bulk mailings.

Under the current IUR, it is estimated that the cost of publishing forms, developing other materials, including guidance documents and policy letters, is approximately $ 1,066 annually. In addition, approximately 7 percent of the calls received and handled by the TSCA hotline can be attributed to the IUR. Therefore, the portion of hotline costs that are attributable to the IUR is estimated to be about Table D 6. Baseline First Year, Present Value, and Annualized Costs According to Chemical Type ( million 2000$)

Type of Chemical First Year Cost Present Value Annualized Cost Low High Low High Low High 3 Percent Discount Rate Organic Chemicals ( including Petroleum Process Stream Chemicals) $ 16.6 $ 26.2 $ 64.4 $ 102.0 $ 4.3 $ 6.9 Inorganic Chemicals $ 0.0 $ 0.0 $ 0.0 $ 0.0 $ 0.0 $ 0.0 Total $ 16.6 $ 26.2 $ 64.4 $ 102.0 $ 4.3 $ 6.9 7 Percent Discount Rate Organic Chemicals ( including Petroleum Process Stream Chemicals) $ 16.6 $ 26.2 $ 48.4 $ 76.7 $ 4.6 $ 7.2 Inorganic Chemicals $ 0.0 $ 0.0 $ 0.0 $ 0.0 $ 0.0 $ 0.0 Total $ 16.6 $ 26.2 $ 48.4 $ 76.7 $ 4.6 $ 7.2 D 6 7 percent of the hotline budget, or approximately $ 42,855, annually. Costs associated with preparing mailings in response to information requests under the current IUR are approximately $ 426 annually.

This cost is based on approximately 21 mailings per month at a cost of $ 1.60 each. Therefore, the total estimated cost for providing supplies and materials, as well as operating the hotline to handle IUR related calls, is estimated to be $ 44,347 ( EPA, 1996d; EPA, 1998b).

Baseline Agency costs are divided into two categories: total annual costs and total one time costs. The total one time costs under the current IUR are sunk costs. The annual costs of the current IUR are incurred each calender year. The total annual costs under the current IUR are presented in Table D 7.

The total annual cost associated with the current IUR is approximately $ 310,890. This cost includes the cost of Agency tasks ( quality control of data entry, data processing, systems development,

and contract oversight and management); extramural tasks ( document receipt and tracking, data entry, and backup systems operations); and additional tasks ( publication and printing forms and materials, the hotline, and mailings). The total one time cost of $ 354,197 is attributable to guidance document development and costs associated with systems hardware and software, as presented in Table D 8 ( IMD,

1996; EPA, 1996b).

For calculation of the present value over a 20 year time period, the one time costs were considered to occur in the first year. The annual costs are assumed to occur in each calendar year. Using a three percent discount rate, the present value of Agency costs under the current IUR over a 20 year time period is estimated to be about $ 5.0 million and the annualized cost is approximately $ 334,000. With a seven percent discount rate, the present value of Agency costs decreases to approximately $ 3.4 million while annualized costs increase to about $ 342,000. D 7 Table D 7. Estimated Annual Agency Costs for the Current IUR Task Current IUR Costs Tasks Performed by Agency Personnel Quality Control of Data Entry $ 90,103 ( 1 FTE, GS 12)

Data Processing, Systems Development, and Contract Oversight and Management $ 107,146 ( 1 FTE, GS 13)

Subtotal $ 197,250 Extramural Tasks ( contractor)

Document Receipt and Tracking and Data Entry $ 42,642 Backup Systems Operations $ 26,651 Subtotal $ 69,293 Additional Tasks Publication and Printing Forms and Materials $ 1,066 Hotline $ 42,855 Mailing $ 426 Subtotal $ 44,347 Total Annual Cost $ 310,890 Note: All costs associated with FTEs include 41 percent fringe benefits and 17 percent overhead.

Sources: Office of Personnel Management ( OPM). 2000. " 2000 General Schedule Locality Notes of Pay for Washington Baltimore, DC MD VA WV." < http:// www. opm. gov/ oca/ 2000tbls/ GSannual/ html/ GSDCB. HTM> As obtained on May 30, 2000. U. S. Environmental Protection Agency. April 1997a. Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313. Office of Pollution Prevention and Toxics, Regulatory Impacts Branch. Information Management Division ( IMD). 1996. Questions for Branches within OPPT with Responsibility for IUR Data Collection, Processing, and Storage. Information Management Division, U. S. Environmental Protection Agency, Washington, DC. U. S. Environmental Protection Agency. August 29, 1996d. Transcribed Telephone Conversation with Ruth Heikkinen on Hotline and Mailing Costs, Office of Pollution Prevention and Toxics. U. S. Environmental Protection Agency. July 30, 1996b. IUR Amendments   Agency Costs Question. Memorandum from Ward Penberthy to Susan Krueger, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency. D 8 Table D 8. Estimated One Time Agency Costs for the Current IURa Task Current IUR Costs Tasks Performed by Agency Personnel Guidance Document Development $ 53,573 ( 0.5 FTE, GS 13)

Subtotal $ 53,573 Extramural Tasks ( contractor)

Systems Development $ 202,548 Hardware and Software $ 44,774 Guidance Document Development $ 53,302 Subtotal $ 300,624 Total One Time Cost $ 354,197 Note: All costs associated with FTEs include 41 percent fringe benefits and 17 percent overhead.

a Systems development, hardware/ software, and guidance document development costs under the current IUR are considered to be sunk costs and are not included in the estimates of total costs associated with the current IUR. These costs are presented, however, for the purposes of developing incremental costs for the IURA relevant to current requirements. These one time costs total $ 328,515.

Sources: U. S. Environmental Protection Agency. July 30, 1996b. IUR Amendments   Agency Costs Question. Memorandum from Ward Penberthy to Susan Krueger, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency Office of Personnel Management ( OPM). 2000. " 2000 General Schedule Locality Notes of Pay for Washington Baltimore, DC MD VA WV." < http:// www. opm. gov/ oca/ 2000tbls/ GSannual/ html/ GSDCB. HTM> As obtained on May 30, 2000. Information Management Division ( IMD). 1996. Questions for Branches within OPPT with Responsibility for IUR Data Collection, Processing, and Storage. Information Management Division, U. S. Environmental Protection Agency, Washington, DC. U. S. Environmental Protection Agency. April 1997a. Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313. Office of Pollution Prevention and Toxics, Regulatory Impacts Branch. APPENDIX E INDUSTRY SURVEY RESULTS 1The survey was conducted for EPA by ICF Incorporated, an EPA contractor supporting TSCA initiatives. This work was performed under EPA Contract No. 68 02 0064.

2EPA maintains the CUS database to track IUR information.

3Appendix A contains a copy of the revised draft reporting form as of publication of the Final Rule. This form is different than the one used for the survey.

E 1 During the spring/ summer of 1996, the Agency conducted a survey ( under Office of Management and Budget clearance # 2070 0034) to assess the potential burden associated with reporting for the proposed IURA under TSCA § 8.1 The survey was distributed to previous IUR reporters selected from the CUS database. 2 The survey was designed to collect information regarding the amount of labor required to complete each task identified in the proposed IURA. Survey respondents were asked to estimate the burden associated with collecting various data for each of three labor categories: clerical, technical, and managerial. The results of this survey provide the basis for determining the burden associated with the proposed IURA. All analysis presented in this appendix focuses on the burden associated with completing the full reporting form. The analysis in Section 3 of this report further dissagregates the data to estimate the burden associated with reports covering only part of the reporting form ( i. e., site identification and manufacturing information). This appendix presents an overview of the results of the survey. It describes the survey, the draft reporting form, and the survey respondents. It discusses the estimates of industry reporting burden per chemical, including the calculation of the mean total industry reporting burden and the total reporting burden for large, medium, and small companies. Finally, the section presents average reporting parameters for the survey participants, including the number of sites per company producing a reportable chemical, number of processing and use sites, and the number of end uses.

E. 1 Introduction The survey was administered to 81 companies over a period of four months, from March through June 1996. The survey was sent to potential respondents along with a copy of the draft reporting form and instructions. Potential respondents were informed that participation was voluntary. Attachment 1 provides a copy of the survey and Attachment 2 contains a copy of the draft reporting form sent with the survey. 3 Participants were asked to estimate the amount of time that would be required to report distinct pieces of information about the manufacture and use of TSCA inventory chemicals. The following sections describe the industry burden survey and the survey results.

E. 1.1 Survey Description The survey was developed based on a preliminary draft reporting form incorporating the IURA as well as the current reporting requirements. Generally, the survey was structured so that each question corresponded to a data element on the reporting form. Most of the questions requested estimates of the amount of time that the reporting company would need to compile specific information concerning a typical chemical produced at their site, dividing the time among clerical, technical, and managerial staff.

