1 Instructions for Reporting for the 2006 Partial Updating of the TSCA Chemical Inventory Database Franklyn Hall, EPA Economics, Exposure and Technology Division Office of Pollution Prevention and Toxics Chris Hibshman, ERG Lori Weiss, ERG Dallas, Texas March 7, 2005 2

Background Information

Reporting Requirements

Completing Form U

CBI

Submitting Information to EPA

Case Study 1   Ammonia Phosphate

Special Topics ° Mixtures, Impurities, By products, Wastes ° Importers/ Exporters ° TSCA/ non TSCA Use

Case Study 2   Acetone

Case Study 3   Xylene

Case Study 4   EDTA

Revisions Rule Training Agenda 3 Background Information 4 If you  manufacture or import a chemical at a single site in volumes of 25,000 pounds or more during calendar year 2005, you may need to report under the Inventory Update Rule ( IUR) 40 CFR Part 710. 5 What is the IUR?

The TSCA Inventory, initiated in 1977, lists over 80,000 TSCA chemicals in commerce in the U. S.

The Inventory Update Rule ( IUR) updates production,

processing, and use information for a subset of chemicals on the TSCA Inventory.

The next submission occurs in 2006 and will include TSCA chemicals manufactured or imported in 2005. 6

Manufacturers and importers of chemicals listed on the TSCA Inventory:

° If your production volume is 25,000 lbs or greater ( annual, per site), then report site identification and manufacturing information ( Parts I and II of Form U).

° If your production volume is 300,000 lbs or greater ( annual, per site), also report downstream processing and use information ( Part III of Form U).

Who needs to report under the IUR in 2006?

Applicability and reporting exemptions will be covered in greater detail in the next section. 7 Available IUR Information

The IUR Web site will be updated to include the 2006 IUR reporting requirements and all supporting documents ( www. epa. gov/ oppt/ iur).

Please direct any general questions or comments on the IUR requirements to Susan Sharkey at sharkey. susan@ epa. gov.

If you need additional assistance when completing Form U, call the TSCA hotline at 202 554 1404. 8 Reporting Requirements 9 Reporting Requirements

Determining your reporting requirements

Determining if your chemical is listed on the TSCA Inventory

Full exemptions

Partial exemptions

Determining if you are a manufacturer required to report

Meeting the reporting thresholds

Determining which Parts of Form U to complete 10 Determining Reporting Requirements CRITERION II:

Are you a manufacturer ( or importer)

required to report? YOU DO NOT NEED TO REPORT.

CRITERION I:

Is your chemical substance reportable? YOU MUST REPORT.

Evaluate CRITERION III to determine what information you should complete.

Yes Yes No No 11 CRITERION I YES YES EVALUATE CRITERION II YES NO YOU DO NOT NEED TO REPORT NO NO Is the substance exempt from reporting?

( 710.46a) Is the substance subject to a special action?( 710.46)

Is the substance on the TSCA Inventory?

( 710.45 and 710.53) 12 Is the substance on the TSCA Inventory?

Chemical substances reportable under IUR must appear on the TSCA Inventory at the beginning of the submission period ( August 25, 2006). YES YES EVALUATE CRITERION II YES NO YOU DO NOT NEED TO REPORT NO NO Is the substance exempt from reporting?

( 710.46a) Is the substance subject to a special action?

( 710.46)

Is the substance on the TSCA Inventory?

( 710.45 and 710.53) 13 What is the TSCA Inventory?

EPA classifies all chemicals as " existing" or " new".

All existing chemicals are compiled in a list called the Toxic Substances Control Act Chemical Substance Inventory or TSCA Inventory.

The Inventory was originally compiled in 1978 and 1979.

EPA adds new chemicals to the Inventory when companies submit a Notice of Commencement following completion of Premanufacture Notification procedures.

Over 80,000 chemicals are listed. 14 How do you obtain a copy of the Inventory?

You can obtain the Public Inventory in hardcopy or electronic format from the National Technical Information Service. Phone number 703 487 4650 or 800 553 NTIS.

Organizations outside of EPA have published versions of the Inventory on the Internet. Please use caution if you rely on these Web sites. EPA is not responsible for the content of these pages and cannot verify the accuracy and completeness of the lists. 15 How do you determine if your substance is on the TSCA Inventory?

Locate the substance in the Public Inventory.

Search company records to determine if the substance was previously reported to EPA under IUR.

Search company records for a Notice of Commencement of manufacture or import for a PMN substance. 16 Hydrates and Mixtures

Hydrates are not listed in the TSCA Inventory. You are required to report using the corresponding anhydrous form.

Mixtures are not reportable under TSCA. You are required to report for the chemical substances making up the mixture.

Examples related to hydrates and mixtures will be presented in later sections. 17

You can request that EPA search the Master Inventory File, including confidential substances.

Because searches are labor intensive, you should request a search only if your search of the Public Inventory and company records fails to resolve your question.

EPA can not guarantee a response for requests received after the beginning of the submission period.

Follow the instructions listed in Section <IP_ADDRESS> of the Instructions for Reporting for submitting your request.

What if you cannot find your chemical in the Inventory? 18

Contact EPA at the address listed in Section <IP_ADDRESS> of the Instructions for Reporting.

Significant reductions in penalties are given for people who voluntarily disclose such information.

What if you manufacture a substance subject to TSCA that is not listed in the Inventory? 19 Is the substance exempt?

Polymers, certain natural gas streams, microorganisms, and naturally occurring substances are largely exempt from reporting.

Exempt substances are noted with an ` XU' flag in the TSCA Inventory. YES YES EVALUATE CRITERION II YES NO YOU DO NOT NEED TO REPORT NO NO Is the substance exempt from reporting?

( 710.46a) Is the substance subject to a special action?

( 710.46)

Is the substance on the TSCA Inventory?

( 710.45 and 710.53) 20 Polymers ( 40 CFR 710.46( a)( 1))

The IUR definition of polymer is sufficiently broad to include all those substances that are generally considered polymers. These include polysaccharides, such as starches and gums, and all classes of proteins. However, substances that result from hydrolysis, depolymerization, or chemical modification, regardless of the extent of these processes, of polymers so that the final products are no longer polymeric ( e. g., a mixture of amino acids that is the result of hydrolysis of a polypeptide) are not considered to be polymers and must be reported if not otherwise excluded. For reporting purposes, salts of polymers are also considered to be polymers. 21 Microorganisms ( 40 CFR 710.46( a)( 2))

A microorganism is any combination of chemical substances that is a living organism and that meets the definition of microorganism at 40 CFR 725.3.

Any chemical substance produced from a living organism is reportable unless otherwise excluded.

40 CFR 725.3 defines microorganism as an organism classified, using the 5 kingdom classification system of Whittacker, in the kingdoms Monera ( or Procaryotae), Protista, Fungi, and the Chlorophyta and the Rhodophyta of the Plantae,

and a virus or virus like particle. 22 Natural Gas ( 40 CFR 710.46( a)( 4))

Certain forms of natural gas are exempt for IUR reporting. These forms are listed in 40 CFR 710.46( a)( 4), Table 2 1 of the Instructions for Reporting, and below:

Form of Natural Gas CAS Number Natural gas ( petroleum), raw liquid mix 64741 48 6 Natural gas condensates 68919 39 1 Gasoline natural 8006 61 9 Gasoline ( natural gas), natural 68425 31 0 Natural gas 8006 14 2 Natural gas, dried 68410 63 9 23 Naturally Occurring Substances ( 40 CFR 710.46( a)( 3))

A naturally occurring substances is any chemical substance which is naturally occurring and:

( 1) Which is ( i) unprocessed or ( ii) processed only by manual, mechanical, or gravitational means; by dissolution in water; by flotation; or by heating solely to remove water;

( 2) Which is extracted from air by any means.

Examples of such substances are: raw agricultural commodities; water, air, natural gas, and crude oil;

and rocks, ores, and minerals. 24 Naturally Occurring Substances

Whether a substance is naturally occurring depends on the manner in which it is produced and isolated.

For this reason, minerals and certain agricultural products are sometimes considered not to be naturally occurring because of their method of production.

Examples:

1. Removing small particles by electrostatic precipitation is treated similarly to a filtration or gravitation separation. Processing a naturally occurring substance by this means does not negate the exemption.

2. Using a solvent to extract a naturally occurring substance is not a natural means, therefore the substance would need to be reported. 25 Example # 1   Naturally Occurring Substances Georgia Rock Products ( GRP) extracts phosphate rock from the earth for production of phosphoric acid. During benefication, the phosphate rock is separated from its matrix by non chemical means, i. e. crushing, screening, gravitational separation, and flotation. What chemical substances manufactured by GRP are subject to reporting requirements under IUR? 26 Is the substance subject to a special action?

Polymers, certain natural gas streams, and microorganisms are not exempt when they are subject to a rule proposed or promulgated under certain sections of TSCA.

See Section 2.1.3, 40 CFR 710.46, and Appendix C of the Instructions for Reporting for additional details.

YES YES EVALUATE CRITERION II YES NO YOU DO NOT NEED TO REPORT NO NO Is the substance exempt from reporting?

( 710.46a) Is the substance subject to a special action?

( 710.46)

Is the substance on the TSCA Inventory?

( 710.45 and 710.53) 27 CRITERION I YES YES EVALUATE CRITERION II YES NO NO NO Is the substance exempt from reporting?

( 710.46a) Is the substance subject to a special action?

( 710.46)

Is the substance on the TSCA Inventory?

( 710.45 and 710.53) YOU DO NOT NEED TO REPORT 28 Do you qualify as a small manufacturer?

( 710.49) Did you manufacture 25,000 pounds or more?

( 710.48) Do you qualify for additional exemptions?

( 710.50)

YES YOU MUST REPORT YES NO YOU DO NOT NEED TO REPORT NO NO CRITERION II Is the substance subject to a special action?

