1
1
INFORMATION
COLLECTION
REQUEST
(
ICR)
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STRATOSPHERIC
OZONE
PROTECTION
1.
Identification
of
Information
Collection
a)
Title:
Significant
New
Alternatives
Policy
(
SNAP)
(
40
CFR
part
82,
subpart
G)
(
Renewal).
ICR
Number
1596.06,
OMB
Number
2060­
0226.

b)
Short
Characterization
Title
VI
of
the
Clean
Air
Act
Amendments
of
1990
(
the
Act)
implements
the
obligation
of
the
United
States
under
the
Montreal
Protocol
to
phase
out
the
use
of
ozone­
depleting
substances.
Section
612
of
Title
VI
establishes
as
U.
S.
policy
the
requirement
that
Class
I
and
Class
II
ozone­
depleting
substances
shall
be
replaced,
to
the
maximum
extent
practicable,
by
chemicals,
product
substitutes,
or
alternative
manufacturing
processes
that
reduce
overall
risks
to
human
health
and
the
environment.

EPA
developed
its
Significant
New
Alternatives
Policy
(
SNAP)
program
to
fulfill
the
requirements
of
Section
612.
The
five
major
provisions
of
Section
612
are:

Rulemaking:
Section
612(
c)
requires
EPA
to
enact
rules
making
it
unlawful
to
replace
any
Class
I
or
II
substance
with
any
substitute
that
the
Administrator
determines
may
present
adverse
effects
to
human
health
or
the
environment
where
an
alternative
has
been
identified
that
(
1)
reduces
the
overall
risk
to
human
health
and
the
environment,
and
(
2)
is
currently
or
potentially
available.

Listing
of
Unacceptable/
Acceptable
Substitutes:
Section
612(
c)
also
requires
EPA
to
publish
a
list
of
the
substitutes
prohibited
for
specific
uses.
EPA
must
publish
a
corresponding
list
of
acceptable
alternatives
for
specific
uses
as
well.

Petition
Process:
Section
612(
d)
grants
the
right
for
any
person
to
petition
EPA
to
add
or
delete
a
substance
from
the
lists
published
in
accordance
with
Section
612(
c).
EPA
has
90
days
to
grant
or
deny
a
petition.

90­
Day
Notification:
Section
612(
e)
authorizes
EPA
to
require
any
person
who
produces
a
chemical
substitute
for
a
Class
I
substance
to
notify
EPA
not
less
than
90
days
before
the
new
or
existing
chemicals
are
introduced
into
interstate
commerce
for
significant
new
uses
as
substitutes
for
a
Class
I
substance.
The
producer
must
also
provide
EPA
with
all
unpublished
health
and
safety
studies
on
such
substitutes.

Clearinghouse:
Section
612(
b)(
4)
requires
EPA
to
set
up
a
public
clearinghouse
of
alternative
chemicals,
product
substitutes,
and
alternative
manufacturing
processes
that
are
available
for
products
and
manufacturing
processes
which
use
Class
I
and
II
substances.
2
2
EPA
issued
regulations
on
March
18,
1994,
in
59
FR
13043,
which
are
codified
at
40
CFR
part
82,
subpart
G
(
Section
82.170
et
seq.),
establishing
the
SNAP
program.
EPA's
major
activities
in
the
SNAP
program
are
to
review
proposed
substitutes
based
on
the
risk­
assessment
criteria
and
the
procedures
set
forth
in
the
regulations,
and
to
publish
(
and
update)
a
list
of
acceptable
and
unacceptable
substitutes
by
end
use
categories.

The
information
required
for
collection
under
the
SNAP
regulations
is
described
below
in
Section
4
of
this
statement,
and
is
currently
approved
by
OMB
for
use
through
October
31,
2004.
EPA
is
in
the
process
of
publishing
a
notice
of
intention
to
renew
this
information
collection
request.
This
notice
of
intention
will
be
published
in
the
Federal
Register.

The
previous
ICR
of
2001
had
the
following
Terms
of
Clearance:

This
collection
is
approved.
OMB
questions
the
need
for
respondents
to
retain
information
for
five
years.
EPA
should
reconsider
this
requirement
and
amend
it
as
appropriate.
OMB
notes
further
that
the
cost
estimate
associated
with
this
collection
and
reported
in
block
14
of
the
83­
I
appears
to
be
erroneous.
In
particular,
OMB
notes
that
the
cost
estimates
contained
in
the
supporting
statement
do
not
appear
to
be
properly
discounted.
EPA
should
revise
its
cost
estimate,
also
explaining
how
the
costs
have
changed
since
the
previously
approved
collection.

EPA
has
addressed
each
of
the
items.
Section
3e
contains
a
justification
for
retaining
records.
Cost
estimates
have
been
discounted
per
OMB
guidance
(
7%
discount
rate).
Section
6
contains
additional
clarification.

2.
Need
for
and
Use
of
the
Collection
a)
Authority
for
the
Collection
Information
required
to
be
collected
under
the
SNAP
program
is
intended
to
fulfill
the
general
mandate
in
Section
612(
c)
of
identifying
acceptable
substitutes
that
can
serve
as
replacements
for
ozone­
depleting
substances
being
phased
out
under
the
Act,
as
well
as
unacceptable
substances
which
may
not
be
used
as
replacements
for
ozone­
depleting
substances
being
phased
out
under
the
Act.
Section
612
(
42
U.
S.
C.
7671k)
is
attached
as
Appendix
B,
and
EPA's
implementing
regulations
(
40
CFR
part
82,
subpart
G,
Sect.
82.170
et
seq.)
are
attached
as
Appendix
C.

b)
Use/
Users
of
the
Data
EPA's
Global
Programs
Protection
Division
(
GPD)
will
use
the
information
submitted
to
evaluate
the
acceptability
or
unacceptability
of
the
proposed
alternatives
for
Class
I
and
Class
II
ozone­
depleting
substances.

3.
Non­
duplication,
Consultations,
and
Other
Collection
Criteria
a)
Non­
duplication
3
3
The
specific
information
requested
by
this
notice
is
not
currently
collected
by
EPA
or
any
other
government
agency.
Use
of
the
TSCA/
SNAP
Addendum
form
(
described
in
section
4(
b)
of
this
statement)
will
insure
that
companies
participating
in
the
Toxic
Substances
Control
Act
(
TSCA)
Pre­
Manufacture
Notice
(
PMN)
program
will
not
have
to
duplicate
their
data
for
the
SNAP
program.

b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
for
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
(
69
FR
33383)
on
June
15,
2004.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

c)
Consultations
In
developing
the
regulations
under
the
Act,
EPA
established
an
advisory
committee
for
issues
relating
to
stratospheric
ozone.
The
Stratospheric
Ozone
Protection
Advisory
Committee
(
STOPAC)
membership
included
representatives
from
affected
industries,
environmental
interest
groups,
and
academics
in
related
fields.
Within
the
STOPAC,
subcommittees
were
formed
to
look
at
more
detailed
issues.
The
subcommittee
on
the
SNAP
program
met
several
times
to
discuss
possible
substitutes
for
ozone­
depleting
substances,
guiding
principles
for
SNAP
evaluations,
and
strategies
to
obtain
information
about
substitutes
from
industry.
This
consultation
was
invaluable
in
developing
the
SNAP
Information
Notice
form
(
described
below
in
section
4(
b)).
EPA
also
received
comments
on
its
proposed
SNAP
regulations,
which
identified
the
information
to
be
collected
through
the
SNAP
program,
and
these
comments
were
helpful
in
developing
the
SNAP
Information
Notice
form.