Additional questions asked for information about the number of reportable chemicals produced at a given site and the number of sites producing a reportable chemical, as well as the number of processing and use 4In the current version of the Form U required under the IURA, there is no longer a distinction between incorporative and nonincorporative uses.

E 2 sites and the number of end uses of a typical chemical. These ancillary questions were designed to develop a better understanding of the reporting parameters and to assist in properly interpreting the results of the reporting burden questions.

In addition to providing answers for each survey question, participants were encouraged to provide comments regarding the survey, the reporting form, and the processes that would be used by the company to complete the reporting form. The Agency considered these comments during the development of the IURA and in redesigning the reporting form.

E. 1.2 Draft Reporting Form Description The survey was developed from a preliminary version of the revised Form U ( i. e., the IURA reporting form) covering both the current IUR reporting requirements and the changes associated with the IURA. The draft reporting form used in this survey is different from the revised form required under the IURA; however, the data elements are similar. The draft form used in the survey was divided into five parts, as follows:

 Part 1   Site Identification Information  Part 2   Chemical Specific Information  Part 3   Information on Chemical Processing   Incorporative Activities  Part 4   Information on Chemical Use   Non Incorporative Activities  Part 5   Known Commercial and Consumer End Uses of Chemical Generally, the information included in Parts 1 and 2 of the reporting form corresponds to the information collected under the current IUR, supported by the addition of three data elements regarding company information, plant site identification, and manufacturing information. Parts 3 through 5 of the amended reporting form include the chemical processing and use information that constitutes the majority of new requirements under the IURA4 The current IUR requires that certain basic production and manufacturer identification information be provided. The specific data required are as follows:

 Certification including a signature, date, and name and title of the representative responsible for the accuracy of the information provided;

 Company Information including technical contact name, company name, company street address, and telephone number;

 Plant Site Identification including plant site name, Dun & Bradstreet number, and plant site street address;

 Chemical Specific Information including chemical identity CBI substantiation, CAS number or other identifying number, ID code, chemical name, site limited status, activity ( manufacturing or import), and production volume; and 5Small companies were identified as having annual sales less than or equal to $ 40 million, medium sized companies have annual sales greater than $ 40 million and less than or equal to $ 200 million, and large companies have annual sales greater than $ 200 million.

E 3  Confidential Business Information including up front substantiation of CBI claims for chemical identity information and substantiation of CBI claims in the event of a Freedom of Information Act ( FOIA) request.

In addition to the information required for the current IUR, the IURA final rule requires information on worker exposure and use, as well as limited new information relating to plant site identification. The information to be collected under the IURA is as follows:

 Company Information adding the company Dun & Bradstreet number and mailing address;

 Plant Site Identification adding the county location of the plant site and the plant site mailing address and provision of CBI substantiation;

 Manufacturing Information adding the confidentiality status of the production volume range, number of workers potentially exposed during manufacturing, the physical state of the chemical, and the maximum concentration of the chemical when manufactured;

 Industrial Processing and Use Exposure Related Information adding information regarding processing and use of the chemical, including process or use codes, five digit NAICS codes, industrial function categories, percentage production volume, site limited status, number of sites ( in ranges), and number of potentially exposed workers ( in ranges);

 Consumer and Commercial End Use Exposure Related Information adding commercial/ consumer end use categories including whether the chemical is intended for children's use, percentage production volume, and maximum concentration ( in ranges) of the chemical in the commercial/ consumer end use; and  Confidential Business Information adding up front substantiation of CBI plant site identification claims.

E. 1.3 Discussion of Survey Respondents Potential participants in the survey were identified through EPA's CUS database, which contains data collected under the current IUR. Companies were then grouped by size using information from Dun & Bradstreet's Dun's Market Identifiers online service. A stratified random sampling method was employed to ensure that a representative cross section of the chemical manufacturing industry was surveyed. The stratification of the chemical manufacturing industry into small, medium, and large manufacturers was based on the annual sales of the parent company. 5 A total of 207 companies were sent a copy of the survey with a cover letter requesting that they participate in the survey. An attempt was made to contact each company by telephone to confirm the contact information and coordinate a telephone appointment to administer the survey instrument.

Of the companies contacted, 81 chose to participate in the survey. Three of these companies' responses are not included in the burden estimates because their results indicated a burden more than 19 times greater than the average burden estimated by all other survey respondents ( see Section E. 2 of this appendix for further discussion). The 78 remaining survey respondents included 20 small, 17 medium,

and 41 large companies, 25.6 percent, 21.8 percent, and 52.6 percent, respectively. The distribution of 6Surveys sent to the Agency were identified as such and transferred directly to ICF.

E 4 small, medium, and large companies that report to the IUR, based on the CUS 94 database, compares favorably to the distribution of companies that participated in the survey. Based on the CUS 94 database,

the distribution of companies reporting to the IUR in 1994 was approximately 21 percent small companies, 21 percent medium companies, and 58 percent large companies. Table E 1 presents a comparison of these results.

Of the remaining 126 companies that were sent the survey but did not participate, 20 declined to participate, 5 determined that the survey was not applicable to their business, and 32 could not be contacted because of incomplete or out of date contact information. The remaining 69 companies either did not acknowledge phone calls or did not find a convenient appointment time to complete the survey. For the most part, individual survey results were compiled over the telephone so that definitions could be explained in a consistent manner to all participants and unique interpretations of the survey questions could be avoided. Several survey participants chose not to review the survey over the telephone and mailed a completed survey to either the Agency6 or to ICF Incorporated ( the Agency's contractor for this work). Responses from these companies were included in the data set.

Following completion of the interview process, the survey responses were entered into a Paradox © database maintained by ICF Incorporated. Queries of the data were prepared and executed to determine average reporting burden estimates and average reporting parameters for the survey participants.

E. 2 Reporting Burden Survey Results Reporting burden results are the answers to those questions directly relating to the amount of effort required to complete Form U for a typical chemical. Results are presented in four ways: for all reporters, for small company reporters, for medium company reporters, and for large company reporters.

In general, the breakdown of small, medium, and large companies in the set of survey participants accurately reflects the actual breakdown of reporters under the current IUR in the chemical manufacturing industry as a whole. The following sections discuss the methodology for estimating the average industry burden associated with the proposed IURA; the distribution of small, medium, and large companies within the set of survey participants and within the set of reporters under the current IUR; and a comparison of the average estimated reporting burdens for small, medium and large companies. Table E 1. Distribution of Survey Participants and IUR Reporters By Company Size Company Size ( Percent)

Small Medium Large Total Survey Participants 25.6 21.8 52.6 100 IUR Reporters 21.1 21.2 57.7 100 7The number of SIC code   function code combinations per chemical was capped at ten because EPA only requires the top ten combinations to be reported.

8It is assumed that it is no more time consuming to report a data element for chemical use across all categories than to report that element for either incorporative or nonincorporative use alone.

E 5 E. 2.1 Methodology for Calculation of the Reporting Burdens The survey results were compiled and reporting burdens calculated separately for small, medium,

and large firms to determine the effect that company size may have on the level of effort required to develop IURA data and the average numbers of sites, chemicals, and reports per company.

High and low burden estimates for each survey data element were provided by respondents. Some elements were provided on a subchemical level. For example, several survey questions requested a burden estimate for a single SIC code ( now NAICS code)   function code combination. The high and low burden estimates for these questions were multiplied by the corresponding number of combinations reported per chemical to obtain burden estimates at the per chemical level. 7 The high estimates were used to develop an average high estimate for each data element. The same methodology was used to develop an average low estimate for each data element. Each average high estimate was then weighted to reflect the correct distribution of small, medium, and large companies ( according to the CUS database). The same was done for each average low estimate. Because firms no longer have to report information for incorporative use, nonincorporative use, and repackaging categories separately as they did at the time of the survey, the burdens for reporting the data elements under Sections 3 and 4 of the survey are assumed to be lower than the sum of the time required for these three categories. EPA concluded that the best estimate of the time required to report the common data elements of these three categories was the maximum time required among incorporative, nonincorporative, and repackaging to report a given data element. This is because data elements no longer have to be reported for multiple categories, which implies the total time required to report a data element should be relatively close to the time reported on the original survey for completing a data element for a single category of the original survey. 8 Weighted average high burden estimates for each data element were then added together to yield a high total burden estimate for completing the entire form. Similarly, weighted average low burden estimates were then added together to yield a low total burden estimate.

It is important to note that, although the IURA only require that industry report " reasonably ascertainable" information for most data elements and " readily available" information for downstream processing and use information, the survey that respondents completed did not mention these standards. Thus, survey respondents were reporting burden estimates assuming a higher standard of information than EPA will require. In addition, the UEIP program, which asked respondents to report chemical information very similar to that required by the IURA, also asked respondents to report the time spent preparing the UEIP form for submission ( EPA, 1997b). Companies reported a median burden of 8 hours per chemical report, with a mean of 12 hours per chemical report. Both of these factors indicate that the burden estimates derived from the survey may overestimate the actual burden.