( 710.46)

YES NO YES 29 Definition of Manufacture

Manufacture means to manufacture, produce, or import for commercial purposes ( 40 CFR 710.3).

Note the definition of manufacture includes import.

Day 2 will cover special topics related to manufacturing and will review the reporting requirements for importers. 30 Do you qualify as a small manufacturer?

( 710.49) Did you manufacture 25,000 pounds or more?

( 710.48) Do you qualify for additional exemptions?

( 710.50)

YES YOU MUST REPORT YES NO YOU DO NOT NEED TO REPORT NO NO Is the substance subject to a special action?

( 710.46)

YES NO YES Do you manufacture quantities of 25,000 pounds or more?

Only report a chemical substance if you manufactured and/ or imported 25,000 pounds or more at any single site.

Report the substance for all sites at which you manufactured and/ or imported 25,000 pounds or more. Form U should be completed for each site. 31 Example # 2  Annual Production Volume Threshold Green Chemical Company Annual Sales $ 50 Million Pennsylvania Site Manufactures 21,000 pounds and imports 5,000 pounds of acetylene Which sites need to report?

New Jersey Site Manufacturers 50,000 pounds of a 50% acetylene mixture New York Site Manufactures 30,000 pounds of a 50% acetylene mixture and 5,000 pounds of 100% acetylene 32 Example # 3  Mixtures Company A purchases 25,000 pounds of Chemical X and 25,000 pounds of Chemical Y from Domestic Manufacturer B. Company A mixes the two chemicals to form Mixture Z with no chemical reaction which they sell directly to consumers. Does company A meet the IUR reporting requirements? 33 Example # 4   Imported Mixtures Company A imports 50,000 pounds of Mixture Z which contains 20,000 pounds of Chemical X and 30,000 pounds of Chemical Y. Company A sells Mixture Z directly to consumers. Does company A meet the IUR reporting requirements? 34 Do you qualify as a small manufacturer?

Total annual sales < $ 4 million ( company wide)

OR

Total annual sales < $ 40 million ( company wide); and Production volume < 100,000 lbs. ( for a chemical substance at a single plant site)

NOTE: Small manufacturers are still required to report on substances subject to a rule proposed or promulgated under certain sections of TSCA ( 710.46).

Do you qualify as a small manufacturer?

( 710.49) Did you manufacture 25,000 pounds or more?

( 710.48) Do you qualify for additional exemptions?

( 710.50)

YES YOU MUST REPORT YES NO YOU DO NOT NEED TO REPORT NO NO Is the substance subject to a special action?

( 710.46)

YES NO YES 35 Example # 5  Small Manufacturer Exemption AAA Chemical Company Annual Sales $ 30 Million Which sites need to report?

New Jersey Site 200,000 pounds of xylene Delaware Site 75,000 pounds of xylene 36 Is the substance subject to a special action?

Substances must be reported if they are subject to a special action.

See Section 2.1.3, 40 CFR 710.46, and Appendix C for additional details.

Do you qualify as a small manufacturer?

( 710.49) Did you manufacture 25,000 pounds or more?

( 710.48) Do you qualify for additional exemptions?

( 710.50)

YES YOU MUST REPORT YES NO YOU DO NOT NEED TO REPORT NO NO Is the substance subject to a special action?

( 710.46)

YES NO YES 37 Do you qualify for additional exemptions?

If you manufacture or import under the following circumstances you are not required to report:

° Substance is imported as part of an article ( 710.50).

° Substance is manufactured as an impurity, by product, or non isolated intermediate ( 710.50, 720.30( g) and ( h)).

° All IUR information was submitted in response to another TSCA Section 8( a) rule within the last year ( CFR 710.55).

Do you qualify as a small manufacturer?

( 710.49) Did you manufacture 25,000 pounds or more?

( 710.48) Do you qualify for additional exemptions?

( 710.50)

YES YOU MUST REPORT YES NO YOU DO NOT NEED TO REPORT NO NO Is the substance subject to a special action?

( 710.46)

YES NO YES 38 Article Exemption

" An article is any manufactured item that:

( 1) is formed to a specific shape or design during manufacture,

( 2) has end use function( s) dependent in whole or in part upon its shape or design during its end use,

and ( 3) has either no change of chemical composition during its end use or only those changes of composition that have no commercial purpose separate from that of the article." ( 40 CFR 710.3) 39 By product, impurities, and non isolated intermediates

" By product is a chemical substance produced without separate commercial intent during the manufacture or processing of another chemical substance( s) or mixture( s)." ( 40 CFR 710.3)

" Impurity is a chemical substance which is unintentionally present with another chemical substance." ( 40 CFR 710.3) 40

" Non isolated intermediate is any intermediate that is not intentionally removed from the equipment in which it is manufactured, including the reaction vessel in which it is manufactured, equipment which is ancillary to the reaction vessel, and any equipment through which the substance passes during a continuous flow process, but not including tanks or other vessels in which the substance is stored after its manufacture." ( 40 CFR 710.43)

By product, impurities, and non isolated intermediates 41 Non isolated intermediate status

Taking laboratory samples of an intermediate does not negate the non isolated status of the substance.

Any storage, even storage within the reaction vessel, negates the non isolated status of the intermediate. 42 Example # 6  Non Isolated Intermediate Exemption Reactants A and B are charged to a vessel where they react to form Chemical Substance X. Reactant C is then added to the same vessel. Chemical Substance X reacts completely with Reactant C to form Chemical Substance Y. Is Chemical Substance X non isolated? 43 Reactants A and B are charged to a Reactor # 1 to form Chemical Substance X. Chemical Substance X is stored in Reactor # 1 until being transferred to Reactor # 2 where it is mixed with Reactant C to form Chemical Substance Y. Is Chemical Substance X non isolated?

Example # 7  Non Isolated Intermediate Exemption 44 Do you qualify as a small manufacturer?

( 710.49) Did you manufacture 25,000 pounds or more?

( 710.48) Do you qualify for additional exemptions?

( 710.50)

YES YOU MUST REPORT YES NO YOU DO NOT NEED TO REPORT NO NO CRITERION II Is the substance subject to a special action?

( 710.46)

YES NO YES 45 CRITERION III What parts do you need to complete?

Is your substance inorganic or listed as a petroleum process stream or listed as a partially exempt chemical substance?

( 710.46)

Did you manufacture 300,000 pounds or more of the substance?

( 710.52) COMPLETE PARTS I, II, AND III OF FORM U.

Yes No No Yes COMPLETE PARTS I AND II OF FORM U. 46 Partial Exemptions   Part III Reporting Not Required You do not need to complete Part III of Form U for:

Specific petroleum process streams listed in Part 710.46( b)( 1) and in Appendix F of the Instructions for Reporting.

Specific chemical substances listed in Part 710.46( b)( 2)( iv) and in Appendix F.

Inorganic substances are partially exempt for the 2006 reporting period only ( 40 CFR 710.46( b)( 3)). 47 What information do you need to report? Part III Complete for all reportable substances manufactured or imported in quantities of 25,000 pounds or more. Complete if you produce 300,000 pounds or more per year except for the following:

1) Petroleum process streams listed in 40 CFR 710.46( b)( 1).

2) Specific chemical substances listed in 40 CFR 710.46( b)( 2)( iv) and in Appendix F.

3) Inorganic substances as defined in 40 CFR 710.46( b)( 3).

Parts I and II Summary of Reporting Requirements 48 Example # 8  Reporting Requirements Zero Pollution Chemical Company Annual Sales $ 50 Million What does this company submit?

California Site 10,000 pounds of organic pigment Arizona Site 30,000 pounds of organic pigment New Mexico Site 350,000 pounds of organic pigment 49 Summary

Form U must be submitted if ° The chemical is on the TSCA chemical substance inventory ° The chemical is manufactured or imported in an amount greater than 25,000 pounds

Exemptions ° Polymers, certain natural gas streams, microorganisms,

naturally occurring substances ° Small manufacturers ° Substance is manufactured as an impurity, non isolated intermediate, or byproduct without separate commercial intent ° Substance is imported as a part of an article Note: Additional information on Reporting Requirements can be found in Chapter 2 of the Instructions for Reporting 50 Completing Form U 51 Completing Form U

General Requirements

Part I   Site Identification Information

Part II   Manufacturing Information

Part III   Processing and Use Information 52 General Requirements

Separate forms are required for each plant site ( 40 CFR 710.52).

If you are reporting for more than one chemical, you should make the required number of copies of Parts II and III.

Information can be submitted either on electronic disk ( not email) or a printed version of Form U ( 40 CFR 710.52). 53 Reporting Standards

EPA expects all information in Parts I and II of Form U should be known to or reasonably ascertainable by the submitter.

Report all readily obtainable information in Part III. If any information is not readily obtainable, enter ` NRO' ( not readily obtainable) in the block for that data element. 54

Report all information that is known to or reasonably ascertainable by you in Parts I and II of Form U.

Known to or reasonably ascertainable by means all information in a person's possession or control, plus all information that a reasonable person similarly situated might be expected to possess, control, or know.

Report readily obtainable information in Part III of Form U.

Readily obtainable information is information known to or readily obtainable by management and supervisory employees of the submitter company who are associated with manufacturing, processing, technical services or marketing of the reportable chemical substance. Extensive file searches are not required. Readily obtainable information includes using best professional judgment based on past experiences for similar chemical substances in the same or similar markets.

Reporting Standards 55 Known to or Reasonably Ascertainable

Examples of reasonably ascertainable information include:

° Files maintained by your company that are associated with research, development, test marketing or commercial marketing of the chemical substance.

° Information contained in standard references such as MSDSs.

° Information from Chemical Abstracts Service ( CAS), Dun & Bradstreet, and NAICS.