In
preparing
to
renew
this
information
collection
request,
EPA
consulted
with
fewer
than
nine
actual
or
potential
respondents
to
discuss
estimated
burden
hours
and
costs
associated
with
this
information
collection
request.
The
respondents
with
whom
EPA
consulted
are
from
various
industries,
companies,
and
organizations.
They
include:
Tony
Vogelsberg
of
Dupont
Fluoroproducts
(
302)
774­
1000;
Bob
Pfahl
of
Motorola/
American
Electronics
Association
(
847)
576­
5102,
Alan
Miller
of
Uni
of
Maryland
Center
for
Global
Climate
Change
 
currently
with
International
Finance
Corporation
(
202)
473­
8324;
Kevin
Fay
of
Alliance
for
Responsible
CFC
Policy
(
703)
243­
0344.

d)
Effects
of
Less
Frequent
Collection
The
SNAP
program
has
minimized
the
number
of
reporting
and
record­
keeping
requirements
as
much
as
possible
by
requiring
only
a
one­
time
application,
in
the
case
of
reporting
requirements,
or
a
one­
time
record­
keeping.

e)
General
Guidelines
This
rule
does
not
exceed
any
of
the
guidelines
set
forth
in
5
CFR
1320.5(
d)(
2),
except
for
records
retention
for
more
than
3
years.
Retention
periods
for
the
two
SNAP
record­
keeping
requirements
(
described
below
in
section
4(
b)
of
this
statement)
are
not
specified
in
Title
VI
of
4
4
the
Act
or
in
the
SNAP
regulations,
but
EPA
requires
retention
of
these
records
for
five
years
for
enforcement
purposes,
pursuant
to
statutory
authority
under
28
U.
S.
C.
Section
2462,
the
applicable
statute
of
limitations.
Sec.
2462
states,

Except
as
otherwise
provided
by
Act
of
Congress,
an
action,
suit
or
proceeding
for
the
enforcement
of
any
civil
fine,
penalty,
or
forfeiture,
pecuniary
or
otherwise,
shall
not
be
entertained
unless
commenced
within
five
years
from
the
date
when
the
claim
first
accrued
if,
within
the
same
period,
the
offender
or
the
property
is
found
within
the
United
States
in
order
that
proper
service
may
be
made
thereon.

f)
Confidentiality
and
Sensitive
Questions
i)
Confidentiality
Measures
to
protect
confidentiality
of
information
collected
under
the
SNAP
program
are
based
on
EPA's
confidentiality
regulations
(
40
CFR
2.201
et
seq.,
or
Subpart
B.)
SNAP
regulations
(
at
40
CFR
82.182)
describe
these
measures,
which
are
also
mentioned
on
the
front
page
of
each
of
the
SNAP
forms.
Each
form
mentions
basic
information
about
asserting
confidentiality
claims,
and
also
instructs
the
submitter
to
read
the
Guidance
Document,
which
contains
more
detailed
discussion
of
the
procedures
for
confidentiality
claims.
(
See
pages
2­
4
of
the
Guidance
Document,
which,
as
described
in
section
4(
b),
is
attached
as
Appendix
F).
These
procedures
are
described
briefly
below.

Submitters
may
designate
all
or
portions
of
their
forms
or
petitions
as
confidential.
EPA
requires
the
submitters
to
substantiate
their
claim
of
confidentiality.
The
submitter
is
advised
that,
under
Section
114(
c)
of
the
Act,
emissions
data
may
not
be
claimed
as
confidential.
The
submitter
is
also
advised
that
there
are
further
instances,
described
in
the
provisions
of
40
CFR
part
2,
subpart
B,
in
which
confidential
assertions
may
be
reopened
or
denied
even
when
confidentiality
claims
are
initially
received.
The
submitter
will
be
contacted
as
part
of
such
an
evaluation
process.

If
required
substantiation
is
not
provided
along
with
the
submission
of
information
claimed
as
confidential,
EPA
may
make
the
information
available
to
the
public
without
further
notice.
The
submitter
must
provide
three
copies
of
all
submissions
under
the
SNAP
program,
one
of
which
contains
no
information
claimed
as
confidential.
The
non­
confidential
submission
will
be
put
in
the
public
docket.

If
toxicity
or
health
and
safety
studies
are
listed
as
confidential,
this
information
cannot
be
maintained
as
confidential
where
such
data
are
also
submitted
under
TSCA
or
FIFRA,
to
the
extent
that
confidential
treatment
is
prohibited
under
those
statutes.
However,
information
in
a
toxicity
study
that
is
not
health
and
safety
data
and
is
not
relevant
to
the
effects
of
a
substance
on
human
health
and
the
environment,
e.
g.,
discussion
of
process
information,
or
proprietary
blends,
can
be
maintained
as
confidential
subject
to
40
CFR
part
2,
subpart
B.

Information
submitted
as
part
of
a
joint
submission
to
either
SNAP/
TSCA
or
SNAP/
FIFRA
must
adhere
to
the
security
provisions
of
the
program
offices
implementing
these
statutes.
For
such
submissions,
the
SNAP
handling
of
such
notices
will
follow
the
security
provisions
under
5
5
these
statutes.

ii)
Sensitive
Questions
This
section
does
not
apply
because
the
SNAP
regulations
and
the
associated
information
collection
request
do
not
seek
information
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
a)
Respondents
Respondents
for
reporting
requirements,
as
well
as
for
the
recordkeeping
requirement
for
the
exemption
for
small
volume
use,
include
manufacturers,
importers,
formulators
and
processors
of
substitutes
for
ozone­
depleting
substances.
Principally,
these
respondents
are
in
the
following
major
categories
of
industry
groups,
by
Standard
Industry
Code
(
SIC)
and
North
American
Industry
Classification
System
(
NAICS):

Manufacturers,
Chemicals
and
Allied
Products
Industry
SIC
NAICS
Plastics
materials
and
synthetics
282
325211
Soap,
cleaners,
and
toilet
goods
284
325611
Paints
and
allied
products
285
32551
Industrial
organic
chemicals
286
325191
Agricultural
chemicals
287
32532
Miscellaneous
chemical
products
289
325998
Manufacturers,
Rubber
and
Misc.
Plastics
Products
Industry
SIC
NAICS
Plastics
foam
products
3086
32615
6
6
Wholesale
Trade­
Nondurable
Goods
Industry
SIC
NAICS
Chemicals
and
allied
products
516
42261
Miscellaneous
nondurable
products
519
42299
Respondents
for
the
narrowed
use
limit
recordkeeping
requirement
include
end
users
of
the
substitutes
in
the
following
industrial
sectors:

Construction­
Special
Trade
Contractors
Industry
SIC
NAICS
Plumbing,
heating,
and
airconditioning
171
23511
Manufacturing­
Industrial
Machinery
&
Equipment
Industry
SIC
NAICS
Computer
and
office
equipment
357
334111
,
333313
Refrigeration
and
service
machinery
358
333415
Manufacturing­
Electronic
&
Other
Electric
Equipment
Industry
SIC
NAICS
Electric
distribution
equipment
361
335311
Electric
industrial
apparatus
362
335312
Communications
equipment
366
33421
Electronic
components
and
accessories
367
334411
Manufacturing­
Transportation
Equipment
Industry
SIC
NAICS
Aircraft
and
parts
372
336412
Ship
and
boat
building
and
repairing
373
336611
Manufacturing­
Instruments
&
Related
Products
Industry
SIC
NAICS
Search
and
navigation
equipment
381
334511
7
7
Medical
instruments
and
supplies
384
339112
Ophthalmic
goods
385
339115
Services
Industry
SIC
NAICS
Services
to
buildings
734
56179
Computer
and
data
processing
services
737
541511
Refrigeration
service
and
repair
7623
811412,
81131
8
8
b)
Information
Requested
i)
Data
Items
(
for
reporting
and
recordkeeping
requirements):

To
simplify
and
expedite
the
submission
and
review
of
SNAP
notices,
EPA
has
developed
the
following
forms
and
a
guidance
document:

­
SNAP
Information
Notice
(
Appendix
D)
­
TSCA/
SNAP
Addendum
(
Appendix
E)
­
Guidance
Document
for
the
SNAP
Program
Information
Notice
(
Appendix
F)

The
SNAP
Information
Notice
is
the
form
used
in
most
submissions
to
give
notice
of
a
respondent's
plans
to
introduce
a
proposed
substitute
into
the
marketplace.
The
TSCA/
SNAP
Addendum
is
an
abbreviated
SNAP
form
for
submissions
in
situations
where
there
is
joint
statutory
review
between
the
TSCA
PMN
program
and
the
SNAP
program.
The
full
SNAP
Information
Notice
should
be
used
in
the
case
of
a
joint
review
with
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA).
A
petition
should
include
the
same
information
that
is
requested
in
the
SNAP
Information
Notice.
No
additional
information
is
required
for
a
petition.
The
guidance
document
provides
further
information
for
a
respondent
preparing
any
of
these
submissions.