E. 2.2 Overall Burden Results Survey results indicate that 45 percent of the companies reported a total per chemical reporting burden of between 0 and 50 hours for preparing and submitting a full report in the first reporting year. E 6 0 5 10 15 20 25 30 35 40 0 50 50 100 100 200 200 300 300 400 400 500 500 600 > 1,000 Total Estimated Reporting Burden ( hours) Number of Companies / /

Figure E 1. Distribution of Companies Based on Total Estimated Reporting Burden Hours Another 17 percent reported an average per chemical reporting burden of between 50 and 100 hours, 17 percent reported an average burden of between 100 to 200 hours, 6 percent reported an average burden of between 200 and 300 hours, and 15 percent reported an average burden greater than 300 hours. As mentioned above, three of these companies provided burden estimates that were extremely large relative to the rest of the respondent population. These three companies provided burden estimates 16, 46, and 115 times greater than the average high burden estimate for medium and large companies. While there is no clear rule on removing outliers, EPA looked for a significant break that would indicate a problem with the responses. Statistically, these outliers are significant anomalies that could have serious impacts on the survey results, and EPA has determined that these responses are outside reasonable limits. For example, one of these three respondents estimated that it would take 12 hours to fill out their address, and 26 hours to fill in a 12 character ID number. Another estimated 780 hours to find the consumer uses of a single chemical. The third estimated 902 hours to report the percentage of production volume of a single chemical that goes to consumer uses. Figure E 1 shows the distribution of companies based on total estimated reporting burden hours.

EPA has no knowledge of the reasons for the disparity in the responses of these firms, but possible explanations include that the respondents misunderstood the survey instructions or that there was an error in data entry by EPA's contractor. For example, the survey respondents may have been unaware, despite repeated instructions, that the survey applied to a single chemical, not to all chemicals produced at E 7 a site. It is not appropriate for EPA to include such responses in either of these cases. The following three sections describe the burden results for a full Form U for small, medium, and large companies.

E. 2.2.1 Small Company Burden Results The average reporting burden for small companies under the amendments was 46.6 to 47.9 hours per report. On average, small companies estimated 3.3 hours of clerical time, 37.7 to 39.0 hours of technical time, and 5.6 hours of managerial time for each report. Burden results for individual data elements, as estimated by small companies, are shown in Table E 2.

E. 2.2.2 Medium Company Burden Results The average reporting burden for medium companies under the amendments was 144.4 to 150.9 hours per report. On average, medium companies estimated 22.0 to 25.3 hours of clerical time, 86.2 to 87.7 hours of technical time, and 36.2 to 37.9 hours of managerial time for each report. Burden results for individual data elements, as estimated by medium companies, are shown in Table E 3.

E. 2.2.3 Large Company Burden Results The average reporting burden for large companies under the amendments was 102.7 to 123.5 hours per report. On average, large companies estimated 9.9 to 11.6 hours of clerical time, 66.7 to 79.8 hours of technical time, and 26.2 to 32.1 hours of managerial time for each report. Burden results for individual data elements, as estimated by large companies, are shown in Table E 4.

E. 2.2.4 Reporting Parameters Results and Discussion This section presents the reporting parameters used as a means of providing a better understanding of the relationship between sites and chemicals being reported. Two questions on the survey requested information aimed at better characterizing the reporting burden for an average company and an average site. The first of these questions asked for the number of sites that manufacture the same chemical subject to IUR reporting. The second question asks for the number of IUR chemicals that are manufactured at a typical site. Averaged values for responses to these survey questions have been developed by weighting according to the stratification of the reporters under the 1994 IUR reporting period. The results are discussed in Sections E. <IP_ADDRESS> and E. <IP_ADDRESS> below.

In addition to the questions mentioned above, Sections 3 through 5 of the survey asked participants to estimate the number of incorporative use sites, nonincorporative use sites, and end uses for a typical chemical that would be reported under the IURA. These sections include Chemical Processing, Chemical Use, and Known Commercial and Consumer End Uses of the Chemical, respectively, and can be further interpreted based on the results of the average reporting parameters developed in the survey. The total burden estimates for Section 3 of the draft reporting form, covering information on incorporative uses of the chemical, can be divided by the number of incorporative use sites to determine the relationship between total burden and number of sites. The same approach can be followed to create parallel estimates for the chemical use and known commercial and consumer end use categories. The results of these calculations are presented in Sections E. <IP_ADDRESS>, E. <IP_ADDRESS>, and E. <IP_ADDRESS> below. E 8 E. <IP_ADDRESS>. Number of Sites per Company Producing a Particular Chemical. For a single chemical subject to IURA reporting, the weighted average number of sites per company was estimated to be between 2.9 and 3.1 sites. Survey results illustrate that these averages vary based on the size of the company. For example, small companies reported that an average of 1.2 sites manufacture a single IURA reportable chemical. For medium sized companies, a single IURA reportable chemical is manufactured at approximately 1.6 sites, while for large companies, a single IURA reportable chemical is manufactured at between 3.9 and 4.2 sites. The mean, median, and range for the survey results are presented in Table E 5. Nearly 52 percent of the companies surveyed reported that one site produces a single reportable chemical, while 39 companies ( 48 percent) estimated greater than one site per reportable chemical. Table E 2. Small Company Reporting Burden for Sections of Form U Task Clerical Hours Technical Hours Managerial Hours I. Site Identification Information 0.03   0.03 0.82   0.82 1.26   1.26 1. Certification 0.01   0.01 0.72   0.72 1.22   1.22 2. Company Information Company Name, Contact, Address 0.01   0.01 0.03   0.03 0.01   0.01 D& B Number, Mailing Address 3. Plant Site Identification Plant Name, D& B Number, Address 0.01   0.01 0.06   0.06 0.03   0.03 EPA ID Number, Mailing Address II. Manufacturing Information 0.48   0.48 4.22   4.47 0.59   0.59 1. Chemical Identification 2. Site Limited 0.30   0.30 1.83   1.86 0.16   0.16 3. Activity 4. Production Volume ( lbs) 5. Chemical Identification Up front CBI Substantiation 0.05   0.05 0.53   0.58 0.18   0.18 6. Plant Site Up front CBI Substantiation 0.05   0.05 0.36   0.41 0.07   0.07 7. Total Number of Workers 0.06   0.06 0.40   0.40 0.07   0.07 8. Physical State 9. Maximum Concentration 0.02   0.02 1.10   1.23 0.11   0.11 III. Processing and Use Information 2.78   2.79 32.69   33.68 3.74   3.74 A. Industrial Processing and Use Exposure Related Data 2.50   2.51 26.10   26.91 2.42   2.42 1. Determination of Applicability 0.11   0.11 0.59   0.59 0.12   0.12 2. Process and Use Code 0.00   0.00 0.00   0.00 0.00   0.00 3. 5 Digit NAICS Code 0.16   0.16 1.17   1.17 0.05   0.05 4. Function Code 0.16   0.16 0.68   0.73 0.12   0.12 5. Percent Production Volume 1.50   1.50 4.89   4.89 1.00   1.00 6. Total Number of Processing and Use Sites 0.54   0.54 5.61   5.86 0.48   0.48 7. Total Number of Potentially Exposed Workers 0.04   0.04 13.17   13.68 0.65   0.65 B. Commercial and Consumer End Use Exposure Related Data 0.28   0.28 6.59   6.77 1.31   1.31 1. Determination of Applicability 0.00   0.00 0.44   0.44 0.06   0.06 2. Identification of End Use 0.10   0.10 0.66   0.66 0.22   0.22 3. Percent Production Volume 0.05   0.05 0.63   0.65 0.13   0.13 4. Estimated Weight Percent in Consumer Product 0.12   0.12 4.86   5.02 0.90   0.90 Total Hours for Report Preparation and Submission Partial Form 0.51   0.51 5.04   5.29 1.85   1.85 Full Form 3.29   3.30 37.73   38.97 5.59   5.59 E 9 E. <IP_ADDRESS>. Number of IUR Reportable Chemicals per Site. The weighted average estimate of the number of IURA chemicals manufactured at an annual production volume greater than 10,000 pounds at a typical site was reported to be between 24.8 and 34.3 chemicals per site for all survey participants. Small companies averaged 13.0 to 15.0 IURA chemicals manufactured at a typical site, while mediumsized companies averaged between 27.2 and 46.5 chemicals and large companies averaged between 27.6 and 36.0 chemicals per site. Table E 6 presents the mean, median, and range for these parameters for all survey participants by size class.