° Common market research information. 56 Readily Obtainable Information

Lesser standard than the known to or reasonably ascertainable by standard.

Includes use of your best professional judgment based on past experiences for similar chemical substances in the same or similar markets.

Does not include surveying your downstream customers. However, if you have any information that would allow you to provide estimates, you should report the information on Part III of the form. 57 SECTION A. CERTIFICATION Certification Statement: I hereby certify to the best of my knowledge and belief that Parts I and II have been completed in compliance with the requirements of 40 CFR 710.52( c)( 1), ( 2), and ( 3); Part III of this form has been completed in compliance with the requirements of 40 CFR 710.52( c)( 4); and the confidentiality statements at the end of this form are true and correct as to that information for which a confidentiality claim has been asserted.

1. A. 1 Signature 1. A. 2 Date signed 1. A. 3 Name 1. A. 4 Official Title Part I, Section I: Certification

This section should be completed by an authorized official of your company. The certification statement attests to the accuracy, completeness, and truthfulness of the submitted information to the best of your knowledge. 58 Part I, Section II:

Parent Company Information Make sure you enter the parent company Dun & Bradstreet number.

SECTION B. PARENT COMPANY AND TECHNICAL CONTACT INFORMATION 1. B. 1 Parent Company Name 1. B. 2 Parent Company Dun &

Bradstreet Number 1. B. 3 Technical Contact Name 1. B. 4 Technical Contact Telephone ( w/ Area Code) 1. B. 5 Technical Contact Email Address Technical Contact Mailing Address 1. B. 6 Technical Contact Address ( Line1)

1. B. 7 Technical Contact Address ( Line 2)

1. B. 8 City 1. B. 9 State 1. B. 10 Zip Code 59 Technical Contact

The technical contact should be able to answer questions regarding all of the information submitted on Form U. The submitter is responsible for determining if the technical contact should be from the parent company or the plant site.

Form U should be completed for each chemical at each plant site. Therefore, you may have different technical contacts for each site and each chemical.

SECTION B. PARENT COMPANY AND TECHNICAL CONTACT INFORMATION 1. B. 1 Parent Company Name 1. B. 2 Parent Company Dun &

Bradstreet Number 1. B. 3 Technical Contact Name 1. B. 4 Technical Contact Telephone ( w/ Area Code) 1. B. 5 Technical Contact Email Address Technical Contact Mailing Address 1. B. 6 Technical Contact Address ( Line1)

1. B. 7 Technical Contact Address ( Line 2)

1. B. 8 City 1. B. 9 State 1. B. 10 Zip Code 60 Part I, Section III:

Plant Site Identification

Dun & Bradstreet assigns separate numbers to plant sites and parent companies. Be sure to provide the correct number for both the parent company and plant site.

You can request a number from your local Dun & Bradstreet office. See www. dnb. com/ us for more information. SECTION C. PLANT SITE IDENTIFICATION 1. C. 1 Plant Site Name 1. C. 2 Plant Site Dun &

Bradstreet Number EPA Facility Identification Number ( for Agency Use Only) LEAVE BLANK 1. C. 3 Street Address ( Line 1)

1. C. 4 Street Address ( Line 2)

1. C. 5 City 1. C. 6 County/

Parish 1. C. 7 State 1. C. 8 Zip Code Make sure you enter the plant site Dun & Bradstreet number. 61 Plant Site Identification SECTION C. PLANT SITE IDENTIFICATION 1. C. 1 Plant Site Name 1. C. 2 Plant Site Dun &

Bradstreet Number EPA Facility Identification Number ( for Agency Use Only) LEAVE BLANK 1. C. 3 Street Address ( Line 1)

1. C. 4 Street Address ( Line 2)

1. C. 5 City 1. C. 6 County/

Parish 1. C. 7 State 1. C. 8 Zip Code EPA will assign a facility identification number. 62 Part II Manufacturing Information

Section A. Chemical Information ° Chemical Identification Number and Code ° Chemical Name

Section B. Manufacturing Information ° Manufacturing Activities and Production Volume ° Number of Potentially Exposed Workers ° Maximum Concentration ° Physical Form( s) of Substance 63 Part II, Section A:

Chemical Identification

Enter the CAS Registry number for the substance in Block 2. A. 1.

If the CAS number is not known, then you may use the EPA Accession or PMN number.

Specify the type of identifying number in Block 2. A. 2 by using the codes in Table 4 1 of the Instructions for Reporting.

Enter the Chemical Abstracts Index/ Preferred names if available in Block 2. A. 3. Trade names may not be used unless the supplier refuses to disclose the specific chemical identity of the substance.

You may claim the identity of your substance as confidential by checking the CBI box and submitting a separate written substantiation. Note that you can not claim confidentiality for any chemical on the non confidential portion of the TSCA Inventory. SECTION A. CHEMICAL IDENTIFICATION CBI*

2. A. 1 Chemical Identifying Number 2. A. 2 ID Code 2. A. 3 Chemical Name 64 Part II, Section B   Manufacturing Information

Checking the CBI box in Block 2. B. 1 asserts a confidentiality claim for the link between the chemical substance and the information about the parent company.

Checking the CBI box in Block 2. B. 2 asserts a confidentiality claim for the link between the site of manufacture/ import and the chemical identity.

Additional information on CBI claims will be presented in another section. SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid 65

Mark ` Y' in Block 2. B. 3 if the substance is site limited.

Mark ` N' if it is not.

Site limited means a chemical is manufactured and processed only within a site and is not distributed for commercial purposes as a substance or as part of a mixture or article outside the site.

An imported chemical is never site limited.

Part II, Section B   Manufacturing Information SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid 66

In Block 2. B. 4, report if you are manufacturing and/ or importing the chemical substance by checking the appropriate box or boxes.

Part II, Section B   Manufacturing Information SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid 67

Add the manufacture and import volumes together and report the total volume in Block 2. B. 5.

EPA will assign a production volume range for Block 2. B. 6.

Part II, Section B   Manufacturing Information SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid 68 Number of Workers  Block 2. B. 7

EPA requires that you report your estimate of the total number of workers " reasonably likely to be exposed."

( 40 CFR 710.52( c)( 3)( vi))

Include exposures through any route of entry   inhalation,

ingestion, skin contact.

Do not exclude workers wearing personal protective equipment.

Reasonably likely to be exposed   Exposure to a chemical substance under foreseeable conditions of manufacture, processing, distribution in commerce. 69 Estimating Number of Exposed Workers

Include workers who, as part of their daily activities,

may potentially be exposed to the chemical substance.

Include any temporary, seasonal, or contract workers if they may be potentially exposed.

Report individual workers, not full time equivalents.

Use the range codes listed in 40 CFR 710.52( c)( 3)( vi) and Table 4 3 of the IUR Instructions for Reporting. 70

Use the range codes listed below which can also be found in 40 CFR 710.52( c)( 3)( vi) and Table 4 3 of the IUR Instructions for Reporting.

Estimating Number of Exposed Workers W1 Fewer than 10 W2 At least 10 but fewer than 25 W3 At least 25 but fewer than 50 W4 At least 50 but fewer than 100 W5 At least 100 but fewer than 500 W6 At least 500 but fewer than 1,000 W7 At least 1,000 but fewer than 10,000 W8 10,000 or greater 71 Example # 9  Number of Workers My site produces isopropyl alcohol and formaldehyde. Six employees are involved in the production of each chemical ( 12 total). On a few occasions throughout the reporting year, two employees from the isopropyl alcohol production line were moved to the formaldehyde production line to provide additional assistance. These two employees had minimal exposure to formaldehyde. How many workers should be reported for the production of formaldehyde? 72 Example # 10  Number of Workers I employ 12 workers to operate three different chemical production lines ( X, Y, and Z). The workers rotate between the different lines. Only four workers work on the production for Chemical X at any given time. However,

any of the 12 workers may be assigned to Chemical X production. How many workers are reasonably likely to be exposed during the manufacture of Chemical X? 73 Example # 11  Number of Workers My site uses 15 workers during the production of my chemical substance. This chemical is then stored until needed for shipment. These same 15 workers package the final product for shipment. Should these workers be counted twice since they are involved in two separate activities? 74 Maximum Concentration   Block 2. B. 8

In Block 2. B. 8, report the maximum concentration,

measured by weight, at the time the chemical is reacted on site or as it leaves the plant site. ( 40 CFR 710.52( c)( 3)( vii))

SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid 75 Maximum Concentration

Round estimates to the nearest 1% using standard rounding procedures. Numbers ending in 0.5 to 0.9 should be rounded up to the nearest percent. Reporting code M1 should be reported for concentrations less than 1% by weight.

Concentrations of laboratory samples do not need to be considered when reporting the maximum concentration. 76 Maximum Concentration

Use the range codes listed below which are also listed in 40 CFR 710.52( c)( 3)( vii) and Table 4 4 of the IUR instructions for reporting.

M1 Less than 1% by weight M2 From 1% to 30% by weight M3 From 31% to 60% by weight M4 From 61% to 90% by weight M5 Greater than 90% by weight 77 Example # 12  Maximum Concentration My company manufactures a solution of Chemical Q. During the manufacturing process several samples are taken, which may contain Chemical Q at concentrations up to 80 percent.

The samples are sent off site for laboratory analysis. The final solution at 50 percent concentration is packaged and shipped to customers. What do I report for the maximum concentration? 78 Physical Form   Block 2. B. 9   2. B. 14

Report all physical forms of the chemical at the time it is reacted or as it leaves your site and the percentage of production volume for each physical form.

Round estimates to the nearest 10%.

SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid 79 Company A, Delaware Site Company A manufactures 90,000,000 lbs of NaOH ( 187,500,000 lbs of a 48% solution) Company A imports 10,000,000 lbs of NaOH ( 20,800,000 lbs of a 48% solution)

100,000,000 lbs of NaOH 20,000,000 lbs purified to a 72% wt solution 6,000,000 lbs crystallized to a solid at > 97% concentration 74,000,000 lbs sold as a 48% wt solution Sold for laboratory and industrial uses.