The
forms
were
developed
to
minimize
the
reporting
burden
for
the
submitter;
however,
their
use
is
optional.
Respondents
with
more
efficient
means
of
submitting
the
information
are
encouraged
to
use
them.
EPA
has
based
the
estimated
respondent
burden
and
cost
on
the
use
of
the
recommended
forms;
to
the
extent
a
respondent
uses
more
efficient
means
to
submit
the
data,
the
estimates
contained
in
this
analysis
may
overestimate
the
respondent
burden
and
cost.

1.
SNAP
Information
Notice/
Petition
Data
Items:
Reference:
Sections
82.176(
a),
82.178,
82.180(
a)(
5),
82.184(
c)

The
information
requested
on
the
SNAP
Information
Notice
includes
the
following
data
items:

Name
and
description
of
the
substitute.
To
the
extent
possible,
the
substitute
should
be
identified
by
its
(
1)
commercial
name,
(
2)
chemical
name,
(
3)
trade
name(
s),
(
4)
generic
name,
(
5)
identification
numbers
(
e.
g.,
CAS
registry,
NIOSH
RTECS,
EPA
hazardous
waste,
OHMTADS
DOT/
UN/
NA/
IMCO
shipping,
HSDB,
NCI),
(
6)
chemical
formula,
and
(
7)
chemical
structure.

Physical
and
chemical
information.
Key
properties
that
should
be
included
to
characterize
the
substitute
are:
molecular
weight;
physical
state;
melting
point;
boiling
point;
density;
odor
threshold;
solubility;
partition
coefficients
(
Log
Kow,
Log
Koc);
and
vapor
pressure.
9
9
Substitute
applications.
Identification
of
the
applications
in
which
the
substitutes
are
likely
to
be
used
is
required.
It
is
essential
to
provide
a
complete
list
of
potential
uses
as
the
substitute
listing
required
by
section
612(
c)
is
specific
to
application.

Process
description.
For
each
application
identified,
EPA
is
requesting
available
descriptive
data
on
processing,
including
in­
place
pollution
controls.
Such
information
will
be
helpful
in
characterizing
workplace
and
environmental
releases
and
exposures.

Ozone
depletion
potential.
The
predicted
ozone
depletion
potential
(
ODP)
of
substitute
chemicals
is
requested.
The
submitter
should
also
provide
sufficient
supporting
documentation­­
either
a
citation
or
the
background
information
used
to
develop
the
ODP.
For
purposes
of
calculating
ODP,
EPA
recommends
the
methodology
used
in
the
most
recent
Scientific
Assessment
of
Ozone
Depletion:
1991,
which
was
prepared
for
the
United
Nations
Environment
Programme.
[
1]
If
a
submitter
is
uncertain
about
a
compound's
ODP,
he
or
she
should
contact
EPA
to
receive
a
list
of
Class
I
and
II
compounds.
In
those
few
cases
where
a
compound
is
believed
to
have
an
ODP
but
is
not
on
this
list,
EPA
will
work
directly
with
the
submitter
to
determine
the
appropriate
course
of
action.

Global
warming
potential.
EPA
is
requesting
readily
available
data
on
the
total
global
warming
potential
(
GWP)
of
the
substitute
in
its
particular
application
(
e.
g.,
as
a
refrigerant,
foam
blowing
agent,
etc.)
The
total
GWP
considers
both
direct
and
indirect
effects.
Direct
effects
comprise
the
direct
global
warming
impacts
of
using
a
substitute.
EPA
is
requesting
that
all
GWPs
be
referenced
to
CO2
using
the
methodology
recommended
by
the
Intergovernmental
Panel
for
Climate
Change
(
IPCC).
[
2]
Indirect
effects
explicitly
consider
the
impact
on
global
warming
arising
from
changes
in
energy
consumption
associated
with
the
use
of
a
substitute
(
e.
g.,
an
alternative
refrigerant).
This
latter
measure
can
be
identified
as
changes
in
energy
efficiency
or
demand
relative
to
the
substitute
being
replaced.

Toxicity
data.
Information
on
toxicity
from
acute
and
chronic
exposure
by
inhalation
of
a
substitute
chemical,
its
impurities,
and
its
degradation
products
on
any
organism
(
e.
g.,
humans,
mammals,
fish,
wildlife,
and
plants)
is
required.
For
mammals,
EPA
is
requesting
a
minimum
submission
of
the
following
tests
to
characterize
substitute
risks:
a
range­
finding
10
10
study,
and
a
90­
day
subchronic
repeated
dose
study
in
an
appropriate
rodent
species.
For
substitutes
that
are
being
evaluated
as
fire
suppressants,
a
cardiotoxicity
study,
usually
performed
on
a
dog,
is
also
required.
Additional
mammalian
toxicity
tests
will
be
identified
based
on
the
substitute
and
application
being
evaluated.
To
sufficiently
characterize
aquatic
toxicity
concerns,
both
acute
and
chronic
toxicity
test
results
for
a
variety
of
species
is
required.
EPA
requires
a
minimum
data
set
as
described
in
"
Guidelines
for
Deriving
Numerical
National
Water
Quality
Criteria
for
the
Protection
of
Aquatic
Organisms
and
their
Uses,"
which
is
available
through
the
National
Technical
Information
Service
(#
PB
85­
227049).
Other
relevant
information
and
data
summaries,
such
as
the
Material
Safety
Data
Sheets,
should
also
be
submitted.
Submission
of
the
actual
toxicity
studies
is
most
beneficial;
however,
it
is
not
necessary
to
submit
these
reports
if
they
have
been
supplied
to
EPA
as
part
of
other
regulatory
submissions.
To
assist
in
locating
these
studies,
the
submitter
must
provide
a
sufficiently
clear
citation
to
ensure
that
these
studies
can
be
located
by
EPA
in
a
timely
fashion.
EPA
requires
that
submitters
providing
information
on
new
chemicals
for
joint
review
under
TSCA
and
SNAP
adhere
to
the
TSCA
minimum
testing
requirements
described
in
TSCA
section
5.

Environmental
Fate
and
Transport.
Where
available,
information
must
be
submitted
on
the
environmental
fate
and
transport
of
substitutes.
Such
data
shall
include
information
on
bioaccumulation,
biodegradation,
adsorption,
volatility,
transformation,
and
other
data
necessary
to
characterize
movement
and
reaction
of
substitutes
in
the
environment.

Flammability.
Data
on
the
flammability
of
a
substitute
chemical
or
mixture
are
required.
Specifically,
data
on
flash
point
and
flammability
limits
are
needed,
as
well
as
information
on
the
procedures
used
for
determining
the
flammability
limits.
For
substitutes
that
will
be
used
in
consumer
applications,
documentation
of
testing
results
conducted
by
independent
laboratories
(
e.
g.,
Underwriters
Laboratories)
should
be
submitted
where
appropriate.
Detail
on
any
suggested
abatement
techniques
to
minimize
the
risks
associated
with
the
use
of
flammable
substances
or
blends
should
also
be
provided.
EPA
recognizes
that
many
promising
alternatives
may
be
considered
marginally
flammable,
but
can
be
used
safely
and
effectively.
The
information
requested
on
this
topic
will
help
EPA
make
a
balanced
decision
regarding
the
use
of
a
flammable
alternative,
which
one
commenter
supported.