For purposes of comparison, it is important to note that the number of chemicals per site, as reported by survey respondents, should correspond to the number of reports per site derived from the 1998 CUS database. However, it is worth noting that the average values developed from the survey do not correlate well with the historical information from the 1998 CUS database ( 9.9 reports per site). Table E 3. Medium Company Reporting Burden for Sections of Form U Task Clerical Hours Technical Hours Managerial Hours I. Site Identification Information 0.72   0.72 1.11   1.11 1.15   1.15 1. Certification 0.65   0.65 1.02   1.02 1.12   1.12 2. Company Information Company Name, Contact, Address 0.03   0.03 0.04   0.04 0.01   0.01 D& B Number, Mailing Address 3. Plant Site Identification Plant Name, D& B Number, Address 0.05   0.05 0.06   0.06 0.03   0.03 EPA ID Number, Mailing Address II. Manufacturing Information 0.93   0.93 6.07   6.74 1.66   1.71 1. Chemical Identification 2. Site Limited 0.30   0.30 1.31   1.37 0.23   0.23 3. Activity 4. Production Volume ( lbs) 5. Chemical Identification Up front CBI Substantiation 0.12   0.12 1.41   1.94 0.38   0.38 6. Plant Site Up front CBI Substantiation 0.09   0.09 0.29   0.32 0.06   0.06 7. Total Number of Workers 0.08   0.08 0.94   0.94 0.28   0.33 8. Physical State 9. Maximum Concentration 0.33   0.33 2.13   2.17 0.71   0.71 III. Processing and Use Information 20.36   23.66 79.07   79.85 33.35   35.01 A. Industrial Processing and Use Exposure Related Data 18.43   21.72 68.49   69.09 27.87   29.47 1. Determination of Applicability 0.27   0.27 2.19   2.19 0.54   0.68 2. Process and Use Code 0.00   0.00 0.00   0.00 0.00   0.00 3. 5 Digit NAICS Code 9.25   12.19 7.87   8.05 6.66   6.66 4. Function Code 0.11   0.11 0.64   0.71 0.30   0.29 5. Percent Production Volume 1.74   1.74 13.36   13.53 3.62   3.92 6. Total Number of Processing and Use Sites 2.83   2.83 16.51   16.69 9.18   9.48 7. Total Number of Potentially Exposed Workers 4.24   4.59 27.92   27.92 7.57   8.46 B. Commercial and Consumer End Use Exposure Related Data 1.94   1.94 10.58   10.76 5.48   5.54 1. Determination of Applicability 0.29   0.29 1.41   1.41 0.32   0.32 2. Identification of End Use 0.37   0.37 0.97   0.97 0.39   0.39 3. Percent Production Volume 0.56   0.56 1.62   1.68 0.62   0.68 4. Estimated Weight Percent in Consumer Product 0.71   0.71 6.58   6.70 4.15   4.15 Total Hours for Report Preparation and Submission Partial Form 1.65   1.65 7.18   7.85 2.81   2.86 Full Form 22.01   25.30 86.25   87.69 36.16   37.87 E 10 Because the historical data provide an extremely reliable value for this data point, the survey data are not used for determining the number of chemicals per site. Reviewing the median survey data, however,

shows a better comparison with the 1998 CUS number. The median value of the survey is between 8.0 and 10.0 chemicals per site, which is in line with the value of 9.9 reports per site derived from the 1998 CUS data set. The median value indicates that at least one half of the respondents reported numbers of chemicals per site that were equal to or less than the averages developed from the CUS data. The extremely high values provided by a few companies in the survey have skewed the average significantly and suggest that the mean may not be representative. Table E 4. Large Company Reporting Burden for Sections of Form U Task Clerical Hours Technical Hours Managerial Hours I. Site Identification Information 0.49   1.07 1.04   1.17 0.93   1.06 1. Certification 0.33   0.87 0.77   0.90 0.83   0.96 2. Company Information Company Name, Contact, Address 0.04   0.06 0.07   0.07 0.03   0.03 D& B Number, Mailing Address 3. Plant Site Identification Plant Name, D& B Number, Address 0.11   0.15 0.20   0.21 0.07   0.07 EPA ID Number, Mailing Address II. Manufacturing Information 2.11   2.20 8.65   13.83 3.24   7.16 1. Chemical Identification 2. Site Limited 0.63   0.72 2.26   3.30 0.35   1.31 3. Activity 4. Production Volume ( lbs) 5. Chemical Identification Up front CBI Substantiation 0.38   0.38 1.17   2.22 0.63   1.61 6. Plant Site Up front CBI Substantiation 0.15   0.15 0.69   1.67 0.34   1.32 7. Total Number of Workers 0.31   0.31 1.47   2.49 0.37   1.37 8. Physical State 9. Maximum Concentration 0.64   0.64 3.07   4.15 1.55   1.55 III. Processing and Use Information 7.28   8.29 56.99   64.78 21.98   23.86 A. Industrial Processing and Use Exposure Related Data 6.19   7.20 45.62   51.38 19.25   20.63 1. Determination of Applicability 0.13   0.13 0.94   1.12 0.32   0.32 2. Process and Use Code 0.00   0.00 0.00   0.00 0.00   0.00 3. 5 Digit NAICS Code 0.34   0.35 5.38   5.90 1.77   1.77 4. Function Code 0.28   0.28 1.31   1.48 0.64   0.66 5. Percent Production Volume 1.33   1.33 12.97   14.32 8.30   9.65 6. Total Number of Processing and Use Sites 1.47   2.47 9.52   11.40 3.60   3.60 7. Total Number of Potentially Exposed Workers 2.65   2.65 15.49   17.15 4.63   4.63 B. Commercial and Consumer End Use Exposure Related Data 1.09   1.09 11.37   13.40 2.73   3.23 1. Determination of Applicability 0.19   0.19 1.18   1.27 0.34   0.39 2. Identification of End Use 0.13   0.13 0.99   1.23 0.26   0.31 3. Percent Production Volume 0.18   0.18 1.59   1.84 0.61   0.66 4. Estimated Weight Percent in Consumer Product 0.59   0.59 7.60   9.06 1.51   1.87 Total Hours for Report Preparation and Submission Partial Form 2.60   3.28 9.69   15.01 4.18   8.23 Full Form 9.88   11.57 66.68   79.79 26.15   32.09 E 11 E. <IP_ADDRESS>. Number of Processing Sites. The number of processing sites per chemical affects the burden for developing processing information for reportable chemicals. If there are a large number of processing sites per chemical, the burden will be higher than if there are comparatively fewer sites. This relationship is strongly supported by the survey responses and is presented in Figure E 2. Table E 7 presents the mean, median, and range estimates developed from the survey responses for this data. As the table indicates, the weighted average number of processing sites per chemical is between 27.6 and 53.3 sites. These average values may be somewhat misleading because of the extremely wide range of reported values and as such, the median ( 2.5 to 6.0 sites per chemical) values may be a more accurate representation of the typical number of processing sites per chemical.

E. <IP_ADDRESS>. Number of Use Sites. Information on the number of use sites per chemical can be examined in the same manner as the information on processing sites presented in the previous section.

However, according to the survey data, the relationship between number of use sites and reporting burden is not as clear as the relationship established between number of processing sites and reporting burden.

As is shown in Figure E 3, there is an increase in burden for companies reporting on 6 or more use sites per chemical compared to those that report on less than 6 use sites per chemical. The results for companies reporting more than 21 use sites per chemical are less certain because of the relatively few survey responses in these ranges. Table E 5. Mean, Median, and Range of Sites per Chemical for Small, Medium, and Large Companies Sites per Chemical Mean Median Range Low High Low High Low High Small 1.2 1.2 1 1 1 4 Medium 1.6 1.6 1 1 1 3 Large 3.9 4.2 2 2 1 30 All Companies ( unweighted) 2.7 2.8 1 1 1 30 All Companies ( weighted) a 2.8 3.0         a Weighting refers to the distribution of average reporting burden by company size based on the proportion of companies within each size class for the set of 1994 IUR reporting companies.

Sources: CUS Database. 1996. Information from the Chemical Update System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency, Washington, DC ICF. 1996. Survey for Estimating the Industry Burden Associated With Collecting Additional Chemical Use Data Under TSCA Section 8 ( IUR Amendments). OMB Control No. 2070 0034. Conducted for EPA by ICF Incorporated, Washington, DC. E 12 As presented in Table E 8, the average number of use sites per chemical as reported by all companies is between 21.0 and 45.5 sites. The reported survey values range from 0 to 1,000 sites, with a weighted average number for all companies of between 22.9 and 49.3 use sites per chemical. Large companies, on average, reported significantly more use sites per chemical than small and medium companies. While the average number of use sites is high because of the large range presented in the survey results, the median values are much lower, indicating that for many companies this data component is not particularly burdensome.