Example # 13 Completing Part II Sodium Hydroxide ( NaOH)

Note that further information about Company A's production of NaOH is included in your handouts. 80 Example # 13 ( cont'd)

SECTION A. CHEMICAL IDENTIFICATION CBI*

2. A. 1 Chemical Identifying Number 2. A. 2 ID Code 2. A. 3 Chemical Name 81 Example # 13 ( cont'd)

Is NaOH site limited?

SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid Does Company A manufacture or import? 82 What is the production volume?

Example # 13 ( cont'd)

SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid 83 Workers per Shift Process engineers Total Load drums onto truck trailers Administrative personnel Maintenance staff Support other manufacturing operations Package the NaOH for shipment Sample the NaOH Transfer NaOH to other processes Operate and monitor NaOH process Load raw materials into storage tanks Total Exposed Workers Number of Shifts Exposed Workers per Shift Activity Example # 13 ( cont'd)

How many workers should be reported in Block 2. B. 7? 84 What code should be entered for the number of workers?

Example # 13 ( cont'd)

SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid 85 What code should be entered for the maximum concentration?

Example # 13 ( cont'd)

SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid 86 SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid What physical forms and percent of production volume associated with each form should be reported?

Example # 13 ( cont'd) 87 Part III: Processing and Use Information

Complete Part III for chemical substances manufactured in quantities of 300,000 pounds or more ( 40 CFR 710.52( c)( 4))

Report readily obtainable information about the industrial processing and use for each chemical substance:

° Sites under your control ° Sites that receive a reportable substance 88 Part III, Section I:

Industrial Processing and Use Report up to 10 unique combinations of the following codes:

Process or use; NAICS; and IFC.

SECTION A. INDUSTRIAL PROCESSING AND USE DATA N/ A a. Type of Process or Use b. ( 5 digit) NAICS c. Industrial Function Category d. % Production Volume e. Number of Sites f. Number of Workers Code CBI Code CBI Code CBI Code CBI Code CBI Code CBI 3. A. 1 3. A. 2 3. A. 3 3. A. 4 3. A. 5 3. A. 6 3. A. 7 3. A. 8 3. A. 9 3. A. 10 89 Part III, Section I:

Industrial Processing and Use If you have less than 10 combinations, leave the remaining lines blank.

If you have more than 10 combinations, report only the 10 unique combinations that cumulatively represent the largest percentage of production, by weight.

SECTION A. INDUSTRIAL PROCESSING AND USE DATA N/ A a. Type of Process or Use b. ( 5 digit) NAICS c. Industrial Function Category d. % Production Volume e. Number of Sites f. Number of Workers Code CBI Code CBI Code CBI Code CBI Code CBI Code CBI 3. A. 1 3. A. 2 3. A. 3 3. A. 4 3. A. 5 3. A. 6 3. A. 7 3. A. 8 3. A. 9 3. A. 10 90 Process or Use Code

Report the process or use code corresponding to the appropriate processing or use operation. These codes are also found in 40 CFR 710.52( c)( 4)( i)( A)

and Table 4 5 in the Instructions for Reporting.

PC: Processing as a reactant PF: Processing   incorporation into a formulation,

mixture, or reaction product PA: Processing   incorporation into an article PK: Processing   repackaging U: Use   non incorporative activities 91 NAICS Codes

The North American Industry Classification System ( NAICS) codes have superseded the 1987 Standard Industrial Classification ( SIC) code system.

Report the five digit NAICS code corresponding to the site( s) that processes or uses the reportable chemical substance or that receives the reportable chemical substance.

For definitions of NAICS codes and tables crossreferencing NAICS and SIC codes, see http:// www. census. gov/ epcd/ www/ naics. html. 92 IFC Code

33 Industrial Function Categories ( IFC)

Report the IFC code that corresponds to the function of the industrial process or use. The codes are listed in 40 CFR 710.52( c)( 4)( i)( C) Table 4 6 of the Instructions for Reporting. Definitions are listed in Appendix G. 93 Part III, Section A   Industrial Processing and Use Data

For each unique combination of Process or Use,

NAICS, and IFC codes, report the following:

° Percent of production volume associated with the use ° Number of sites ° Number of workers reasonably likely to be exposed SECTION A. INDUSTRIAL PROCESSING AND USE DATA N/ A a. Type of Process or Use b. ( 5 digit) NAICS c. Industrial Function Category d. % Production Volume e. Number of Sites f. Number of Workers Code CBI Code CBI Code CBI Code CBI Code CBI Code CBI 3. A. 1 3. A. 2 3. A. 3 3. A. 4 3. A. 5 3. A. 6 3. A. 7 3. A. 8 3. A. 9 3. A. 10 94 Percentage of Production Volume

Round estimates to nearest 10%

( 40 CFR 710.52( c)( 4)( i)).

If the amount is less than 5% of the production volume and the amount is less than 300,000 pounds, reporting is not required. If the amount is less than 5% and the amount exceeds 300,000 pounds, round to the nearest percent.

The total percentage production volume may add up to more than 100% since you are reporting for sites under your control as well as downstream sites. 95 Number of Sites

Report an estimate of the total number of sites. Use the codes listed in 40 CFR 710.52( c)( 4)( i)( E) or Table 4 8 corresponding to the appropriate range.

If a chemical substance is both manufactured and processed/ used at a site, that site should be counted as both a manufacturing site in Part II and a processing or use site in Part III. 96

Report an estimate of the total number of workers including those at sites not under your control. Follow the same guidelines as in reporting the number of exposed workers during manufacturing ( 40 CFR 710.52( c)( 3)( vii)).

Number of Workers 97 Example # 14  Part III, Section A:

Industrial Processing and Use Data Company B manufactures 25,000,000 lbs of xylene 1,000,000 lbs sold to paint formulators for use as a solvent in architectural paints 24,000,000 lbs sold to organic chemical manufacturers as a chemical intermediate What unique combinations of Process or Use, NAICS, and IFC codes should Company B report for xylene? 98 SECTION A. INDUSTRIAL PROCESSING AND USE DATA N/ A a. Type of Process or Use b. ( 5 digit) NAICS c. Industrial Function Category d. % Production Volume e. Number of Sites f. Number of Workers Code CBI Code CBI Code CBI Code CBI Code CBI Code CBI 3. A. 1 3. A. 2 3. A. 3 3. A. 4 3. A. 5 3. A. 6 3. A. 7 3. A. 8 3. A. 9 3. A. 10 What % PV should be entered for each use?

Example # 14 ( cont'd) 99 SECTION A. INDUSTRIAL PROCESSING AND USE DATA N/ A a. Type of Process or Use b. ( 5 digit) NAICS c. Industrial Function Category d. % Production Volume e. Number of Sites f. Number of Workers Code CBI Code CBI Code CBI Code CBI Code CBI Code CBI 3. A. 1 3. A. 2 3. A. 3 3. A. 4 3. A. 5 3. A. 6 3. A. 7 3. A. 8 3. A. 9 3. A. 10 What codes should be reported for the number of sites and exposed workers for each use?

Example # 14 ( cont'd) 100 Part III, Section B: Commercial and Consumer End Use Commercial Use  Use of a chemical substance or mixture in a commercial enterprise providing saleable goods or a service.

Consumer Use  Use of a chemical substance that is directly, or as part of a mixture, sold to a consumer for their own use.

SECTION B. COMMERCIAL & CONSUMER END USE EXPOSURE RELATED DATA N/ A a. Commercial and Consumer Product Category b. Use in Children's Product c. Percent Production Volume associated with each category d. Maximum Concentration associated with each category Code CBI Y/ N/? CBI Percent CBI Code CBI 3. B. 1 3. B. 2 3. B. 3 3. B. 4 3. B. 5 3. B. 6 3. B. 7 3. B. 8 3. B. 9 3. B. 10 101

Designate up to 10 commercial and consumer product categories that represent the predominant uses.

Determine if the chemical is present in or on any consumer product intended for use by children.

Report the percent production volume and maximum concentration associated with each use.

SECTION B. COMMERCIAL & CONSUMER END USE EXPOSURE RELATED DATA N/ A a. Commercial and Consumer Product Category b. Use in Children's Product c. Percent Production Volume associated with each category d. Maximum Concentration associated with each category Code CBI Y/ N/? CBI Percent CBI Code CBI 3. B. 1 3. B. 2 3. B. 3 3. B. 4 3. B. 5 3. B. 6 3. B. 7 3. B. 8 3. B. 9 3. B. 10 Part III, Section B: Commercial and Consumer End Use 102 Commercial and Consumer Product Categories

19 commercial and consumer product categories

Report the code that corresponds to the use. The codes are listed in 40 CFR 710.52( c)( 4)( ii)( A) and Table 4 10 of the Instructions for Reporting.

Definitions are listed in Appendix G.

If more than 10 codes apply, report only the codes that represent the largest percentage of production volume, measured by weight. 103 Intended for Use by Children Intended for use by children means the chemical substance or mixture is used in a product that is specifically intended for use by children age 14 or younger. If you answer yes to any of the following questions, you should report ` Y' for children's use.

( 1) Is the product commonly recognized ( i. e., by a reasonable person) as being intended for children age 14 or younger?

( 2) Does the manufacturer of the product state through product labeling or other written materials that the product is intended for use by children age 14 or younger?

( 3) Is the advertising, promotion, or marketing of the product aimed at children age 14 or younger? 104 Children's Use Examples

Examples of products specifically intended for use by children:

° Plastic parts for toys, car seats, or cribs ° Art supplies such as crayons, water colors, and markers ° Flame retardants that may be applied to children's pajamas

Examples of products not intended for use by children:

° Interior paint   This product is not specifically intended for use by children even though it may be used to paint children's rooms.