Exposure
data.
The
submitter
should
provide
extant
modeling
or
monitoring
data
on
exposures
associated
with
the
manufacture,
formulation,
transport,
and
use
of
a
substitute.
Descriptive
process
information
for
each
substitute
application,
as
requested
above,
will
be
used
to
develop
exposure
estimates
where
exposure
data
are
not
readily
available.
Depending
on
the
application,
exposure
profiles
will
be
needed
for
workers,
consumers,
and
the
general
population.
11
11
Environmental
release
data.
Available
data
on
emissions
from
the
substitute
application
and
equipment,
as
well
as
pollutant
releases
or
discharge
to
all
environmental
media
(
ambient
air,
surface
water,
hazardous/
solid
waste),
are
needed
to
complete
the
risk
characterization.
Submitters
should
provide
information
on
release
locations,
if
known.
Any
information
on
any
pollution
controls
used
or
that
could
be
used
in
association
with
the
substitute
(
e.
g.,
emissions
reduction
technologies,
wastewater
treatment,
treatment
of
hazardous
waste)
and
the
costs
of
such
technology
are
also
requested.

Replacement
ratio
for
a
chemical
substitute.
EPA
is
requesting
information
on
the
replacement
ratio
for
a
chemical
substitute
versus
the
Class
I
or
II
substances
being
replaced.
For
example,
in
the
case
of
a
degreasing
agent,
how
much
more
or
less
of
the
substitute
chemical
is
needed?
This
will
have
an
impact
on
the
estimated
incremental
cost
and
environmental
effects
associated
with
use
of
the
substitute.

Required
changes
in
technoloqy.
Detail
on
the
changes
in
technology
needed
to
use
the
alternative
is
requested.
Such
information
should
include
a
description
of
whether
the
substitute
can
be
used
in
existing
equipment­­
with
or
without
some
retrofit­­
or
in
new
equipment.
Data
on
the
cost
(
capital
and
operating)
and
estimated
life
of
the
technology
modifications
should
also
be
submitted.
These
economic
data
are
essential
to
understanding
the
near­
term
potential
of
using
an
alternative.

Cost
of
substitute.
EPA
is
requesting
data
on
the
expected
average
cost
of
the
alternative.
The
cost
of
the
substitute
can
be
expressed,
for
example,
in
terms
of
$/
pound
(
for
a
chemical
substitute)
or
as
incremental
capital
and
operating
costs
associated
with
a
retrofit
or
new
equipment.
In
addition,
information
is
needed
on
the
expected
equipment
lifetime
for
an
alternative
technology.
Other
critical
cost
considerations
should
be
identified,
as
appropriate.
For
example,
it
is
important
to
understand
the
incremental
costs
associated
with
losses
or
gains
in
energy
efficiency
associated
with
use
of
a
substitute
relative
to
current
experience.

Availability
of
substitute.
EPA
needs
to
understand
the
extent
to
which
a
substitute
is
already
commercially
available
or
the
expected
date
at
which
it
may
become
available.
The
timing
of
availability
is
an
important
factor
in
assessing
the
overall
health
and
environmental
impacts
of
the
substitute.

Anticipated
market
share.
Data
on
the
anticipated
near­
term
and
long­
term
(
over
the
next
five
years)
nationwide
substitute
sales
(
not
just
those
of
the
submitter)
is
requested.
This
information
can
be
presented
in
several
ways,
for
example:
a
percentage
of
existing
nationwide
use
of
Class
I
or
Class
II
chemicals
in
a
particular
application;
number
of
units/
products
to
be
produced;
or
pounds
of
substitute
sold.
This
information
is
required
to
assess
the
potential
impacts
related
to
total
consumption
and
environmental
releases.

Applicable
regulations
under
other
environmental
statutes.
The
submitter
is
requested
to
provide
information
on
whether
the
substitute(
s)
are
regulated
under
other
statutory
authorities,
in
particular
the
Clean
Water
Act,
Safe
Drinking
Water
Act,
the
Resource
Conservation
and
Recovery
Act,
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act,
the
Toxic
Substances
Control
Act,
and
other
titles
under
the
CAA.
EPA
will
evaluate
substitutes
under
the
SNAP
program
subject
to
these
existing
regulatory
constraints.
12
12
Information
already
submitted
to
EPA.
Individuals
may
have
already
submitted
information
being
requested
in
the
SNAP
program
notice
to
EPA
as
part
of
past
regulatory
and
information­
gathering
activities.
If
such
a
situation
exists,
and
to
minimize
reporting
burden,
the
submitter
should
provide
the
following
information
to
help
locate
the
data
already
maintained
at
EPA:
type
of
information
submitted;
the
date
of
submission;
the
name
of
the
EPA
office
to
which
the
data
were
sent;
description
of
the
regulatory
program;
and
a
document­
control
number,
if
assigned
(
e.
g.,
a
PMN
number).
If
the
submitter
cannot
provide
references
to
data
sent
previously
to
EPA,
he
or
she
should
include
all
requested
information
in
the
SNAP
notice.

Information
already
available
in
the
literature.
If
any
of
the
data
needed
to
complete
the
SNAP
program
notice
are
available
in
the
literature,
the
submitter
should
provide
EPA
with
references
for
such
information.
Failure
to
provide
EPA
with
sufficient
citation,
however,
will
delay
review
of
the
notice.
Additionally,
submitters
are
encouraged
to
provide
copies
of
any
literature
to
expedite
review,
particularly
if
the
citation
is
from
a
source
not
readily
available
to
EPA
researchers.
Any
references
from
sources
in
foreign
languages
should
be
translated.

Additional
information.
If
critical
new
information
becomes
available
during
the
review
period
that
may
influence
EPA's
evaluation
of
a
substitute,
the
submitter
must
notify
EPA
of
the
existence
of
such
information
within
10
days
of
learning
of
such
data.
The
submitter
must
also
inform
EPA
of
new
studies
underway,
even
if
the
results
will
not
be
available
within
the
review
period.

2.
TSCA/
SNAP
Addendum
Form
Data
Items:
Reference:
Sections
82.176(
a),
82.178,
82.180(
a)(
5)

EPA
has
identified
only
a
few
additional
data
elements,
beyond
those
already
required
by
the
Premanufacture
Notice
(
PMN)
program,
that
would
need
to
be
included
for
review
under
the
SNAP
program.
For
this
reason,
the
added
burden
to
respondent
from
the
SNAP
program,
above
that
already
required
by
the
PMN
program,
is
very
small.

The
additional
data
elements
in
the
TSCA/
SNAP
Addendum
include:

­
The
ozone­
depletion
potential,
­
The
global­
warming
potential,
­
Explicit
quantification
of
the
cost
of
using
the
substitute
(
including
the
chemical
replacement
data,
chemical
cost
data,
incremental
equipment
expenditures
needed
to
use
the
substitute,
and
information
on
the
cost
implications
resulting
from
changes
in
energy
consumption),
and
­
Documentation
of
testing
results
regarding
the
flammability
of
substitutes
that
will
be
used
in
consumer
applications.

If
critical
new
information
becomes
available
during
the
review
period
that
may
influence
EPA's
evaluation
of
a
substitute,
the
submitter
must
notify
EPA
of
the
existence
of
such
information
within
10
days
of
learning
of
such
data.
The
submitter
must
also
inform
EPA
of
new
studies
underway,
even
if
the
results
will
not
be
available
within
the
review
period.

3.
Notification
for
Test
Marketing
Activity
Data
Items
Reference:
Section
82.176(
b)(
5)
13
13
Uses
of
substitutes
for
the
sole
purpose
of
test
marketing
is
exempt
from
SNAP
notification
requirements
until
90
days
prior
to
the
introduction
of
such
substitutes
for
full­
scale
commercial
sale
in
interstate
commerce.
Persons
taking
advantage
of
this
exemption
are,
however,
required
to
notify
EPA
in
writing
that
they
are
conducting
test
marketing
30
days
prior
to
the
commencement
of
such
marketing.
Notification
shall
include
the
following
data
items:

­
Name
of
the
substitute
­
Volume
used
in
the
test
marketing
­
Intended
sector
end
uses
­
Expected
duration
of
the
test
marketing
period
4.
Recordkeeping
for
Substitutes
Acceptable
Subject
to
Narrowed
Use
Limits
Data
Items
Reference:
Section
82.180(
b)(
3)

If
a
substitute
is
listed
by
EPA,
in
a
decision
on
a
SNAP
information
notice,
TSCA/
SNAP
addendum,
or
petition,
as
acceptable
subject
to
narrowed
use
limits,
end
users
intending
to
use
the
substitute
must
determine
that
other
alternatives
are
not
technically
feasible.
Such
end
users
must
document
the
results
of
their
evaluation
and
retain
the
results
on
file
for
the
purpose
of
demonstrating
compliance.
This
documentation
shall
include
the
following
data
items:

­
Descriptions
of
substitutes
examined
and
rejected
­
Processes
or
products
in
which
the
substitute
is
needed
­
Reason
for
rejection
of
other
alternatives,
e.
g.,
performance,
technical
or
safety
standards
­
The
anticipated
date
other
substitutes
will
be
available
and
projected
time
for
switching
to
other
available
substitutes.

