DRAFT:
Appendix
G
Case
Studies
G­
1
Appendix
G
Case
Studies
INTRODUCTION
This
Appendix
presents
seven
hypothetical
case
studies
to
illustrate
how
to
report
information
on
Form
U.
EPA
designed
the
case
studies
to
cover
a
variety
of
reporting
scenarios.
These
case
studies
are
not
based
on
actual
data,
but
are
hypothetical
situations
generated
to
assist
submitters.
None
of
these
hypothetical
situations
are
binding.
EPA
will
assess
each
situation
in
a
case­
by­
case
basis.
Each
case
study
is
divided
into
the
following
sections:

°
Scenario
­
This
section
presents
a
sample
manufacturing
scenario
for
a
single
chemical
including
processing
and
use
information.
For
some
cases,
a
figure
is
included
to
clarify
the
manufacture,
process,
and
use
information;

°
EPA
Approach
­
This
section
discusses
the
rationale
for
each
of
the
three
criteria
presented
in
Chapter
2
and
identifies
which
parts
of
Form
U
must
be
completed;

°
Key
Points
­
This
section
highlights
important
information
which
is
helpful
for
completing
Form
U;

°
Completing
the
Form
­
This
section
discusses
the
responses
which
should
be
entered
on
Form
U
for
each
manufacturing
scenario.
This
section
explains
the
basis
and
rationale
for
the
reported
information;
and
°
Sample
Form
U
­
A
completed
Form
U
for
each
scenario
is
included.
Part
I
of
Form
U
was
completed
for
Case
Study
A
only.
Parts
II
and
III
of
Form
U
were
completed
for
all
cases,
as
necessary.

EPA
created
these
case
studies
to
cover
the
following
frequently
asked
questions:

1.
How
do
I
know
if
my
chemical
is
site
limited?
A
chemical
is
site
limited
if
it
is
manufactured
at
your
plant
site
and
you
do
not
distribute
the
substance
or
any
mixture
containing
the
substance
outside
the
plant
site
for
commercial
purposes.
See
Section
4.6.3
and
Case
Study
A
for
additional
guidance.
DRAFT:
Appendix
G
Case
Studies
G­
2
2.
What
if
my
site
only
imports
a
chemical?
Manufacturers
and
importers
are
required
to
report
under
the
IURA.
Importers
should
check
the
"
import"
box
in
Block
2.
B.
4.
Sections
2.2.1.2
and
4.6.4
and
Case
Study
B
of
this
document
provide
additional
guidance
for
reporting
this
information.

3.
What
if
my
site
exports
the
entire
volume
of
the
manufactured
chemical?
If
you
manufacture
an
IUR­
reportable
chemical
substance
solely
for
export,
you
are
required
to
report
and
otherwise
comply
with
all
IUR
requirements
for
Parts
I
and
II
of
Form
U.
Case
Study
C
illustrates
how
to
complete
Form
U
for
a
chemical
that
is
exported.

4.
What
if
my
site
both
manufactures
and
imports
the
same
chemical?
Sites
both
manufacturing
and
importing
a
chemical
substance
should
check
both
boxes
in
Block
2.
B.
4.
The
total
volume
of
chemical
(
both
manufactured
and
imported)
should
be
reported
in
Parts
II
and
III
of
Form
U.
See
Sections
2.2.1.2
and
4.6.4
and
Case
Study
G
for
additional
guidance.

5.
How
do
I
report
the
number
of
workers
at
my
site
and
at
downstream
sites?
Estimates
for
the
number
of
workers
reasonably
likely
to
be
exposed
are
required
for
both
the
manufacturing
and
industrial
processing
sections
of
Form
U.
Sections
4.6.7
and
4.7.1.6
of
this
document
describe
how
to
report
these
codes
and
give
examples
of
worker
activities
that
could
potentially
result
in
exposure.
All
case
studies
provide
examples
of
how
to
report
the
number
of
potentially
exposed
workers
along
with
the
basis
and
rationale
for
selecting
the
reported
code.

6.
How
do
I
report
the
maximum
concentration
of
my
chemical?
You
are
required
to
report
the
maximum
concentration,
by
weight,
of
your
chemical
at
the
time
it
sent
off­
site
from
each
site.
If
a
chemical
is
site­
limited,
report
the
maximum
concentration
before
it
is
reacted
on­
site
to
produce
a
different
chemical
substance.
Section
4.6.8
of
this
document
provides
guidance
for
reporting
this
information.
Case
Study
A
illustrates
how
to
complete
Block
2.
B.
8.

7.
What
if
I
manufacture
my
chemical
in
more
than
one
physical
form?
You
are
required
to
report
all
physical
forms
of
the
chemical
substance
at
the
time
it
leaves
your
site
and
the
percent
of
production
volume
for
each
form.
The
percentage
must
be
rounded
off
to
the
nearest
10%;
the
sum
of
the
percentages
for
each
form
must
not
add
up
to
more
than
100%.
Section
4.6.9
of
this
document
provides
guidance
for
reporting
the
physical
form
and
the
percent
production
volume
in
each
physical
form.
Case
Study
F
provides
a
scenario
and
illustrates
how
to
complete
Blocks
2.
B.
9
though
2.
B.
14.
DRAFT:
Appendix
G
Case
Studies
G­
3
8.
What
if
there
are
multiple
NAICS,
IFC,
and
"
Types
of
Process
or
Use"
code
combinations
for
my
chemical?
You
are
required
to
report
up
to
ten
unique
combinations
of
codes.
If
more
than
10
unique
combinations
apply,
you
need
only
report
the
ten
combinations
that
represent
the
largest
percentage
of
production
volume.
Section
4.7.1
and
Case
Studies
F
and
G
provide
additional
guidance.