E. <IP_ADDRESS>. Number of End Uses. Information developed from the survey on end uses was analyzed to determine the average number of end uses per chemical for small, medium, and large companies. The weighted average number of end uses per chemical as reported by all surveyed companies is between 3.2 and 5.1 end uses, with estimates ranging from 0 to 100, as presented in Table E 9. While the ranges presented in Table E 9 are broad, both the mean and median estimates for all company sizes fall within a consistent band of between 1 and 7 end uses per chemical. Table E 6. Mean, Median, and Range of Chemicals per Site for Small, Medium, and Large Company Sites Chemicals per Site Mean Median Range Low High Low High Low High Small 13.0 15.0 5.0 5.0 1.0 100.0 Medium 27.2 46.5 7.0 9.0 1.0 500.0 Large 27.6 36.0 10.0 12.5 1.0 300.0 All Companies ( unweighted) 23.7 32.9 8.0 10.0 1.0 500.0 All Companies ( weighted) a 24.4 33.8         a Weighting refers to the distribution of average reporting burden by company size based on the proportion of companies within each size class for the set of 1994 IUR reporting companies.

Sources: CUS Database. 1996. Information from the Chemical Update System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency, Washington, DC ICF. 1996. Survey for Estimating the Industry Burden Associated With Collecting Additional Chemical Use Data Under TSCA Section 8 ( IUR Amendments). OMB Control No. 2070 0034. Conducted for EPA by ICF Incorporated, Washington, DC. E 13 0 10 20 30 40 50 60 70 80 90 1 5 6 20 21 50 > 50 Average Number of Processing Sites Average Reporting Burden ( hours)

Figure E 2. Relationship Between Average Reporting Burden and Average Number of Processing Sites for All Companies Surveyed Table E 7. Mean, Median, and Range of Processing Sites per Chemical for Small, Medium, and Large Company Sites Processing Sites per Chemical Mean Median Range Low High Low High Low High Small 31.0 57.3 1.5 2.0 0.0 1,000.0 Medium 11.3 19.7 2.0 5.0 0.0 150.0 Large 32.3 64.0 8.0 12.5 0.0 1,000.0 All Companies ( unweighted) 27.4 53.0 2.5 6.0 0.0 1,000.0 All Companies ( weighted) a 27.6 53.3         a Weighting refers to the distribution of average reporting burden by company size based on the proportion of companies within each size class for the set of 1994 IUR reporting companies.

Sources: CUS Database. 1996. Information from the Chemical Update System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency, Washington, DC ICF. 1996. Survey for Estimating the Industry Burden Associated With Collecting Additional Chemical Use Data Under TSCA Section 8 ( IUR Amendments). OMB Control No. 2070 0034. Conducted for EPA by ICF Incorporated, Washington, DC. E 14 0 10 20 30 40 50 60 70 80 1 5 6 20 21 50 > 50 Average Number of Processing Sites Average Reporting Burden ( hours)

Figure E 3. Relationship Between Average Reporting Burden and Average Number of Use Sites for All Companies Surveyed E 15 Table E 8. Mean, Median, and Range of Use Sites per Chemical for Small, Medium, and Large Company Sites Use Sites per Chemical Mean Median Range Low High Low High Low High Small 3.2 4.1 0.0 0.0 0.0 20.0 Medium 8.1 51.3 1.0 1.0 0.0 500.0 Large 35.4 65.0 2.0 5.0 0.0 1,000.0 All Companies ( unweighted) 21.0 45.5 1.0 1.0 0.0 1,000.0 All Companies ( weighted) a 22.9 49.3         a Weighting refers to the distribution of average reporting burden by company size based on the proportion of companies within each size class for the set of 1994 IUR reporting companies.

Sources: CUS Database. 1996. Information from the Chemical Update System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency, Washington, DC ICF. 1996. Survey for Estimating the Industry Burden Associated With Collecting Additional Chemical Use Data Under TSCA Section 8 ( IUR Amendments). OMB Control No. 2070 0034. Conducted for EPA by ICF Incorporated, Washington, DC.

Table E 9. Mean, Median, and Range of End Uses per Chemical for Small, Medium, and Large Company Sites End Uses per Chemical Mean Median Range Low High Low High Low High Small 2.4 2.5 1.5 2.0 1.0 8.0 Medium 2.9 3.3 3.0 3.0 1.0 6.0 Large 3.6 6.8 3.0 4.0 0.0 100.0 All Companies ( unweighted) 3.1 4.9 3.0 3.0 0.0 100.0 All Companies ( weighted) a 3.2 5.1         a Weighting refers to the distribution of average reporting burden by company size based on the proportion of companies within each size class for the set of 1994 IUR reporting companies.

Sources: CUS Database. 1996. Information from the Chemical Update System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency, Washington, DC ICF. 1996. Survey for Estimating the Industry Burden Associated With Collecting Additional Chemical Use Data Under TSCA Section 8 ( IUR Amendments). OMB Control No. 2070 0034. Conducted for EPA by ICF Incorporated, Washington, DC. E 16 ATTACHMENT 1 INDUSTRY BURDEN SURVEY AND COVER LETTER SENT TO SURVEY PARTICIPANTS OMB Control No. 2070 0034 E 17 SURVEY FOR ESTIMATING THE INDUSTRY BURDEN ASSOCIATED WITH COLLECTING ADDITIONAL CHEMICAL USE DATA UNDER TSCA SECTION 8 ( IUR AMENDMENTS)

Name of Respondent __________________________________

Position/ Title __________________________________

Name of Company __________________________________

Address __________________________________

__________________________________

__________________________________

__________________________________

Phone Number __________________________________

Fax Number __________________________________ E 18 *********** IMPORTANT ***********

This survey has been developed to determine the industry effort associated with collecting chemical exposure data under TSCA Section 8. When completing the following questions, please mark all answers according to a base case scenario in which the data being reported applies to one typical chemical being produced at one typical manufacturing site, unless otherwise instructed in the question. If possible, please provide a breakout of the burden estimate by labor category for each question. Please note that staff from all labor categories may not be required to complete each individual data element. Any and all connection between the identity of the respondent and the answers to the survey will be kept confidential and will not be provided to EPA. PROPOSED SURVEY FOR ESTIMATING THE INDUSTRY BURDEN ASSOCIATED WITH COLLECTING ADDITIONAL CHEMICAL USE DATA UNDER TSCA SECTION 8 ( IUR AMENDMENTS)

PART 1. FACILITY IDENTIFICATION INFORMATION Section 1.1. Certification 1. The reporting form requires a signature certifying that the information provided is complete and accurate. Please estimate the amount of time that will be required to complete this certification, including the time needed for final review ( legal and technical) and verification of information ( note: do not include time that is covered in other survey questions):

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management ( including legal)

Certification Section 1.2. Plant Site Identification 2. This section of the reporting form requires identification and address information for a typical manufacturing plant site. Please indicate the estimated amount of time required to provide this information ( including plant site name, CBI, Dun & Bradstreet number, and plant site address):

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Plant Site Identification E 19 3. The reporting form requires indication of the EPA Identification Number ( EPA ID) that corresponds to the facility being reported. The EPA ID is a 12 character number assigned to facilities covered by RCRA. Facilities not covered by RCRA are not likely to have an assigned EPA ID. Please indicate the estimated time to determine the EPA ID for the facility being reported ( in the case that a typical facility at your company does not have an EPA ID, enter the estimated time to determine that an EPA ID does not exist, and check the Not Applicable box below):

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management EPA Identification Number EPA Identification Number Not Applicable Section 1.3. Company Information 4. This section of the reporting form requires the contact information for a technical contact including address and telephone number. Please estimate the amount of time that would be necessary to provide this:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Company Information 5. To calculate the amount of time that may be needed to provide company and site specific information for all chemicals and associated plant sites, it is necessary to determine the number of reportable chemicals produced at a typical facility and how many facilities may produce one typical chemical.

a. Please provide an estimate of the number of plant sites that manufacture a typical chemical:

Estimated Number of Plant Sites That Manufacture a Typical Chemical b. Please provide an estimate of the number of chemicals with annual volume greater than 10,000 pounds manufactured at a typical plant site:

Estimated Number of Chemicals Manufactured at a Typical Plant Site E 20 PART 2. CHEMICAL SPECIFIC INFORMATION Section 2.1. Manufacturing Information 6. This section of the reporting form requires information ( subsections a  f) regarding manufacturing specifications. Please provide burden estimates in the box below based on the following data requirements:

a. Identifying Number: Provide the CAS number of the chemical. b. ID Code: Indicate the correct tracking code from a list on the back of the reporting form. c. Activity ( M or I) and CBI: Provide information on the production of the chemical by indicating " M" ( manufacture) or " I" ( import); indicate if this is CBI. d. Site Limited and Indication of CBI: Indicate if the chemical is distributed for commercial purposes outside of the plant site; also, indicate if this is CBI. e. Production Volume in Pounds and Indication of CBI: Provide the production volume, in pounds, of the relevant chemical manufactured at this plant site; also, indicate if this is CBI. f. Specific Chemical Name: Indicate the name of the chemical for which information is being provided.