Respondents
are
required
to
maintain
these
records
five
years.
See
section
3(
d)
of
this
statement
for
the
justification
for
this
length
of
time.

5.
Recordkeeping
for
Small
Volume
Use
Exemption
Data
Items
Reference:
Section
82.176(
b)(
3)

Within
the
eight
principal
SNAP
sectors,
persons
introducing
a
substitute
whose
expected
volume
of
use
amounts
to
less
than
10,000
pounds
per
year
within
a
SNAP
sector
are
exempt
from
notification
requirements.
Persons
taking
advantage
of
this
exemption
for
small
uses
must
maintain
documentation
for
each
substitute
describing
how
the
substitute
meets
this
small
use
definition.
This
documentation
must
include
the
following
data
item:

­
Annual
production
and
sales
information
by
sector
Respondents
are
required
to
maintain
these
records
five
years.
See
section
3(
d)
of
this
statement
for
the
justification
for
this
length
of
time.

ii)
Respondent
Activities
14
14
There
are
five
types
of
respondent
reporting
and
recordkeeping
activities
required
pursuant
to
Section
612
of
the
Act
and
the
SNAP
regulations
promulgated
thereunder,
40
CFR
Sections
82.170­
82.184:

Reporting:
SNAP
Information
Notice/
Petition
This
includes
the
following
types
of
activities:

­
Pre­
submittal
contact
with
EPA.
­
Prepare
and
submit
notice
or
petition
to
EPA.
­
Respond
to
EPA
requests
for
additional
information
and/
or
notify
EPA
of
additional
information
as
it
becomes
available.

Reporting:
TSCA/
SNAP
Addendum
This
includes
the
following
types
of
activities:

­
Pre­
submittal
contact
with
EPA.
­
Prepare
and
submit
form
to
EPA.
­
Respond
to
EPA
requests
for
additional
information
and/
or
notify
EPA
of
additional
information
as
it
becomes
available.

Reporting:
Notification
for
Test
Marketing
Activity
­
Compile
information,
and
prepare
and
submit
letter
to
EPA
with
the
information.

Recordkeeping:
Substitutes
Acceptable
Subject
to
Narrowed
Use
Limits
­
Assess
other
acceptable
alternative
substitutes.
­
Compile
and
prepare
record
of
assessment.

Recordkeeping:
Small
Volume
Uses
­
Assess
sector
sales.
­
Compile
and
prepare
record
of
sector
sales.

5.
The
Information
Collected
­
Agency
Activities,
Collection
Methodology.
and
Information
Management.

a)
Agency
Activities
EPA
activities
associated
with
reviewing
SNAP
submissions
consist
of
the
following:

Pre­
submittal
contact
with
respondent
­
Send
forms
and
guidance
document
to
potential
respondents.
­
Answer
questions
regarding
the
completion
of
SNAP
program
forms
and
the
need
to
submit
15
15
a
SNAP
notice.

Review
and
Communication
regarding
submission
­
Assign
tracking
number
to
SNAP
notice
or
petition.
­
Review
SNAP
notice
or
petition
for
sufficiency
of
information
provided,
send
letter
of
receipt,
and
notify
submitter
if
additional
information
is
required.
­
Review
requests
for
confidentiality
and
provide
appropriate
protection.
­
Review
SNAP
notice
or
petition,
and
notify
submitter
of
decision.
­
Review
TSCA/
SNAP
Addendum
in
detail,
coordinate
with
TSCA
office,
and
notify
submitter
of
decision.
­
Prepare
and
evaluate
EPA­
initiated
changes
to
the
SNAP
determinations.

Administrative
operations
­
Maintain
administrative
tracking
system
for
all
submissions.
­
Maintain
technical
clearinghouse
to
help
users
identify
acceptable
substitutes
that
are
listed
under
the
SNAP.
­
Prepare
and
publish
in
the
Federal
Register
periodic
notices
and
rulemakings
to
inform
the
public
of
any
changes
to
the
SNAP
lists
and
of
all
pending
determinations.

b)
Collection
Methodology
and
Management
(
including
discussion
of
the
items
mentioned
in
OMB's
remarks
in
the
1994
approval
of
the
original
ICR)

EPA
collects
information
through
submission
by
respondents
of
a
SNAP
Information
Notice,
a
TSCA/
SNAP
Addendum,
or
a
petition.
In
each
case,
the
collection
methodology
is
the
same.
EPA
has
90
days
from
receipt
of
a
complete
submission
to
respond
to
the
filing,
and
EPA
must
publish
its
decisions
in
these
submissions
in
its
periodic
Federal
Register
notices
and
rulemakings.

Initially,
EPA
reviews
each
submission
for
completeness
within
15
days
of
receipt
of
the
submission.
If
information
is
incomplete,
the
submitter
will
be
contacted
for
this
information.
Thus,
the
15
day
completeness
review
period
begins
on
the
date
EPA
receives
a
submission,
and
it
ends
15
days
after
the
date
of
receipt.

The
90­
day
review
period
will
not
commence
until
EPA
judges
the
submission
complete,
although
manufacturers
of
a
new
substitute
may
introduce
the
substitute
into
interstate
commerce
90
days
after
EPA
receives
a
submission
if
EPA
has
not
already
rendered
an
unacceptability
determination.
Once
the
90­
day
review
period
has
begun,
EPA
may
determine
that
additional
data
are
necessary,
or
the
submitter
may
notify
EPA
of
additional
information,
which
has
become
available
and
may
influence
EPA's
evaluation
of
the
proposed
substitute.
In
either
case,
EPA
may
contact
the
submitter
to
explore
extending
or
suspending
the
review
period,
depending
on
the
type
of
data
and
the
stage
of
review.
Thus,
the
90­
day
review
period
begins
on
the
date
a
complete
submission
is
received
by
EPA,
and
it
ends
90
days
thereafter,
unless
EPA
and
the
submitter
have
agreed
to
another
date.
16
16
EPA
will
check
data
quality
of
each
submission
by
its
review
of
the
data
in
each
submission.
EPA
will
use
its
existing
systems
for
telephones
and
computers
to
process
each
submission.
Each
submission
is
assigned
a
tracking
number,
which
will
identify
the
submission
in
the
public
docket
where
non­
confidential
versions
of
each
submission
are
filed,
as
well
as
the
filing
system
at
EPA
for
the
confidential
versions
of
each
submission.
The
public
can
get
access
to
non­
confidential
data
in
each
submission
by
visiting
the
public
docket
maintained
in
Washington,
DC.

There
is
a
means
for
filing
electronic
SNAP
submissions
with
EPA.
EPA
has
established
both
a
telephone
"
hotline"
clearinghouse
and
an
electronic
clearinghouse
of
useful
information
about
the
SNAP
program,
including
updated
lists
of
acceptable
and
unacceptable
substitutes,
which
helps
some
respondents
reduce
the
burden
of
gathering
information
to
prepare
a
SNAP
submission.

c)
Small
Entity
Flexibility
Submission
of
a
notice
to
EPA
90
days
before
introducing
a
new
substitute
into
commerce
is
required
by
statute,
regardless
of
the
size
of
the
submitter.
The
information
requested
in
the
SNAP
program
is
necessary
for
EPA
to
evaluate
the
proposed
substitute
chemicals
which
will
be
listed
as
acceptable
or
unacceptable,
depending
on
the
evaluations.
The
SNAP
program
has
directed
the
burden
on
manufacturers
and
formulators,
rather
than
the
end
user,
which
greatly
reduces
the
potential
burden
on
small
entities.