° Paper   This product is not specifically intended for use by children even though it may be used by children. 105 Architectural paints containing < 15% xylene Commercial and Consumer Uses Industrial Processing and Uses Company B manufactures 25,000,000 lbs of xylene 1,000,000 lbs sold to paint formulators for use as a solvent in architectural paints 24,000,000 lbs sold to organic chemical manufacturers as a chemical intermediate Xylene destroyed ( no commercial and consumer uses)

Example # 14 ( cont'd) Part III, Section B:

Commercial and Consumer End Use 106 SECTION B. COMMERCIAL & CONSUMER END USE EXPOSURE RELATED DATA N/ A a. Commercial and Consumer Product Category b. Use in Children's Product c. Percent Production Volume associated with each category d. Maximum Concentration associated with each category Code CBI Y/ N/? CBI Percent CBI Code CBI 3. B. 1 3. B. 2 3. B. 3 3. B. 4 3. B. 5 3. B. 6 3. B. 7 3. B. 8 3. B. 9 3. B. 10 Is the architectural paint intended for use by children?

What Percent Production Volume and Maximum Concentration should be Reported? Example # 14 ( cont'd) 107

Reporting ends when either:

° The chemical is consumed to form another chemical substance.

° The final processing and use of the chemical substance is reported.

For the purposes of IUR reporting, the final consumer use for a fertilizer is land application described by C07, Lawn and Garden Products.

Downstream processing or use information ends once the chemical has been converted into a new chemical substance. However, you should evaluate your IUR reporting requirements for any new substances manufactured.

Where does reporting end? 108 Example # 15   End of Reporting I manufacture anhydrous ammonia and ship it to 5 agricultural supply wholesalers. They react the anhydrous ammonia with water to form ammonium hydroxide. The wholesalers then sell the ammonium hydroxide to farmers for use as a fertilizer. What should I report in Part III? 109 Claiming Confidential Business Information ( CBI) 110 Overview

Claiming CBI for information submitted to EPA

Additional requirements for claiming CBI for:

° Chemical identity ° Manufacturing plant site identity ° Production volume and production volume range

Example

Discussion 111 To claim confidentiality on Form U:

In general, information submitted to EPA is entitled to confidential treatment if:

° The business asserts a claim for confidentiality by marking the appropriate box on IUR Form U;

° The submitter has taken reasonable measures to protect the confidentiality of the information;

° The information is not reasonably ascertainable without the consent of the business submitting the information; and,

° The disclosure of the information is likely to cause substantial harm to the business's competitive position ( 40 CFR part 2). 112 To claim confidentiality on Form U:

An authorized official must sign Part I, Section I.

Must mark the appropriate boxes on Form U.

Must file a written substantiation for:

° Chemical Identity ° Manufacturing Plant Site Identity

Note: CBI should not be submitted by email. 113 Chemical Identity

Must file a separate written substantiation, signed and dated by an authorized official, for each chemical substance.

Only assert a confidentiality claim if EPA treats the identity as confidential in the TSCA Inventory.

Address all questions in 40 CFR 710.58( b) and Table 5 2.

° Harmful effects to competitive position ° Length of time information must remain confidential ° Patent and licensing status ° Publication in technical journals or trade literature ° Ability of others to analyze products or wastes 114 Manufacturing Plant Site Identity

Check the CBI box next to Block 2. B. 2.

Submit a written substantiation, signed and dated by an authorized official, answering the questions in 40 CFR 710.58( c) and Table 5 3.

° Has site information been linked with a chemical identity in any other reporting scheme ( e. g. through an MSDS).

° What harmful effect to your competitive advantage would result from the identity of the site and chemical substance?

Upfront substantiation is not required for company information CBI claims ( Block 2. B. 1). 115 Company Identity versus Plant Site Identity Checking this box asserts a confidentiality claim for the link between your plant site and the chemical substance.

Checking this box asserts a confidentiality claim for the link between your company and the chemical substance. SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid 116 Production Volume vs.

Production Volume Range

To claim production volume as CBI, check the CBI box next to Block 2. B. 5

To claim production volume range as CBI, check the CBI box next to Block 2. B. 6

EPA wants to provide as much information to the public as possible

If you claim the production volume as CBI, you are not required to claim the production volume range as CBI.

The production volume ranges listed in Table 4 2 of the Reporting Instructions are assigned by EPA 117 SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid SECTION A. CHEMICAL IDENTIFICATION CBI*

2. A. 1 Chemical Identifying Number 67 64 1 2. A. 2 ID Code C 2. A. 3 Chemical Name 2 propanone N 60 X 40 X M5 W3 800,000 X X X X X X X X X X X X X Claiming CBI on Form U 118 SECTION A. INDUSTRIAL PROCESSING AND USE DATA N/ A a. Type of Process or Use b. ( 5 digit) NAICS c. Industrial Function Category d. % Production Volume e. Number of Sites f. Number of Workers Code CBI Code CBI Code CBI Code CBI Code CBI Code CBI 3. A. 1 3. A. 2 3. A. 3 3. A. 4 3. A. 5 3. A. 6 3. A. 7 3. A. 8 3. A. 9 3. A. 10 PART III. PROCESSING AND USE INFORMATION Complete Part III, Sections A and B only if the production volume noted in Block 2. B. 5 is greater than or equal to 300,000 lb/ year PA S1 40 W3 U08 32619 PF S3 60 W5 U08 32551 SECTION B. COMMERCIAL & CONSUMER END USE EXPOSURE RELATED DATA N/ A a. Commercial and Consumer Product Category b. Use in Children's Product c. Percent Production Volume associated with each category d. Maximum Concentration associated with each category Code CBI Y/ N/? CBI Percent CBI Code CBI 3. B. 1 3. B. 2 3. B. 3 3. B. 4 3. B. 5 3. B. 6 3. B. 7 3. B. 8 3. B. 9 3. B. 10 40 C15 M1 NRO C18 30 M2 Y C12 40 M2 N X X X X X X X X X X X X XXX XX X XX X XX X Claiming CBI on Form U 119 Sending CBI to EPA

Send any CBI in a double wrapped package.

Label the inner package with the recipient's name and ` Confidential Business Information'.

Label the outer wrapper with the name and address of the recipient and your return address. Do not place anything on the outer wrapper that would indicate that the package contains CBI.

Send the package by certified or registered mail,

return receipt requested, or by courier service or U. S. Postal Service Express Mail. 120 Submitting Information to EPA 121

General Reporting Information

Electronic Reporting System Topics 122

Information for calendar year 2005 must be submitted to EPA during the submission period which is currently from August 25 to December 23, 2006 ( 40 CFR 710.53).

Information must be submitted for all chemicals that are on the TSCA Inventory at the beginning of the submission period ( currently August 25, 2006), which are otherwise subject to reporting ( 40 CFR 710.45).

Information from calendar year 2005 should be reported during the 2006 submission period.

When do you report? 123

Send a completed written or electronic Form U to EPA at:

OPPT Document Control Officer Mail Code 7407M ATTN: Inventory Update Rule Office of Pollution Prevention and Toxics Environmental Protection Agency Ariel Rios Building 1200 Pennsylvania Avenue, N. W.

Washington, D. C. 20460 How do you submit Form U? 124

You are required to retain records of IUR reports for 5 years after the effective date of the reporting period ( 40 CFR 710.57).

You should retain records that document any information reported to EPA.

If you do not report a substance because the annual production is less than 25,000 pounds, EPA suggests you maintain records to document your reasons for not filing Form U. What are the recordkeeping requirements? 125

Features:

° Platform independent   Java based program can be run using any operating system.

° Automatically creates the required fields for each submission.

° Validation feature checks for submission errors.

Automated IUR Software 126

Minimum System Requirements:

° CD ROM drive ° 30 MB hard drive ° 64 RAM

Software will be downloadable from the IUR Web site or on CD.

Additional information is available in Appendix E of the Instructions for Reporting.

Automated IUR Software Screen 1   Parent Company and Technical Contact Information Standard File Menu Options:

New: Create new Form U Open: Continue work on Form U previously started Validate: Review input Finalize: Save, Validate, Print File Menu Options ° A full help system will be available containing information from the regulatory text and the Instructions for Reporting.

° Click on ` Enable Tool Tips' to see the definition of each data element.

Help Systems Move the mouse over the data element name to see the definition of that element.

Tool Tips Screen 2   Plant Site Information Screens 3 and 4   Parts II Information Arrows in the data entry block note that pull down menus are available. On this page there are pull down menus for chemical identifying number,

number of workers, and maximum concentration. Pull Down Menus In addition to the pull down menus, look up tables define the range codes used in reporting. Look up Tables Screen 4   Parts II Information Screen 5   Questionnaire Screen 6   Parts III Processing and Use Information The look up table for NAICS codes contains a description of the 5 digit NAICS codes and allows you to search on key words. Look up Tables Screen 7   Parts III Commercial and Consumer End Use Information 140

Choose ` Finalize' in the File Menu to save, validate,

and print the certification.

Copy file to disk or CD.

Mail electronic media and signed certification to EPA.

Follow instructions for mailing CBI if required.

Submitting an Electronic Form U 141  Background Information  Reporting Requirements  Completing Form U  CBI  Submitting Information to EPA

Case Study 1   Ammonia Phosphate

Special Topics ° Mixtures, Impurities, By products, Wastes ° Importers/ Exporters ° TSCA/ non TSCA Use

Case Study 2   Acetone

Case Study 3   Xylene

Case Study 4   EDTA

Revisions Rule Training Agenda 142 Beneficiation Plant: Phosphate rock is crushed, washed, and deslimed.

Ore is ground into approximately 2.9 billion lbs of phosphate slurry using a ball mill. The slurry contains 35% net phosphate.