Please indicate the estimated amount of time necessary to complete subsections a  f for one typical chemical at a typical manufacturing plant site:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Manufacturing Information ( a  f)

7. This section of the reporting form requires indication of CBI status for Chemical Identity. A CBI claim for this information requires up front substantiation, including a justification of why release of this information would jeopardize the market position of the company. Indicate the estimated amount of time to indicate CBI status and provide substantiation for a CBI claim, if applicable, for chemical identity:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Chemical Identity a. If this information is not typically claimed CBI, please indicate that by checking the box below.

Chemical Identity CBI Substantiation Not Applicable E 21 8. This section of the reporting form requires indication of CBI status for Facility Identity. A CBI claim for this information requires up front substantiation, including a justification of why release of this information would jeopardize the market position of the company. Indicate the estimated amount of time to indicate CBI status and provide substantiation for a CBI claim, if applicable, for facility identity:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Facility Identification a. If this information is not typically claimed CBI, please indicate that by checking the box below.

Facility Identification CBI Substantiation Not Applicable 9. This section of the reporting form requires indication of CBI status of production volume range information. The ranges are:

10,000   100,000 lbs/ yr 50,000,000   100,000,000 lbs/ yr 100,000   1,000,000 lbs/ yr 100,000,000   500,000,000 lbs/ yr 1,000,000   10,000,000 lbs/ yr 500,000,000   1,000,000,000 lbs/ yr 10,000,000   50,000,000 lbs/ yr If the production volume range is not indicated to be CBI, the information may be made available to the public. Please indicate the estimated amount of time required to indicate CBI status of the production volume in ranges:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management CBI Status of Production Volume in Ranges a. For what percentage of the chemicals reported by your company would the production volume range be claimed CBI?

Percent of Chemicals Whose Production Volume Range Would Be Claimed CBI E 22 10. This section of the reporting form requires indication of the appropriate range of the total number of workers potentially exposed to the chemical being reported and indication of CBI status for that information. The ranges are:

Fewer than 10 workers 10 to 20 workers 25 to 100 workers 100 to 250 workers 250 to 1,000 workers More than 1,000 workers Please indicate the estimated amount of time required to provide this information:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Estimated Total Number of Potentially Exposed Workers PART 3. INFORMATION ON CHEMICAL PROCESSING  INCORPORATIVE ACTIVITIES Please be advised that the reporting form requires some information in this section to be provided by indicating ranges rather than exact numbers. The ranges are as follows:

number of processing sites number of potentially exposed workers Fewer than 10 Fewer than 10 10 to 20 10 to 20 25 to 100 25 to 100 100 to 250 100 to 250 250 to 1,000 250 to 1,000 More than 1,000 More than 1,000 maximum concentration ( wt %)

Fewer than 1% 1 to 30% 30 to 60% 60 to 90 % Less than 90%

Please note that codes will be designated to stand for various ranges ( e. g., the letter ` b' will mean between 10 and 20 processing sites). E 23 11. Not Applicable:

The first step in this section requires determination of whether or not the chemical being reported undergoes chemical processing. Please indicate the estimated amount of time necessary to determine whether chemical processing is applicable for the chemical being reported:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Not Applicable If chemical processing does not apply to any chemicals that your company reports under TSCA Section 8, please skip to PART 4.

If chemical processing does apply to one or more of the chemicals that your company reports, please continue with PART 3.

12. Function Codes:

This section requires determination of the functions and function codes ( provided in Attachment 1) for the chemical being reported. Although the information required for each category is the same, the reporting form divides the functions into two categories  incorporation into a formulation, mixture, or reaction product and incorporation into an article. Please indicate the estimated amount of time necessary to determine and report the function codes for a typical chemical:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Function Codes 13. SIC Code:

For each function code of the chemical that is reported, SIC codes must be reported for processing sites. It has not been determined whether a 3 digit or a 4 digit SIC code will be required. Please indicate separately the estimated amount of time required to determine and report a chemical's 4 digit and 3 digit SIC codes for one function category:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management 3 Digit SIC Code 4 Digit SIC Code E 24 14. Percent Production Volume:

The reporting form requires a determination of the percentage of production volume of the chemical that is processed in each specific combination of SIC code and function code. The percent production volume is required to be reported within ± 10% of the actual percentage. Since the total production volume of the chemical has already been determined in Part 2 of the reporting form, the information necessary for the calculations required here includes only the amount of the chemical that is used in each industry classification ( SIC code). Please indicate the estimated amount of time required to calculate and report the appropriate range for the percentage of production volume for a single function code and SIC code combination for a typical chemical:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Percent Production Volume 15. Number of Processing Sites:

The reporting form requires information on the appropriate range for the number of processing sites that receive the chemical from the specific production plant for each combination of function code and SIC code. Please indicate the estimated amount of time necessary to provide the appropriate range for the number of processing sites for a single function code and SIC code combination for a typical chemical:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Number of Processing Sites 16. Number of Potentially Exposed Workers:

The appropriate range for the number of potentially exposed workers at all processing sites for each combination of function code and SIC code is also required in this section of the form. Please indicate the estimated amount of time necessary to determine the appropriate range for the number of potentially exposed workers for a single function code and SIC code combination for a typical chemical:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Number of Potentially Exposed Workers E 25 17. Maximum Concentration ( wt%):

The appropriate range for the maximum concentration, by weight percentage, of the chemical that is incorporated into a formulation, mixture, or reaction product or into an article is also required in this section of the form. Please indicate the estimated amount of time necessary to determine the appropriate range for the maximum concentration, by weight percentage, for a single function code and SIC code combination for a typical chemical:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Maximum Concentration ( wt%)

18. Repackaging:

Some percentage of the chemical may be repackaged rather than processed or used in another product after manufacture. Please indicate the estimated amount of time that would be necessary to complete the following data for information about repackaging for a typical chemical:

Required Information ( Reported in Ranges) Estimated Hours Required By Each Staff Level Clerical Technical Management Percent of Production Volume Number of Repackaging Sites Number of Exposed Workers Maximum Concentration ( wt%)

CBI Claims PART 4. INFORMATION ON CHEMICAL USE  NON INCORPORATIVE ACTIVITIES Please be advised that the reporting form requires some information in this section to be provided by indicating ranges rather than exact numbers. The ranges are as follows:

number of processing sites number of potentially exposed workers Fewer than 10 Fewer than 10 10 to 20 10 to 20 25 to 100 25 to 100 100 to 250 100 to 250 250 to 1,000 250 to 1,000 More than 1,000 Less than 1,000 E 26 maximum concentration ( wt %)

Fewer than 1% 1 to 30% 30 to 60% 60 to 90% More than 90%

Please note that codes will be designated to stand for various ranges ( e. g., the letter ` b' will mean between 10 and 20 non incorporative use sites).

19. Not Applicable:

The first step in this section requires determination of whether or not use in non incorporative activities occurs for the chemical being reported. Please indicate the estimated amount of time necessary to determine whether chemical use information must be reported:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Not Applicable If chemical use in non incorporative activities does not apply to any chemicals that your company reports under TSCA Section 8, please skip to PART 5.

If chemical use in non incorporative activities does apply to one or more of the chemicals that your company reports, please continue with PART 4.

20. Function Codes:

The first step in this section requires determination of the functions and function codes ( provided in Attachment 1) for the chemical being reported. Please indicate the estimated amount of time necessary to determine and report the function codes for a typical chemical at all use sites:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Function Codes E 27 21. SIC Code:

For each function code of the chemical that is reported, SIC codes must be reported for use sites. It has not been determined whether a 3 digit or a 4 digit SIC code will be required. Please indicate separately the estimated amount of time required to determine and report a chemical's 4 digit and 3 digit SIC codes for one function category:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management 3 Digit SIC Code 4 Digit SIC Code 22. Percent Production Volume:

The reporting form requires a determination of the percentage of production volume of the chemical that is used in each specific industry category by SIC and function code combination. The percent production volume is required to be reported within ± 10% of the actual percentage. Since the total production volume of the chemical has already been determined in Part 2 of the reporting form, the information necessary for the calculations required here includes only the amount of the chemical that is used in each industry classification ( SIC code). Please indicate the estimated amount of time required to calculate and report the appropriate range for the percentage of production volume for a single function code and SIC code combination for a typical chemical:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Percent Production Volume 23. Number of Use Sites:

The reporting form requires information on the number of use sites that receive the chemical from the specific production plant for each combination of function code and SIC code. Please indicate the estimated amount of time necessary to provide the appropriate range for the number of use sites for a single function code and SIC code combination for a typical chemical:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Number of Use Sites E 28 24. Number of Potentially Exposed Workers:

The number of potentially exposed workers at all of the use sites for each combination of function code and SIC code is also required in this section of the form. Please indicate the estimated amount of time necessary to determine the appropriate range for the number of potentially exposed workers for a single function code and SIC code combination for a typical chemical:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Number of Potentially Exposed Workers PART 5. KNOWN COMMERCIAL AND CONSUMER END USES OF CHEMICAL Please be advised that the reporting form requires some information in this section to be provided by indicating ranges rather than exact numbers. The ranges are as follows:

maximum concentration ( wt %) number of potentially exposed workers Less than 1% Fewer than 10 1 to 30% 10 to 20 30 to 60% 25 to 100 60 to 90 % 100 to 250 250 to 1,000 250 to 1,000 Greater than 90% More than 1,000 Please note that codes will be designated to stand for various ranges ( e. g., the letter ` b' will mean between 10 and 20 potentially exposed workers).