Additionally,
SNAP
reporting
requirements
provide
an
exemption
for
persons
introducing
a
substitute
whose
expected
volume
of
use
amounts
to
less
than
10,000
pounds
per
year
within
a
SNAP
industrial
sector.
This
exemption
reduces
the
potential
burden
on
small
entities,
although
such
persons
are
subject
to
a
recordkeeping
requirement
documenting
their
qualification
for
this
exemption.

d)
Collection
Schedule
The
SNAP
regulations
were
promulgated
March
18,
1994,
and
collection
of
information
as
required
therein
commenced
on
that
date.
EPA
accepts
and
reviews
SNAP
submissions
as
they
are
provided
to
EPA
by
respondents.
Information
in
the
public
docket
on
these
submissions
has
been
available
since
submissions
have
been
received.

6.
Estimating
the
Burden
and
Cost
of
Collection
a)
Estimating
Respondent
Burden
b)
Estimating
Respondent
Costs
The
following
tables
(
6A/
B­
1
through
6A/
B­
5)
present
estimates
of
annual
respondent
burden
hours
and
costs
for
each
of
the
respondent
activities
described
in
section
4(
b)(
ii),
with
explanations
of
the
assumptions
made
in
each
table.
All
cost
values
are
in
2004
$
and
reflect
inflation
since
the
previous
ICR.
Labor
costs
are
from
the
Bureau
of
Labor
Statistics.

Exhibit
6A/
B­
1:
SNAP
Information
Notice/
Petition:
Annual
Respondent
Burden
and
Cost
17
17
(
1)

The
following
table
shows
estimates
of
respondent
burden
hours
and
costs
for
the
first
set
of
activities
listed
above
in
section
4(
b)(
ii).
In
making
these
estimates,
EPA
relied
on
its
experience
in
ten
years
of
implementing
the
SNAP
program
and
its
consultations
with
respondents,
and
made
the
following
assumptions:

­
The
number
of
inquiries
about
filing
a
SNAP
Information
Notice
or
petition
is
15
per
year,
of
which
90%
(
rounded
to
14)
submit
the
filing.
The
number
of
CBI
requests
is
50%
of
the
14
submittals.
The
number
of
filings
for
which
additional
information
is
required
is
50%
of
the
14
submittals.

­
Labor
cost
of
$
56.00
represents
an
average
hourly
rate
of
pay,
including
overhead
and
benefits,
for
a
private
company
for
labor
that
would
be
classified
as
"
technical"
time
for
the
bulk
of
the
effort
and
"
clerical"
time
for
a
small
part
of
the
effort.

­
Estimated
start­
up
cost
is
based
on
the
cost
of
required
toxicological
data
which,
in
25%
of
SNAP
filings,
is
a
one­
time
event
incurred
for
the
sole
purpose
of
fulfilling
SNAP
requirements.
EPA
estimates
the
cost
of
such
data
ranges
from
$
30,000
to
$
350,000,
with
more
than
half
of
respondents
incurring
such
costs
in
an
amount
equal
to
or
less
than
$
75,000.
EPA
multiplied
a
weighted
average
of
these
costs
($
133,610)
by
.25
to
get
an
estimated
average
start­
up
cost
of
$
33,402
which
represents
the
cost
distributed
among
all
respondents.
This
total
start­
up
cost
was
discounted
to
present
value
using
20
years
as
the
useful
life
of
the
chemical
for
which
data
was
collected
and
7%
as
the
discount
value.

­
There
is
no
annual
operating
and
maintenance
cost
associated
with
this
reporting
requirement.

Table
6A/
B­
1:
SNAP
INFORMATION
NOTICE
/
PETITION
(
A)

Hours/

Year
Resp.
(
B)
Labor
Cost
(@

$
56/

hr)
per
Resp.

per
Year
(
C)

Annualized
Startup
Cost
per
Resp.
(
D)
No.
of
Resp.
(
E)
Total
Hrs/
Year
(
All
Resp.)

(
A*
D)
(
F)

Total
Annualized
Cost
per
Year
(
All
Resp.)

(
C*
D)
(
G)
Total
Labor
Cost
per
Year
(
All
Resp.)

(
B*
D)
(
H)
Total
Cost
per
Yea
(
All
Resp.)

(
F+
G)

a)
Pre­
submittal
contact
with
EPA
Obtain
form
and
guidance
document
from
EPA
0.5
$
28
$
0
15
7.5
$
0
$
420
$
420
Review
form
and
guidance
document
from
EPA
3
$
168
0
$
0
$
0
Identify
chemical
and
applications
0.5
$
28
$
0
15
7.5
$
0
$
420
$
420
b)
Prepare
and
submit
form
to
EPA
$
0
Collect
data
for
form
122
$
6,832
$
3,153
14
1708
$
44,142
$
95,648
$
139,790
Prepare
notification
form
10
$
560
$
0
14
140
$
0
$
7,840
$
7,840
Prepare
non­
confidential
version
of
form
if
CBI
is
declared
4
$
224
$
0
7
28
$
0
$
1,568
$
1,568
c)
Respond
to
EPA
requests
for
add'l
information
and/
or
notify
EPA
of
add'l.
info.
$
0
Communicate
with
EPA
2
$
112
$
0
7
14
$
0
$
784
$
784
18
18
Collect
data
6
$
336
$
0
7
42
$
0
$
2,352
$
2,352
Prepare
data
to
send
to
EPA
2
$
112
$
0
7
14
$
0
$
784
$
784
Subtotals
150
$
8,400
$
3,153
varies
but
15
is
most
1,961.0
$
44,142
$
109,816
$
153,958
Exhibit
6A/
B­
2:
TSCA/
SNAP
ADDENDUM:
Annual
Respondent
Burden
and
Cost
(
2)

The
following
table
shows
estimates
of
respondent
burden
hours
and
costs
for
the
second
set
of
activities
listed
above
in
section
4(
b)(
ii).
In
making
these
estimates,
EPA
relied
on
its
experience
in
ten
years
of
implementing
the
SNAP
program
and
its
consultations
with
respondents,
and
made
the
following
assumptions:

­
Three
inquires
per
year
come
in
regarding
a
TSCA/
SNAP
Addendum.
Half
actually
submit
the
filing
(
rounded
to
2).
One
CBI
request
comes
from
the
2
submittals.
The
number
of
filings
for
which
additional
information
is
required
is
1
of
the
2
submittals.

­
Labor
cost
of
$
56.00
represents
an
average
hourly
rate
of
pay,
including
overhead
and
benefits,
for
a
private
company
for
labor
that
would
be
classified
as
"
technical"
time
for
the
bulk
of
the
effort
and
"
clerical"
time
for
a
small
part
of
the
effort.

­
There
is
no
start­
up
or
operating
and
maintenance
cost
associated
with
the
TSCA/
SNAP
Addendum.

Table
6A/
B­
2:
TSCA/
SNAP
Addendum
(
A)

Hours/

Year
Resp.
(
B)
Labor
Cost
(@

$
56/

hr)
per
Resp.

per
Year
(
C)
No.
of
Resp.
(
D)
Total
Hrs/
Year
(
All
Resp.)

(
A*
C)
(
E)
Total
Labor
Cost
per
Year
(
All
Resp.)

(
B*
C)

a)
Pre­
submittal
contact
with
EPA
Obtain
form
and
guidance
document
from
EPA
0.5
$
28
3
1.5
$
84
Review
form
and
guidance
document
from
EPA
3
$
168
3
9
$
504
Identify
chemical
and
applications
0.5
$
28
3
1.5
$
84
b)
Prepare
and
submit
form
to
EPA
Collect
data
for
form
30
$
1,680
2
60
$
3,360
Prepare
notification
form
5
$
280
2
10
$
560
Prepare
non­
confidential
version
of
form
if
CBI
is
declared
2
$
112
1
2
$
112
c)
Respond
to
EPA
requests
for
add'l
information
and/
or
notify
EPA
of
add'l.
info.