Mining Operation: PQR, a subsidiary of KLM, surface mines 4 billion lbs of phosphate rock containing 25% net phosphate. Phosphoric Acid Plant Sulfuric Acid Plant: At a nearby plant also owned by KLM, sulfur dioxide emitted as a waste product from copper smelting is converted to sulfur trioxide, and then to 2.1 billion pound of 98%

sulfuric acid. Neither sulfur dioxide nor sulfur trioxide are isolated or stored.

Case Study 1   Ammonium Phosphate Production 143 Case Study 1   Ammonium Phosphate Production Ammonia Plant: Hydrogen ( extracted from natural gas)

and nitrogen ( extracted from air) are reacted to produce of ammonia immediately after extraction. PQR produces 215 million lbs of ammonia.

Phosphoric Acid Plant: The phosphate slurry is combined with sulfuric acid to produce 1.65 billion lbs of 78%

phosphoric acid. During this reaction,

2.7 billion pounds of gypsum crystals (> 99% anhydrous CaSO 4) are formed as a byproduct and sold to a wallboard manufacturer.

Granulation Plant: Phosphoric acid is reacted with ammonia to form a liquid slurry. The slurry is granulized and dried to produce 1.5 billion pounds of fertilizer containing 98%

ammonium phosphate and 2% diammonium phosphate.

Beneficiation Plant Sold to Customers Sulfuric Acid Plant 144

Phosphate rock ore?

Which chemical substances need to be reported? 145

Phosphate rock following beneficiation?

Which chemical substances need to be reported? 146

Sulfur dioxide?

Which chemical substances need to be reported? 147

Sulfur trioxide?

Which chemical substances need to be reported? 148

Sulfuric acid?

Which chemical substances need to be reported? 149

Phosphoric acid?

Which chemical substances need to be reported? 150

Gypsum?

Which chemical substances need to be reported? 151

Hydrogen?

Which chemical substances need to be reported? 152

Nitrogen?

Which chemical substances need to be reported? 153

Ammonia?

Which chemical substances need to be reported? 154

Ammonium phosphate?

Which chemical substances need to be reported? 155

Diammonium phosphate?

Which chemical substances need to be reported? 156 SECTION B. PARENT COMPANY AND TECHNICAL CONTACT INFORMATION*

1. B. 1 Name Parent Company 1. B. 2 Dun & Bradstreet Number 1. B. 3 Name 1. B. 4 Telephone 1. B. 5 Email Address 1. B. 6 Address line 1 1. B. 7 Address line 2 Technical Contact 1. B. 8 City 1. B. 9 State 1. B. 10 Zip Code SECTION A. CERTIFICATION Certification Statement:

1. A. 1 Signature 1. A. 2 Date signed 1. A. 3 Name 1. A. 4 Official Title Case Study 1   Part I 157 SECTION C. PLANT SITE IDENTIFICATION 1. C. 1 Plant Site Name 1. C. 2 Plant Site Dun &

Bradstreet Number EPA Facility Identification Number ( for Agency Use Only) LEAVE BLANK 1. C. 3 Street Address ( Line 1)

1. C. 4 Street Address Line 2)

1. C. 5 City 1. C. 6 County/

Parish 1. C. 7 State 1. C. 8 Zip Code Case Study 1   Part I, Section C Note that PQR could complete one copy of Part I, and then Parts II and III for each chemical. 158 SECTION A. CHEMICAL IDENTIFICATION CBI*

2. A. 1 Chemical Identifying Number 2. A. 2 ID Code 2. A. 3 Chemical Name Case Study 1   Part II, Section A 159 SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid Case Study 1   Part II, Section B 160 SECTION A. INDUSTRIAL PROCESSING AND USE DATA N/ A a. Type of Process or Use b. ( 5 digit) NAICS c. Industrial Function Category d. % Production Volume e. Number of Sites f. Number of Workers Code CBI Code CBI Code CBI Code CBI Code CBI Code CBI 3. A. 1 3. A. 2 3. A. 3 3. A. 4 3. A. 5 3. A. 6 3. A. 7 3. A. 8 3. A. 9 3. A. 10 SECTION B. COMMERCIAL & CONSUMER END USE EXPOSURE RELATED DATA N/ A a. Commercial and Consumer Product Category b. Use in Children's Product c. Percent Production Volume associated with each category d. Maximum Concentration associated with each category Code CBI Y/ N/? CBI Percent CBI Code CBI 3. B. 1 3. B. 2 3. B. 3 3. B. 4 3. B. 5 3. B. 6 3. B. 7 3. B. 8 3. B. 9 3. B. 10 Case Study 1   Part III What information should be completed for Part III? 161 Byproducts, Impurities, and Mixtures 162

" Byproduct means a chemical substance produced without separate commercial intent during the manufacture or processing of another chemical substance( s) or mixture( s)." ( 40 CFR 710.3)

" Impurity means a chemical substance which is unintentionally present with another chemical substance." ( 40 CFR 710.3)

Byproduct or Impurity 163

Chemicals listed on the TSCA Inventory may be generated as byproducts from chemical reactions.

You only need to report byproducts that are used for commercial purposes and meet the reporting requirements.

IUR does not recognize a de minimus value.

Do not report byproducts disposed as waste or only combusted as fuel.

Do not report impurities.

Do I Report Byproducts and Impurities? 164 An energy company operates a sulfur recovery plant as a pollution control device to minimize sulfur oxide emissions. This sulfur plant generates 100,000 pounds of elemental sulfur; 40,000 pounds is sold to customers and 60,000 pounds is landfilled as waste. Does this site need to report for sulfur?

Example # 16  Byproduct 165 My company paints its products ( metal articles) with an oil based paint. As the paint cures, new chemical substances are created. Do I need to report these chemical substances under IUR?

Example # 17  Byproduct 166 Organo Chemicals Co. imports styrene. The styrene may contain small quantities of toluene and benzene. Does Organo Chemicals need to report for the benzene and toluene?

Example # 18  Impurity 167 " Mixture means any combination of two or more chemical substances if the combination does not occur in nature and is not, whole or in part, the result of a chemical reaction; except that mixture does include:

( 1) Any combination which occurs, in whole or in part, as a result of a chemical reaction if the combination could have been manufactured for commercial purposes without a chemical reaction at the time the chemical substances comprising the combination were combined and if, after the effective date or premanufacture notification requirements, none of the chemical substances comprising the combination is a new chemical substance, and ( 2) Hydrates of a chemical substance or hydrated ions formed by association of a chemical substance with water." ( 40 CFR 710.3)

Mixtures 168 Are Mixtures Subject to IUR?

Mixtures are not subject to IUR, but the chemical substances comprising the mixture are subject to IUR.

If you import a mixture, you must evaluate your reporting obligations for all chemical substances in the mixture.

If you produce a mixture by combining existing substances that your company does not manufacture and no chemical reaction occurs ( i. e., blending and formulating), do not report those substances. 169 Complex Chemical Substances

Any material extracted or removed from nature is a chemical substance ( not a mixture) even though it may be comprised of many different chemical substances.

Examples: natural gas, iron ore, and lemon oil extract

A complex reaction product combination is not a mixture under TSCA, but rather is a chemical substance.

Example: catalytic cracked petroleum distillates 170 Example # 19  Mixture I manufacture 50,000 pounds of a hydrochloric acid and water mixture, which contains 22,000 pounds of hydrochloric acid. Do I need to complete a Form U for the hydrochloric acid? 171 Example # 20  Mixture I purchase several chemical substances from suppliers and formulate these chemicals to create my cleaning products. The chemicals do not react when I combine them. Do I need to complete a Form U for the substances in my cleaning products? 172 Hydrated Substances

The TSCA Inventory does not include hydrated forms of a chemical substance or hydrated ions formed by association of a chemical substance with water.

Anhydrous forms of chemical substances are subject to IUR regulations.

Example: You manufacture copper sulfate pentahydrate. Copper sulfate is subject to IUR regulations. 173 Example # 21  Hydrate Thrifty Chemical Company manufactured 1,000,000 pounds of sodium hypochlorite pentahydrate, NaOCl° 5 H2O ( CAS# 10022 70 5).

How does Thrifty report this chemical substance? 174 What is an Alloy?

An alloy is a solid mixture containing two or more elements, at least one of which is a metal.

If you blend chemical substances to create an alloy,

but do not manufacture any of the component substances, then you are not subject to IUR reporting.

If you import an alloy, evaluate whether you need to report for each chemical substance present in the alloy.

More information and examples are available in the 1995 Statutory Mixture Policy available at http:// www. epa. gov/ oppt/ newchems/ mixtures. txt 175 Example # 22  Alloy A circuit board manufacturer imports 100,000 pounds of lead solder from a non domestic supplier.

The solder contains 40% tin and 60% lead and is received as wire or bars. The solder is used to manufacture electronic circuit boards. 176 Imported and Exported Chemicals 177 Importer

" Importer means any person who imports any chemical substance or any chemical substance as part of a mixture or article into the customs territory of the U. S. and includes:

( 1) The person primarily liable for the payment of any duties on the merchandise, or ( 2) An authorized agent acting on his/ her behalf ( as defined in 19 CFR 1.11)." ( 40 CFR 710.3)

Chemical importers have the same reporting obligations as chemical manufacturers. 178 Imported Chemicals

Report information for domestic sites only.

Report for each chemical substance in a mixture, if it meets the reporting requirements.

Do not report chemical substances that are imported as a part of an article. For example,

° Coolants contained in refrigeration units ° Chemicals contained in batteries ° Chemicals contained in electronic devices ° Plastic parts whose shape does not change ( not including pellets)

° Metal products whose shape is retained during use ( not including ingots) 179 Import Using a Broker

The party who controls the transaction is responsible for reporting.