25. Not Applicable:

The first step in this section requires determination of the existence of commercial and consumer enduses involving the chemical being reported. Please indicate the estimated amount of time necessary to determine whether known end uses for the chemical must be reported:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Not Applicable If commercial and consumer end uses do not apply to any chemicals that your company reports under TSCA Section 8, please skip to PART 6.

If commercial and consumer end uses do apply to one or more of the chemicals that your company reports, please continue with PART 5. E 29 26. End Use Categories:

The reporting form provides the following end use categories and requires that all of the appropriate uses be designated on the form. Please indicate the estimated amount of time that would be necessary to determine the use categories of a typical chemical:

Adhesives and Sealants Cosmetics and Toiletries Automotive Care Products Electrical/ Electronic Products Glass/ Ceramic Products Fabric/ Textiles/ Apparel Leather Products Lubricants, Greases, & Fuel Additives Metal Products Paper Products Paint and Coatings Pesticides and Lawn/ Garden Products Polishes and Sanitation Rubber/ Plastic Products Soaps and Detergents Transportation Products Wood/ Wood Furniture Other Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management End Use Categories 27. Percent of Production Volume:

The reporting form requires that the percentage of production volume for each end use be determined. The percent of production volume is required to be reported within ± 10% of the actual percentage. Please indicate the estimated amount of time that would be necessary to provide percent of production volume information for a typical chemical:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Percent of Production Volume 28. Percent by Weight of Chemical in Product:

The reporting form requires an estimate of the appropriate range of the percentage ( by weight) of the chemical in the designated end use category. Please indicate the estimated amount of time that would be necessary to indicate the appropriate range for a typical chemical in a typical end use category:

Required Information Estimated Hours Required By Each Staff Level Clerical Technical Management Percent by Weight of Chemical in End Use E 30 PART 6. GENERAL QUESTIONS ON REPORTING The following questions request information about all of the Parts and Sections of the reporting form as a whole. However, please continue to mark all answers according to a base case scenario in which the data being reported applies to one typical chemical being produced at one typical manufacturing site, unless otherwise instructed in the question.

29. Please provide numerical estimates that correspond to the following statements assuming the base case scenario:

DATA ELEMENT RESPONSE ( Please provide a numerical response)

Average number of function codes per chemical produced at a typical manufacturing site Average number of 3 digit SIC codes per function code Average number of 4 digit SIC codes per function code Average total number of incorporative processing sites to which a typical chemical is distributed from one manufacturing plant Average total number of non incorporative use sites to which a typical chemical is distributed from one manufacturing plant Average number of end uses of a typical chemical that would be reported based upon categories listed in Question 26 E 31 30. Indicate the data elements below that are required in the reporting form that are presently available in a company database or otherwise readily available:

DATA ELEMENT AVAILABLE ( check if yes)

PART 1: FACILITY IDENTIFICATION INFORMATION Manufacturing Plant Site Name Company Technical Contact Name PART 2: CHEMICAL SPECIFIC INFORMATION Manufacturing Activity ( M or I)

Manufacturing Plant Site Limited Chemical Use Total Production Volume Plant Link to Chemical Chemical Link to Plant Total Number of Potentially Exposed Workers Process Category PART 3. INFORMATION ON CHEMICAL PROCESSING  INCORPORATIVE ACTIVITIES Function Code 3 Digit SIC Code 4 Digit SIC Code Percent Production Volume Numbers of Potentially Exposed Workers Numbers of Processing Sites PART 4. INFORMATION ON CHEMICAL USE  NON INCORPORATIVE ACTIVITIES Function Code 3 Digit SIC Code 4 Digit SIC Code Percent Production Volume Numbers of Potentially Exposed Workers Numbers of Use Sites PART 5. KNOWN COMMERCIAL AND CONSUMER END USES OF CHEMICAL End Use Category Percent Production Volume Estimated Weight Percentage in Consumer Product E 32 31. Indicate which of the required data elements your company is likely to claim CBI:

DATA ELEMENT CLAIM CBI ( check if yes)

PART 1: FACILITY IDENTIFICATION INFORMATION Manufacturing Plant Site Name Company Technical Contact Name PART 2: CHEMICAL SPECIFIC INFORMATION Manufacturing Activity ( M or I)

Manufacturing Plant Site Limited Chemical Use Total Production Volume Total Production Volume Within a Range Plant Link to Chemical Chemical Link to Plant Total Number of Potentially Exposed Workers Process Category PART 3. INFORMATION ON CHEMICAL PROCESSING  INCORPORATIVE ACTIVITIES Function Code 3 Digit SIC Code 4 Digit SIC Code Percent Production Volume Numbers of Potentially Exposed Workers Numbers of Processing Sites PART 4. INFORMATION ON CHEMICAL USE  NON INCORPORATIVE ACTIVITIES Function Code 3 Digit SIC Code 4 Digit SIC Code Percent Production Volume Numbers of Potentially Exposed Workers Numbers of Use Sites PART 5. KNOWN COMMERCIAL AND CONSUMER END USES OF CHEMICAL End Use Category Percent Production Volume Estimated Weight Percentage in Consumer Product E 33 32. Please indicate if your company has a schedule for the retention of records, including chemical production information:

Yes No a. If yes, for how long does your company retain records? b. Please explain:

33. Please indicate if your company has a policy for the destruction of records:

Yes No b. Please explain:

34. We welcome any suggestions you may have concerning improvements in the reporting form that has been provided here. You may provide comments by telephone or mail to:

Mark Wagner ICF Incorporated 1850 K Street, NW, Suite 1000 Washington DC 20006 2213 phone: 202 862 1155 fax: 202 862 1144 E 34 ATTACHMENT 1 Proposed List of Function Codes for IUR Reporting Intermediates ( Only valid for incorporation into product) Lubricants and Lubricant Additives Adsorbents and Absorbents Odor Agents Adhesive and Binding Agents Oxidizing Agents Aerosol Propellants Photosensitive Chemicals Agricultural Chemicals pH Regulating Agents Anti Adhesive Agents Process Regulators, used in Polymerization or Vulcanization Processes Bleaching Agents Process Regulators other than Polymerization or Vulcanization Chemical Processing Aids, not otherwise listed Reducing Agents Coloring Agents Reprographic Agents Corrosion Inhibitors and Anti Scaling Agents Solvents, Cleaning/ Degreasing Electroplating Agents Solvents, Become Part of Product Formulation Fillers Solvents, For Chemical manufacture and Processing that are Not Part of the End Product Fixing Agents Stabilizers Flame Retardants Surface Active Agents, Cleaning Agents Flotation Agents Surface Active Agents, Emulsifying Agents Fuel and Fuel Additives Viscosity Adjustors Functional Fluids, Hydraulic and Transmission Fluids Sterilants/ Disinfectants/ Biocides Functional Fluids, Heat Transfer Agents Other Functional Fluids, Electrical Conductive and Semiconductive Agents E 35 ATTACHMENT 2 DRAFT IUR AMENDMENTS REPORTING FORM SENT TO SURVEY PARTICIPANTS APPENDIX F SENSITIVITY ANALYSIS F 1 To examine the effects of two parameters on the expected costs of the IURA, a sensitivity analysis was performed. The sensitivity cases presented in this appendix assess the impacts on costs of certain assumptions presented in the cost analysis. The cost analysis presented in Section 3 of this report incorporates several assumptions regarding the average chemical that will be reported under the IURA.

Those assumptions include the number of reports per site ( 9.0 reports per site for organic chemicals and petroleum streams and 8.3 reports per site for inorganics under the amendments) and a discount rate of 3 percent.

Sensitivity cases were developed for these parameters by examining the effect that they have on the quantified costs. The sensitivity cases are as follows:

Number of Reports per Site Scenario 1a estimates the cost for a site submitting one report.

Scenario 1b estimates the cost for a site submitting 20 reports.

Variation in Discount Rate Scenario 2 changes the discount rate used to calculate costs of the IURA from 3 percent to 7 percent.