Communicate
with
EPA
1
$
56
2
2
$
112
Collect
data
3
$
168
2
6
$
336
Prepare
data
to
send
to
EPA
1
$
56
2
2
$
112
19
19
Subtotals
46
$
2,576
varies
but
3
is
most
94.0
$
5,264
Exhibit
6A/
B­
3:
Notification
for
Test
Marketing
Activity:
Annual
Respondent
Burden
and
Cost
(
3)

The
following
table
shows
estimates
of
respondent
burden
hours
and
costs
for
the
third
set
of
activities
listed
above
in
section
4(
b)(
ii).
In
making
these
estimates,
EPA
relied
on
its
experience
in
ten
years
of
implementing
the
SNAP
program
and
its
consultations
with
respondents,
and
made
the
following
assumptions:

­
The
number
of
notifications
for
test
marketing
activity
is
one
per
year,
and
the
number
of
hours
per
notification
is
two.

­
Labor
cost
of
$
56.00
represents
an
average
hourly
rate
of
pay,
including
overhead
and
benefits,
for
a
private
company
for
labor
that
would
be
classified
as
"
technical"
time
for
the
bulk
of
the
effort
and
"
clerical"
time
for
a
small
part
of
the
effort.

­
There
is
no
start­
up
or
operating
and
maintenance
cost
associated
with
the
notification.

Table
6A/
B­
3:
Notification
for
Test
Marketing
Activity
(
A)

Hours/

year
Resp.
(
B)
Labor
Cost
(@

$
56/

hr)
per
resp.

per
year
(
C)
No.
of
Resp.
(
D)
Total
Hrs/
Year
(
A*
C)
(
E)
Total
Labor
Cost
per
resp.

per
year
(
B*
C)

a)
Compile
information
and
prepare
letter
2
$
112
1
2
$
112
Subtotal
2
$
112
1
2
$
112
Exhibit
6A/
B­
4:
Record­
Keeping
For
Substitutes
Acceptable
to
Narrowed
Used
Limits:
Annual
Respondent
Burden
and
Cost
(
4)

The
following
table
shows
estimates
of
respondent
burden
hours
and
costs
for
the
fourth
set
of
activities
listed
above
in
section
4(
b)(
ii).
In
making
these
estimates,
EPA
relied
on
its
experience
in
ten
years
of
implementing
the
SNAP
program
and
its
consultations
with
respondents,
and
made
the
following
assumptions:

­
The
number
of
record­
keeping
collections
is
250
per
year.
Each
collection
is
a
one­
time
occurrence.
Users
of
restricted
alternatives
may
periodically
reevaluate
alternatives
available.

­
Labor
cost
of
$
56.00
represents
an
average
hourly
rate
of
pay,
including
overhead
and
benefits,
for
a
private
company
for
labor
that
would
be
classified
as
"
technical"
time
for
the
bulk
of
the
effort
and
"
clerical"
time
for
a
small
part
of
the
effort.

­
There
is
no
start­
up
cost
associated
with
the
record­
keeping
collection.
20
20
Annual
operating
and
maintenance
cost
represents
an
estimate
of
cost
of
storage
space
for
keeping
the
records.

Table
6A/
B­
4:
Record­
Keeping
For
Substitutes
Acceptable
to
Narrowed
Used
Limits
(
A)
Hours/

Year
Resp.
(
B)
Labor
Cost
(@

$
56/

hr)
per
Resp.

per
Year
(
C)

Annualized
Startup
Cost
per
Resp.
(
D)
No.
of
Resp.
(
E)
Total
Hrs/
Year
(
All
Resp.)

(
A*
D)
(
F)

Total
Annualized
Cost
per
Year
(
All
Resp.)

(
C*
D)
(
G)
Total
Labor
Cost
per
Year
(
All
Resp.)

(
B*
D)
(
H)
Total
Cost
per
Year
(
All
Resp.)

(
F+
G)

a)
Assessment
of
other
acceptable
alternatives
25
$
1,400
$
0
250
6,250
$
0
$
350,000
$
350,000
b)
Compile
information
and
prepare
recordkeeping
2
$
112
$
1
250
500
$
250
$
28,000
$
28,250
Subtotal
27
$
1,512
$
1
250
6,750
$
250
$
378,000
$
378,250
Exhibit
6A/
B­
5:
Record­
Keeping
for
Small
Volume
Uses:
Annual
Respondent
Burden
and
Cost
(
5)

The
following
table
shows
estimates
of
respondent
burden
hours
and
costs
for
the
fifth
set
of
activities
listed
above
in
section
4(
b)(
ii).
In
making
these
estimates,
EPA
relied
on
its
experience
in
ten
years
of
implementing
the
SNAP
program
and
its
consultations
with
respondents,
and
made
the
following
assumptions:

­
The
number
of
record­
keeping
collections
is
10
per
year,
and
each
collection
is
a
one­
time
occurrence.

­
Labor
cost
of
$
56.00
represents
an
average
hourly
rate
of
pay,
including
overhead
and
benefits,
for
a
private
company
for
labor
that
would
be
classified
as
"
technical"
time
for
the
bulk
of
the
effort
and
"
clerical"
time
for
a
small
part
of
the
effort.

­
There
is
no
start­
up
cost
associated
with
the
record­
keeping
collection.

­
Annual
operating
and
maintenance
cost
represents
an
estimate
of
cost
of
storage
space
for
keeping
the
records.

Table
6A/
B­
5:
Record­
Keeping
for
Small
Volume
Uses:
Annual
Respondent
Burden
and
Cost
21
21
(
A)

Hours/

Year
Resp.
(
B)
Labor
Cost
(@

$
56/

hr)
per
Resp.

per
Year
(
C)

Annualized
Startup
Cost
per
Resp.
(
D)
No.
of
Resp.
(
E)
Total
Hrs/
Year
(
All
Resp.)

(
A*
D)
(
F)

Total
Annualized
Cost
per
Year
(
All
Resp.)

(
C*
D)
(
G)
Total
Labor
Cost
per
Year
(
All
Resp.)

(
B*
D)
(
H)
Total
Cost
per
Year
(
All
Resp.)

(
F+
G)

a)
Assessment
of
sector
sales
10
$
560
$
0
10
100
$
0
$
5,600
$
5,600
b)
Compile
information
and
prepare
recordkeeping
2
$
112
$
1
10
20
$
10
$
1,120
$
1,130
Subtotal
12
$
672
$
1
10
120
$
10
$
6,720
$
6,730
c)
Estimating
Agency
Burden
and
Costs
Exhibit
6C­
1:
Annual
Agency
Burden
and
Costs
The
following
table
shows
estimates
of
EPA
burden
hours
and
costs
(
including
the
cost
of
contractor
services)
for
the
activities
listed
in
section
5
above.
In
making
these
estimates,
EPA
made
the
following
assumptions:

­
The
number
of
occurrences
is
based
on
the
number
of
inquiries
and
submittals
by
respondents
estimated
above
in
tables
6A­
1
and
6A­
2.

­
The
number
of
EPA­
initiated
changes
in
SNAP
determinations
is
estimated
to
be
two
per
year.

­
The
number
of
hours
per
detailed
review
of
a
TSCA/
SNAP
Addendum
assumes
60
hours
per
form.

­
Labor
cost
is
based
on
the
annual
2004
salary
for
a
GS
12/
Step
2
employee
($
62,659),
which
is
divided
by
2,080
hours,
the
number
of
hours
in
a
federal
work
year
(
resulting
in
an
hourly
rate
of
$
22.44),
then
multiplied
by
1.6,
the
standard
government
benefits
multiplication
factor
(
resulting
in
a
final
hourly
rate
of
$
48.20.)

­
The
cost
of
contractor
services
in
the
two
circumstances
noted
in
the
chart
is
based
on
a
percentage
of
the
total
annual
cost
to
SPD
of
the
contractor's
charges
under
the
respective
contracts.
The
percentage
in
each
case
represents
an
estimate
of
the
time
spent
by
the
contractor
on
SNAP
issues
as
distinguished
from
other
SPD
issues
not
related
to
SNAP.
The
hourly
rate
noted
in
each
case
represents
the
average
rate
charged
per
hour
under
these
contracts.