° If the broker plays an active role, ordering the chemical substance, arranging for shipment, directing delivery, paying import duties etc., then the broker controls the transaction and has primary responsibility for reporting.

° If the broker merely puts you in touch with a supplier, and you make the individual orders, then you should report.

If no one reports an imported chemical, the EPA can hold all parties involved in the transaction responsible for any violations. See 40 CFR 710.55( b). 180 Example # 23  Importer My chemical company imports a chemical substance directly to sites that sell the product for commercial and consumer use and does not handle the substance.

Who is responsible for reporting this chemical to IUR? 181 Example # 24  Importer I imported a chemical to two different sites within my company during the reporting year   15,000 pounds to one site and 10,000 pounds to a second site. Do I need to report? 182 Example # 25  Importer The corporate headquarters for Lotsa Chemicals Co. purchases 65,000 pounds of a chemical and has it delivered directly to three of its sites Louisiana Site 30,000 pounds Texas Site 30,000 pounds Ohio Site 5,000 pounds Who should report? 183

If you import a mixture but do not know the chemical composition, refer to the MSDS or contact the supplier for more information.

If a chemical composition is proprietary or trade secret, you can claim the chemical name as confidential ( if the supplier will disclose this information to you).

If the supplier will not disclose the chemical name to you, the supplier can submit a Form U for the chemical. Importing Mixtures of Unknown Composition 184 Importing Mixtures of Unknown Composition ( cont'd)

If you know the amount of mixture imported, you can use the following rules to calculate how much chemical you imported from information provided on the MSDS:

° Exact concentration  use concentration provided ° Ex) MSDS: 25% Use: 25%

° Upper bound  use upper limit ° Ex) MSDS: < 40% Use: 40%

° Range   use the maximum of the range ° Ex) MSDS: 60 80% Use: 80%

° Lower bound   subtract out other known constituents to determine the maximum concentration ° Ex) MSDS: > 60% chemical Use: 80%

20% water 185 Exporting a Chemical

Report information for domestic sites only.

If you manufacture a chemical solely for export ( distribute it to a customer( s) outside the U. S. territory),

you still need to complete a Form U if you meet the reporting requirements.

° Complete Parts I & II ( Chemical Identification and Manufacturing Information sections)

° Check the " NA" box for both sections in Part III

If you manufacture a chemical and distribute it to both domestic and foreign customer sites, you still need to complete a Form U if you meet the reporting requirements.

° Complete Parts I & II for the entire PV ° Complete Part III for domestic industrial and consumer uses. 186 Non TSCA Uses 187 Non TSCA Uses

Non TSCA uses are regulated by other federal acts,

including:

° Federal Food, Drug, and Cosmetic Act ° Federal Insecticide, Fungicide, and Rodenticide Act ° Atomic Energy Act 188 What are Non TSCA Uses?

Pesticide active ingredients

Tobacco product additives

Food and food additives

Pharmaceutical drugs

Cosmetic products

Nuclear source, special nuclear, and nuclear byproduct material 189 What are Non TSCA Uses?

Intermediates for chemicals used in certain non

TSCA uses ( e. g. pesticides) are still reportable under IUR.

Solvents, catalysts, and other chemicals used in the synthesis of certain non TSCA use chemicals ( e. g.

pesticides) are still reportable under IUR.

Inert ingredients in pesticides must still be reported;

however, inert ingredients in pharmaceuticals, food additives, and cosmetics are exempt. 190 Example # 26  Non TSCA Uses

Company A manufactures 500,000 lbs of a solvent used in commercial and consumer insecticide products.

Company B manufactures 500,000 lbs of an active ingredient in commercial and consumer insecticide products.

Company C manufactures 500,000 lbs of an intermediate for an active ingredient in commercial and consumer insecticide products.

Which company manufactures a chemical for a non

TSCA use? 191 Reporting a Chemical with a Non TSCA Use

If the chemical is only used for non TSCA uses, you do not need to report under IUR.

If the chemical is used for both TSCA and non TSCA uses, only complete Form U for the portion of the production volume that is associated with TSCA uses. 192 Example # 27  Non TSCA Use Company D manufactures 10,000,000 pounds of benzoic acid. Company XYZ uses 9,000,000 lbs of benzoic acid as a chemical intermediate and formulates 1,000,000 lbs of benzoic acid into mixtures and products. The customers use these products as a a food preservative. How should Company D complete Form U for benzoic acid? 193 Case Study 2   Acetone Manufacturing 30,000,000 lbs used on site as a chemical reactant 40,000,000 lbs shipped off site Industrial Processing and Use next page Chemical reacted AAA Chemicals, Inc. manufactures 70,000,000 lbs of acetone at > 99% conc. 194 Case Study 2   Acetone 40,000,000 lbs of > 99% conc.

acetone shipped off site 30,000,000 lbs used as a chemical reactant at 7 other sites Industrial Processing and Use 10,000,000 lbs shipped to 20 formulators of commercial and consumer adhesives and sealants Commercial and Consumer Use 10,000,000 lbs used as a component in commercial and consumer adhesives and sealants at concentrations from 5% to 45%. Chemical reacted 195 Exposed Workers per Shift Number of Shifts Total Administrative personnel Engineering staff Load regular grade acetone into drums, tank trucks, and rail cars Operate production equipment using acetone as a reactant for other chemicals Maintenance and equipment cleaning Operate and monitor equipment Exposed Workers Activity Number of Workers Potentially Exposed During Manufacturing Case Study 2   Worksheet # 1 196 SECTION A. CHEMICAL IDENTIFICATION CBI*

2. A. 1 Chemical Identifying Number 2. A. 2 ID Code 2. A. 3 Chemical Name Case Study 2   Worksheet # 2 Form U, Part II, Section A 197 SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid Case Study 2   Worksheet # 2 Form U, Part II, Section B 198 Case Study 2   Worksheet # 3 # of Workers # of Sites IFC Code NAICS Code Proc / Use Code Amount,

pounds Process or Use Description Organic Chemical Production On Site Formulation of Adhesives and Sealants Organic Chemical Production Off Site 199 SECTION A. INDUSTRIAL PROCESSING AND USE DATA N/ A a. Type of Process or Use b. ( 5 digit) NAICS c. Industrial Function Category d. % Production Volume e. Number of Sites f. Number of Workers Code CBI Code CBI Code CBI Code CBI Code CBI Code CBI 3. A. 1 3. A. 2 3. A. 3 3. A. 4 3. A. 5 3. A. 6 3. A. 7 3. A. 8 3. A. 9 3. A. 10 Case Study 2   Worksheet # 5 Form U, Part III, Section A 200 Maximum Concentration Used in Children's Products ( Y, N, NRO)

Comm. & Cons.

Product Category Code Amount,

pounds End Use SECTION B. COMMERCIAL & CONSUMER END USE EXPOSURE RELATED DATA N/ A a. Commercial and Consumer Product Category b. Use in Children's Product c. Percent Production Volume associated with each category d. Maximum Concentration associated with each category Code CBI Y/ N/? CBI Percent CBI Code CBI 3. B. 1 3. B. 2 3. B. 3 3. B. 4 3. B. 5 3. B. 6 3. B. 7 3. B. 8 3. B. 9 3. B. 10 Case Study 2   Worksheet # 6 Form U, Part III, Section B 201 Case Study 2   Acetone 40,000,000 lbs of > 99% conc.

acetone shipped off site 30,000,000 lbs used as a chemical reactant at 7 other sites Industrial Processing and Use 10,000,000 lbs shipped to 20 formulators of commercial and consumer adhesives and sealants Chemical reacted How would the facilities receiving acetone report? 202

Aggregate identical combinations of Process or Use, NAICS, and IFC codes.

Once a chemical has been reacted, the downstream uses are not reported.

Workers wearing personal protective equipment should still be reported.

Case Study 2   Summary 203 Case Study 3   Flow Diagram Manufacturing Industrial Processing and Use Company G manufactures 19,000,000 lbs of xylene up to 99% conc. Company G imports 1,000,000 lbs of xylene up to 99% conc.

Company G manufactures a total of 20,000,000 lbs xylene at 99% max. conc.

6,000,000 lbs shipped directly to 3 customers at 99% for use as a chemical reactant 14,000,000 lbs shipped to warehouses for storage until shipment to formulators Xylene reacted to form a different chemical 14,000,000 lbs shipped to 15 customers for formulation into products at 0.5   95% conc. 204 Case Study 3   Flow Diagram 14,000,000 lbs shipped to 15 customers for formulation into products at 0.5   95% conc.

6,000,000 lbs is simply resold to 200 hardware manufacturers at 95% concentration for use as a metal degreaser 800,000 lbs formulated into paint at 15% concentration Industrial Processing and Use 5,000,000 lbs formulated into automotive care products at 35% maximum concentration 2,000,000 lbs blended into pesticide formulations at 10%

concentration 200,000 lbs formulated into as a component of consumer products at 95% maximum concentration 205 Case Study 3   Flow Diagram Industrial Processing and Use Commercial and Consumer Use 5,000,000 lbs formulated into automotive care products at 35% maximum concentration 2,000,000 lbs blended into pesticide formulations at 10%

concentration Automotive care products used by consumers and commercial users at 35% concentration or less Pesticide sold for commercial and consumer applications 206 Case Study 3   Flow Diagram Industrial Processing and Use 800,000 lbs formulated into paint at 15% concentration 200,000 lbs formulated into as a component of consumer products at 95% maximum concentration Commercial and Consumer Use Paint sold for commercial and consumer applications Used by consumers for various uses 207 Case Study 3   Worksheet # 1 Loading tank trucks and rail cars from bulk storage Total Administrative personnel Engineering staff Transferring xylene to bulk storage Drumming operations Analyze samples ( lab technicians)

Maintenance and equipment cleaning Operating and monitoring equipment Exposed Workers Number of Shifts Exposed Workers per Shift Activity Number of Workers Potentially Exposed During Manufacturing 208 Case Study 3   Worksheet # 2 Physical Form and Percent of PV 2. B. 9

2. B. 14 Maximum Concentration and Maximum Concentration Code 2. B. 8 Number of Workers and Number of Workers Code 2. B. 7 Production Volume ( lbs)

2. B. 5 Activity ( M, I, or both)

2. B. 4 Site limited ( Y/ N)

2. B. 3 Chemical Name 2. A. 3 ID Code 2. A. 2 Chemical ID Number 2. A. 1 Entry Block Title Block Manufacturing Information 209 Case Study 3   Worksheet # 3 Industrial Processing and Use Information Blended into pesticides Various consumer products Formulated into automotive care products Chemical reactant Formulated into paints Metal degreaser Code #

Code # Exposed Workers Sites % PV IFC Code NAICS Code Proc /

Use Code Amount,

pounds Process or Use Description 210 Case Study 3   Worksheet # 4 Painting applications Blended into pesticides Various consumer products Use of automotive care products Code % Maximum Concentration % PV Children's Products ( Y, N, ?)