A cost analysis was developed for each case presented in the sensitivity analysis. As shown in Table F 1, the sensitivity analysis for Scenarios 1a and 1b was based on variations in the assumed number of reports per site. The costs for the IURA ( Option 1) are also presented in this table. Table F 2 presents the first year incremental, baseline, and total net present values and annualized costs for all of the reporting threshold options under Scenario 2 ( i. e., using a 7 percent discount rate).

F. 1 Changing the Number of Reports per Site An increase in the assumed average number of reports per site will significantly increase the cost burden per site of the IURA. Under Scenario 1a, per site costs are approximately four to nine times lower than the costs of the IURA because of the decrease in the number of reports per site. Conversely,

increasing the number of reports per site to 20 increases per site costs by more than a factor of two. Based on the data presented in Section 3, it is clear that these estimates ( i. e., one report and 20 reports per site) under and overestimate, respectively, the costs for a typical site.

F. 2 Changing the Discount Rate Since the benefits resulting from the amendments will not occur simultaneously with the costs, it is necessary to discount the future streams of costs and benefits before comparing them. The time horizon over which costs and benefits are discounted in this analysis is 20 years. The primary discount rate used in Section 3 is 3 percent, although some results are also presented using a 7 percent discount rate. This sensitivity scenario explores the effect of using a 7 percent discount rate on the incremental costs of the eight options examined for this rule. F 2 There is considerable debate in the economics discipline whether to use the social rate of time preference or the rate of return on investment when discounting. According to recent literature, the rates are quite similar, so choosing one or the other will not make much difference in the magnitude of the present value estimate. The debate between using a rate of return on investment capital and the consumption rate of return focuses on whether investment or consumption is being displaced. Some discounting theory emphasizes that a dollar diverted from productive investment reduces the stream of production created by that marginal investment, while a dollar diverted from consumption would only substitute one type of consumption for another. This diverted capital argument is the basis of the Table F 1. Results for Sensitivity Analysis on the Number of Reports per Site Incremental Cost Per Site ( 2000$)

Scenario Reports Per Site Low High IURA First Reporting Cycle Organic Chemicals ( including Petroleum Process Stream Chemicals) 9.0 $ 26,971 $ 31,871 Inorganic Chemicals 8.3 $ 11,742 $ 18,185 Future Reporting Cycles Organic Chemicals ( including Petroleum Process Stream Chemicals) 9.0 $ 20,391 $ 24,221 Inorganic Chemicals 8.3 $ 27,602 $ 34,780 Scenario 1a First Reporting Cycle Organic Chemicals ( including Petroleum Process Stream Chemicals) 1.0 ($ 726) ($ 2,945)

Inorganic Chemicals 1.0 $ 3,184 $ 4,415 Future Reporting Cycles Organic Chemicals ( including Petroleum Process Stream Chemicals) 1.0 ($ 2,907) ($ 5,532)

Inorganic Chemicals 1.0 $ 3,652 $ 4,687 Scenario 1b First Reporting Cycle Organic Chemicals ( including Petroleum Process Stream Chemicals) 20.0 $ 65,313 $ 80,068 Inorganic Chemicals 20.0 $ 25,342 $ 40,066 Future Reporting Cycles Organic Chemicals ( including Petroleum Process Stream Chemicals) 20.0 $ 52,643 $ 65,460 Inorganic Chemicals 20.0 $ 65,658 $ 82,598 F 3 " shadow price of capital" approach to discounting, which treats displaced investment as " costing" more than displaced consumption. The practical difficulty in implementing this approach is to identify which costs are diverted investments and which are diverted consumption. Various pragmatic approaches to solving this dilemma have been proposed and used by EPA and other government agencies for regulatory analysis, including the " two staged" discounting approach ( Kolb and Scheraga, 1990), or a single " blended rate" somewhere between the rate of investment return and the consumption return.

Recent developments in the economic literature have raised serious questions about the extent to which capital is actually " displaced" today. The displaced capital theory maintains that because regulation diverts funds from alternative investments, some investment opportunities are not undertaken. The pool of available capital is assumed to be fixed, forcing some investment to be foregone when capital is diverted. While the pool of available capital is relatively fixed ( at least in the short run) in a closed economy, in an open economy capital can flow in from other countries. The increased demand for investment capital in the United States ( created in part to finance the federal deficit) has attracted large amounts of capital into the country, and many economists feel this has significantly reduced the pressure that federal borrowing has had on real interest rates. While the supply of capital is not perfectly elastic, neither is it perfectly inelastic. An elastic supply of capital reduces the difference between investment rates of return and consumer rates of return.

Estimates of real rates of return on investment are lower than many people believe. The real rate of return on U. S. government bonds has been near 0 percent for most of this century, while the annual return on a broad portfolio of stocks has averaged near 4 percent. In general, stocks have done better since 1980 ( averaging 4.26 percent) than in other periods of this century, but the rate of return may return to historic norms in the future ( Freeman, 1993). Thus, the real rates of return on investment opportunities range from near 0 to 4 percent.

The issues involving the appropriate discount rates and procedures are complex and are not likely to be resolved soon. Much of the recent economic literature summarizing the discounting debate concludes that discount rates reflecting either the social rate of time preference or the rate of return on investments are the appropriate discount rates to use, and this literature also concludes that there is not much difference between the rates. For example, Moore and Viscusi ( 1990) find no evidence that the rate of time preference for environmental related health effects differs from financial rates of return and cite evidence that a 2 percent rate is appropriate. Lind ( 1990) recommends a range of 1 to 3 percent, and Freeman ( 1993) recommends 2 to 3 percent.

Based on the information presented above, a 3 percent discount rate has been adopted as the most appropriate rate for use in this analysis. However, the results of discounting costs at a 7 percent rate are also presented in the main text of the report for some variables as well as in Table F 2. This table reveals an increase in incremental annualized costs of approximately 7 percent and a decrease in incremental net present values of approximately 24 percent for the selected option. The net present value and annualized cost of all the other options change by a similar percentage in moving from a 3 percent discount rate to a 7 percent discount rate. F 4 Table F 2. Incremental Net Present Values and Annualized Industry Costs of Amendment Options Discounted at 3 Percent and 7 Percent ( million 2000$)

Option First Year Cost Net Present Valuea Annualized Cost Low High Low High Low High 3 Percent Discount Rate Threshold Options 1a  Draft Finalb $ 73.8 $ 88.9 $ 289.1 $ 346.0 $ 19.4 $ 23.3 1b  Selected Finalb $ 72.4 $ 87.4 $ 258.0 $ 309.8 $ 17.3 $ 20.8 2 $ 91.1 $ 103.1 $ 362.3 $ 410.3 $ 24.4 $ 27.6 3 $ 67.2 $ 77.3 $ 260.7 $ 300.6 $ 17.5 $ 20.2 4 $ 59.1 $ 68.6 $ 226.4 $ 263.6 $ 15.2 $ 17.7 5 $ 67.2 $ 77.3 $ 339.0 $ 385.2 $ 22.8 $ 25.9 Reporting Exemption Option 6 $ 84.7 $ 94.7 $ 292.5 $ 328.8 $ 19.7 $ 22.1 Reporting Cycle Options 7 $ 91.1 $ 103.1 $ 706.3 $ 800.0 $ 47.5 $ 53.8 8 $ 91.1 $ 103.1 $ 88.5 $ 100.1 $ 5.9 $ 6.7 7 Percent Discount Rate Threshold Options 1a  Draft Finalb $ 73.8 $ 88.9 $ 217.3 $ 260.2 $ 20.5 $ 24.6 1b  Selected Finalb $ 72.4 $ 87.4 $ 195.7 $ 235.1 $ 18.5 $ 22.2 2 $ 91.1 $ 103.1 $ 278.6 $ 325.0 $ 26.3 $ 30.7 3 $ 67.2 $ 77.3 $ 196.1 $ 226.1 $ 18.5 $ 21.3 4 $ 59.1 $ 68.6 $ 170.5 $ 198.5 $ 16.1 $ 18.7 5 $ 67.2 $ 77.3 $ 249.5 $ 283.8 $ 23.6 $ 26.8 Reporting Exemption Option 6 $ 84.7 $ 94.7 $ 222.6 $ 250.0 $ 21.0 $ 23.6 Reporting Cycle Options 7 $ 91.1 $ 103.1 $ 511.8 $ 579.6 $ 48.3 $ 54.7 8 $ 91.1 $ 103.1 $ 85.2 $ 96.3 $ 8.0 $ 9.1 a NPV determined for a 20 year period. b Option 1a represents the draft final option included in the initial submission for interagency review. Option 1b is the final option that was promulgated. EPA removed a CBI reassertion requirement and added a partial exemption for specific chemicals based on low current interest in processing and use data for those chemicals. All options other than 1b include CBI reassertion and do not include the partial exemption for specific chemicals.