Table
6C1:
EPA
burden
hours
and
costs
22
22
No.
of
Occurrences
No.
of
Hours
per
Occurrence
Total
no.
of
Hours
per
Year
Labor
Cost
(@

$
48.20/
hr)
per
Year
Cost
of
Contract
Services
per
Year
Total
Cost
per
Year
1)
Pre­
submittal
contact
w/
respondent
Send
forms/
guidance
to
potential
submitters
19
0.5
9.5
$
457.90
n/
a
$
458
Answer
questions
re
potential
submissions
19
3
57
$
2,747.40
n/
a
$
2,747
2)
Review
&
communication
re
submission
Assign
tracking
number
to
submission
15
0.5
7.5
$
361.50
n/
a
$
362
Review
submission,
send
receipt,
notify
if
add'l
info
required
15
2
30
$
1,446.00
n/
a
$
1,446
Review
CBI
requests
and
protect
as
appropriate
9
4
36
$
1,735.20
n/
a
$
1,735
Review
submission
in
detail
and
notify
submitter
of
decision
14
120
1680
$
80,976.00
n/
a
$
80,976
Contractor
assistance
in
reviewing
submissions
(@

$
78.25/
per
hr)
n/
a
n/
a
1422
n/
a
$
111,272
$
111,272
Review
TSCA/
SNAP
Addendum
in
detail
and
notify
submitter
of
decision
3
60
180
$
8,676.00
n/
a
$
8,676
Prepare
and
evaluate
EPAinitiated
changes
to
determinations
2
40
80
$
3,856.00
n/
a
$
3,856
3)
Administrative
operations
Maintain
system
of
tracking
submissions
on­
going
75
75
$
3,615.00
n/
a
$
3,615
Maintain
clearinghouse
to
help
users
on­
going
80
80
$
3,856.00
n/
a
$
3,856
Contractor
assistance
for
clearinghouse(@
$
55/
per
hr)
n/
a
n/
a
3701
n/
a
$
203,555
$
203,555
Prepare
FR
notices
and
rulemakings
re
changes
to
SNAP
lists
4
40
160
$
7,712.00
n/
a
$
7,712
Totals
varies
varies
7518
$
115,439.00
$
314,827
$
430,266
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs.
See
the
tables
in
section
6(
a)
and
(
b)
for
these
estimates.

Bottom
Line
Burden
Hours
and
Cost
Tables
23
23
Exhibit
6E­
1:
Information
Collection
Activity:
Total
Estimated
Respondent
Burden
and
Cost
Summary
Table
6E1:
Total
Estimated
Respondent
Burden
and
Cost
Summary
No.
of
Respondents
per
year
No.
of
Activities
per
year
Total
Hours
per
year
Total
Labor
Cost
per
year
Total
Annualized
Start­
up
Costs
Total
Annualized
O&
M
Costs
Total
Annualized
Costs
Total
Costs
SNAP
Information
Notice/

Petition
15
15
2,006
$
112,336
$
44,142
$
0
$
44,142
$
156,478
TSCA/
SNAP
Addendum
3
3
94
$
5,264
$
0
$
0
$
0
$
5,264
Notification
for
test
marketing
activity
1
1
2
$
112
$
0
$
0
$
0
$
112
Recordkeeping
for
Substitutes
Acceptable
Subject
to
Use
Limits
250
250
6,750
$
378,000
$
0
$
250
$
250
$
378,250
Recordkeeping
for
Small
Volume
Uses
10
10
120
$
6,720
$
0
$
10
$
10
$
6,730
Totals
280
280
8972
$
502,432
$
44,142
$
260
$
44,402
$
546,834
These
numbers
are
from
the
subtotals
of
tables
in
6(
a)
and
6(
b),
and
are
used
to
complete
items
13
and
14
in
Form
83­
1.

Exhibit
6E­
2:
Total
Estimated
Agency
Burden
and
Cost
Summary
Table
6E2:
Total
Estimated
Agency
Burden
and
Cost
Summary
No.
of
Respond
ents
No.
of
Activities
Total
Hours
per
Year
Total
Govt
Labor
Hours
per
Year
Total
Annual
Govt
Labor
Cost
(@$
48.20/
Hr)
Cost
of
Contract
Services
per
Year
Total
Cost
per
Year
Pre­
submittal
contact
with
respondents
19
19
66.5
66.5
$
3,205
$
­
$
3,205
Review
and
communicate
re
submission
15
15
3,436
2,014
$
97,051
$
111,272
$
208,322
Administrative
operations
varies
varies
4,016
315
$
15,183
$
203,555
$
218,738
Totals
varies
varies
7,518
2,395
$
115,439
$
314,827
$
430,266
f)
Reasons
for
Change
in
Burden
The
total
number
of
burden
hours
requested
for
this
information
collection
has
decreased
from
10,363
in
2000
to
8,972.
The
reason
for
this
change
in
burden
is
the
smaller
number
of
respondents
keeping
records
for
alternatives
that
are
subject
to
narrowed
use
limits
than
three
years
ago
because
of
the
development
of
new
substitutes.
For
example,
users
of
some
restricted
fire
suppressants
now
have
other
options
available
with
no
restriction,
and
thus,
no
paperwork
requirement.
In
addition,
we
have
noticed
a
reduction
in
the
number
of
TSCA/
SNAP
addendums
being
filed
over
the
past
three
years.
EPA
has
taken
steps
to
reduce
paperwork
burden
by
converting
the
forms
for
the
Internet
and
to
allow
electronic
filing.
The
24
24
recordkeeping
estimates
also
have
been
reduced.

g)
Burden
Statement
Exhibits
6A/
B­
1
through
6A/
B­
5
present
the
average
annual
respondent
burden
for
each
person
subject
to
SNAP
reporting
and
record­
keeping
requirements.
For
persons
filing
a
SNAP
Information
Notice
or
petition,
the
reporting
burden
is
estimated
to
average
150
hours
per
year.
For
persons
filing
a
TSCA/
SNAP
Addendum,
the
reporting
burden
is
estimated
to
average
46
hours
per
year.
For
persons
filing
a
notification
of
test
marketing
activity,
the
reporting
burden
is
estimated
to
average
2
hours
per
year.
For
persons
keeping
records
of
use
of
a
substitute
subject
to
narrowed
use
limits,
the
recordkeeping
burden
is
estimated
to
average
27
hours
per
year.
For
persons
keeping
records
of
a
small
volume
use,
the
recordkeeping
burden
is
estimated
to
average
12
hours
per
year.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OAR­
2004­
0077,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
and
Radiation
Docket
and
Information
Center
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OAR­
2004­
0077
and
OMB
Control
Number
2060­
0226
in
any
correspondence.

Part
B
of
the
Supporting
Statement
25
25
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.

APPENDICES
Appendix
A­
Draft
FR
notice
announcing
request
for
ICR
renewal
Please
see
this
draft
notice
as
a
separate
document
submitted
with
this
ICR
package.

Appendix
B­
Text
of
Section
612
of
the
Clean
Air
Act
as
amended
in1990
Please
visit:
http://
www.
epa.
gov/
oar/
caa/
caa612.
txt
Appendix
C­
Text
of
SNAP
Regulations,
40
CFR
part
82,
subpart
G
Please
visit:
http://
www.
epa.
gov/
ozone/
snap/
regs/
59fr13044.
html
(
Subpart
G
is
close
to
the
bottom)

Appendix
D­
SNAP
Information
Notice
(
EPA
Form
1265­
93)
(
Please
see
attached
form)

Appendix
E­
TSCA/
SNAP
Addendum
(
EPA
Form
1265­
94)
(
Please
see
attached
form)

Appendix
F­
Guidance
Document
for
the
SNAP
Program
Information
Notice
(
EPA
Form
1265­
93(
1)
(
Please
see
attached
form)

Please
note
the
OMB
Control
Number
expiration
date
listed
on
the
first
page
of
the
forms
in
Appendices
D
and
E
is
incorrect.
The
OMB
Control
Number
expiration
date
is
listed
as
October
31,
2007.
EPA
plans
to
re­
print
the
forms
with
the
correct
OMB
Control
Number
and
expiration
date
pending
approval
of
this
request
for
extension
of
the
ICR.