Comm. & Cons.

Product Category Code Amount,

pounds End Use Commercial and Consumer End Use Information 211 SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid Case Study 3   Form U SECTION A. CHEMICAL IDENTIFICATION CBI*

2. A. 1 Chemical Identifying Number 2. A. 2 ID Code 2. A. 3 Chemical Name 212 Case Study 3   Form U SECTION A. INDUSTRIAL PROCESSING AND USE DATA N/ A a. Type of Process or Use b. ( 5 digit) NAICS c. Industrial Function Category d. % Production Volume e. Number of Sites f. Number of Workers Code CBI Code CBI Code CBI Code CBI Code CBI Code CBI 3. A. 1 3. A. 2 3. A. 3 3. A. 4 3. A. 5 3. A. 6 3. A. 7 3. A. 8 3. A. 9 3. A. 10 213 Case Study 3   Summary

Combine manufactured and imported production volumes

Non TSCA uses ( pesticides, cosmetics, etc.) are exempt from IUR reporting 214 Case Study 4   Flow Diagram On Site Activities Chelant Chemical Company ( CCC) manufactures 30,000,000 lbs of Tetrasodium EDTA at 40% concentration ( 75,000,000 lbs of solution)

15,000,000 lbs reacted to other chemical substances on site 15,000,000 lbs of liquid tetrasodium EDTA Some of the product is reacted back to 1,500,000 lbs of highpurity tetrasodium EDTA 1,500,000 lbs of high purity liquid 3,000,000 lbs of solid product 12,000,000 lbs of original liquid 3,000,000 lbs used to make a solid product at 100% conc.

13,500,000 lbs of other chemical substances Shipped Off Site 215 Case Study 4   Flow Diagram High Purity Distribution 750,000 lbs direct to customers 750,000 through distributors ( 325,000 lbs repackaged)

High Purity Liquid Processing and Use 1,500,000 lbs of high purity liquid Institutional and consumer cleaning products 0.1 2.5% conc. Personal care products < 2.5% conc.

High Purity Use # 1 1,200,000 lbs formulated into cleaning products High Purity Use # 2 300,000 lbs formulated into personal care products Commercial and Consumer Use 216 Solid Distribution 3,000,000 through distributors ( 300,000 lbs repackaged)

Solid Product Processing and Use 3,000,000 lbs of solid product Institutional and consumer cleaning products < 3% conc.

Personal care products < 5% conc.

Solid Use # 1 2,400,000 lbs formulated into personal care products Solid Use # 2 600,000 lbs formulated into cleaning products Commercial and Consumer Use Case Study 4   Flow Diagram 217 Case Study 4   Flow Diagram Commercial and Consumer Use Institutional and consumer cleaning products containing EDTA at 0.1 to 5% concentration Liquid Use # 1 4,000,000 lbs formulated into institutional and consumer cleaning products Original Liquid Product Processing and Use CCC Terminals 3,000,000 direct to customers 9,000,000 through terminals( repackaged)

12,000,000 lbs of original liquid product 8,000,000 lbs of original liquid product Next Slide Liquid Distributors 4,000,000 lbs repackaged and sold to cleaning product formulators 218 Case Study 4   Flow Diagram Industrial Cleaner Use at unknown sites Liquid Use # 2 4,800,000 lbs used as a stabilizer in pulp and paper mills 8,000,000 lbs of original liquid product Original Liquid Product Processing and Use Liquid Use # 3 2,000,000 lbs formulated into industrial cleaners Liquid Use # 4 720,000 lbs used as a stabilizer in textile mills Liquid Use # 5 360,000 lbs used to control metal ions in plastic plating Liquid Use # 6 120,000 lbs used in natural gas conditioning 219 High Purity ( operations) Exposed Workers per Shift Number of Shifts Total Solid Production ( sampling and packaging)

Manufacturing ( sampling and transfers) Exposed Workers Activity Number of Workers Potentially Exposed During Manufacturing Case Study 4   Worksheet # 1 220 SECTION A. CHEMICAL IDENTIFICATION CBI*

2. A. 1 Chemical Identifying Number 2. A. 2 ID Code 2. A. 3 Chemical Name Case Study 4   Worksheet # 2 Form U, Part II, Section A 221 SECTION B. MANUFACTURING INFORMATION CBI CBI a. Physical Form b. Percent of Production Volume in Each Physical Form 2. B. 1 Company Information 2. B. 2 Plant Site Identity* Check All That Apply CBI Percent CBI CBI 2. B. 3 Site Limited ( Y/ N) 2. B. 9 Dry Powder CBI 2. B. 4 Activity ( Check all that apply) G Manufacture G Import 2. B. 10 Pellets or Large Crystals CBI 2. B. 5 Production Volume ( LB) 2. B. 11 Water or Solvent Wet Solid CBI 2. B. 6 Production Volume Range LEAVE BLANK 2. B. 12 Other Solid CBI 2. B. 7 Number of Workers ( code) 2. B. 13 Gas or Vapor CBI 2. B. 8 Maximum Concentration ( code) 2. B. 14 Liquid Case Study 4   Worksheet # 2 Form U, Part II, Section B 222 Liquid Use # 1 Liquid Use # 4 Industrial Cleaner Use High Purity Use# 2 Intermediate High Purity Distributors High Purity Use# 1 Liquid Distributors CCC Terminals Solid Use # 2 Solid Use # 1 Solid Distributors Liquid Use # 5 # of Workers # of Sites Liquid Use # 2 Liquid Use # 6 Liquid Use # 3 IFC Code NAICS Code Proc / Use Code Amount,

pounds Process or Use Description Case Study 4   Worksheet # 3 223 Case Study 4   Worksheet # 4 Data Aggregation for Proc/ Use Code PF, NAICS 32562,

and IFC U09 ( Personal Care Products Formulation Solid Use # 1 Total High Purity Use # 2 Code #

Code # Exposed Workers Sites Amount, lbs Process or Use Description 224 SECTION A. INDUSTRIAL PROCESSING AND USE DATA N/ A a. Type of Process or Use b. ( 5 digit) NAICS c. Industrial Function Category d. % Production Volume e. Number of Sites f. Number of Workers Code CBI Code CBI Code CBI Code CBI Code CBI Code CBI 3. A. 1 3. A. 2 3. A. 3 3. A. 4 3. A. 5 3. A. 6 3. A. 7 3. A. 8 3. A. 9 3. A. 10 Case Study 4   Worksheet # 5 Form U, Part III, Section A 225 Maximum Concentration Used in Children's Products ( Y, N, NRO)

Comm. & Cons.

Product Category Code Amount,

pounds End Use Commercial and Consumer End Use Information Case Study 4   Worksheet # 6 226 Case Study 4   Worksheet # 6 Form U, Part III, Section B Information from Worksheet # 6 SECTION B. COMMERCIAL & CONSUMER END USE EXPOSURE RELATED DATA N/ A a. Commercial and Consumer Product Category b. Use in Children's Product c. Percent Production Volume associated with each category d. Maximum Concentration associated with each category Code CBI Y/ N/? CBI Percent CBI Code CBI 3. B. 1 3. B. 2 3. B. 3 3. B. 4 3. B. 5 3. B. 6 3. B. 7 3. B. 8 3. B. 9 3. B. 10 227

Aggregate identical combinations of Process or Use, NAICS, and IFC codes.

Aggregate identical Commercial and Consumer Product Category Codes.

Case Study 4   Summary 228 Revisions Rule 229 Revisions Rule

EPA proposed revisions to the IUR in the Federal Register on January 26, 2005.

Comments must be submitted by February 25, 2005 to docket number OPPT 2004 0106.

These revisions do not affect the intent of the rule or the information collected by the IUR. The revisions clarify certain aspects of the rule and slightly modify how some information is collected.

This presentation is based on the rule as it is currently appears in Code of Federal Regulations and does not include any of the proposed revisions. 230 Revisions Rule

Proposed changes to the IUR include:

° Changing the reporting cycle from every 4 years to every 5 years.

° Moving the submission period from August 25 through December 23 to January 1 though April 30.

° Clarifying the partial exemption petition process.

° Adding additional petroleum process streams to the list of partially exempt chemicals.

° Revising the list of commercial and consumer product categories to combine " Soaps and Detergents" and " Polishes and Sanitation Goods", remove the " Photographic Chemicals" category, and add a " Agricultural Products ( non pesticidal)" category. 231 Revisions Rule

Proposed changes to the rule also include:

° Separating the reporting the volume of the chemical substance imported and the volume manufactured domestically.

° Restricting the reporting of processing and use information to domestic activities.

° Revising the definition of polymer to exclude reference to 1985 Inventory.

° Deleting the requirement to determine confidentiality of a production volume range.