9.
What
if
my
percent
production
volume
is
less
than
5%
for
a
process/
use,
NAICS,
and
IFC
code
combination
and
the
total
production
volume
is
less
than
300,000
pounds?
As
discussed
in
Section
4.7.1.4
of
this
document,
if
a
particular
combination
accounts
for
less
than
5%
of
the
percent
production
volume
and
is
less
than
300,000
pounds,
then
you
may
report
the
percent
production
volume
as
0%.
Case
Study
G
illustrates
how
to
report
this
information.

10.
What
if
my
percent
production
volume
is
less
than
5%
for
a
process/
use,
NAICS,
and
IFC
code
combination
but
the
total
production
volume
is
greater
than
300,000
pounds?
As
discussed
in
Section
4.7.1.4
of
this
document,
if
a
particular
combination
accounts
for
less
than
5%
of
the
percent
production
volume
and
is
300,000
pounds
or
greater,
then
you
must
report
the
percent
production
volume
to
the
nearest
1%
of
production
volume.
Case
Study
G
illustrates
how
to
report
this
information.

11.
What
if
the
values
I
report
for
percent
production
volume
for
each
end
use
add
up
to
more
than
100%?
As
discussed
in
Section
4.7.1.4,
the
total
percent
production
volumes
may
add
up
to
more
than
100%
since
you
are
reporting
on
the
distribution
of
the
chemical
to
downstream
sites.
The
values
may
add
up
to
less
than
100%
if
the
information
on
production
volume
is
not
readily
obtainable.
Case
Studies
F
and
G
illustrate
how
to
report
this
information.

12.
What
if
my
chemical
has
multiple
commercial
and
consumer
uses?
You
must
report
up
to
10
commercial
and
consumer
product
categories
for
which
your
chemical
is
used.
Section
4.7.2.1
and
Case
Studies
F
and
G
provide
additional
guidance
for
completing
Column
"
a"
in
Part
III,
Section
B.

13.
What
if
my
substance
is
used
in
children's
products?
You
must
determine,
within
each
commercial
and
consumer
product
category
reported,
whether
any
amount
of
each
reportable
chemical
substance
is
present
in
consumer
products
intended
for
use
by
children
age
14
or
younger.
Section
4.7.2.2
of
this
document
provides
guidance
for
completing
Column
"
b"
in
Part
III,
Section
B
of
Form
U.
Case
Study
F
presents
a
scenario
to
illustrate
how
to
complete
this
part
of
Form
U.
DRAFT:
Appendix
G
Case
Studies
G­
4
14.
How
do
I
report
chemicals
that
are
intermediates?
Definitions
for
"
intermediate"
and
"
non­
isolated
intermediate"
are
provided
in
Appendix
B.
Section
2.2.3
of
this
document
states
that
impurities,
byproducts,
and
non­
isolated
intermediates
are
exempt
from
reporting.
However,
reporting
the
manufacture
of
an
isolated
intermediate
is
required.
Case
Study
A
provides
a
possible
scenario
for
reporting
an
isolated
intermediate.
Additional
examples
are
available
in
section
2.2.3
of
this
document.

15.
How
do
I
report
hydrates
of
a
chemical
substance?
You
are
required
to
complete
Form
U
for
the
corresponding
anhydrous
form.
Section
2.1.1.2
of
this
document
specifically
addresses
how
to
report
a
hydrate
of
a
chemical
substance
and
provides
an
example.
Furthermore,
Case
Study
D
presents
another
example
of
how
to
report
a
hydrate
of
a
chemical
substance.

16.
How
do
I
report
inorganic
chemical
substances?
Inorganic
chemical
substances
are
partially
exempt
from
reporting
for
the
2006
reporting
period
and
will
not
be
exempt
for
subsequent
reporting
periods.
For
the
2006
reporting
period,
you
only
need
to
complete
Parts
I
and
II
of
Form
U.
Section
2.3.2.3
of
this
document
provides
additional
guidance
on
this
subject.
Case
Study
D
illustrates
how
to
report
an
inorganic
chemical
substance
for
the
2006
reporting
period.

17.
What
if
my
chemical
is
listed
on
the
"
specific
exempted
chemical
substances"
list?
EPA
generates
a
list
of
chemicals
for
which
manufacturers
are
exempt
from
reporting
Part
III
of
Form
U.
Additional
information
about
these
chemicals
can
be
found
in
section
2.3.2.2
of
this
document.
Case
Study
E
illustrates
how
to
report
a
chemical
that
is
listed
as
a
"
partially
exempt
chemical
substance."
DRAFT:
Appendix
G
Case
Studies
G­
5
CASE
STUDY
A
This
example
illustrates
how
to
report:


Site­
limited
chemicals;
and

Intermediates.

Scenario:
Company
A
manufactures
1,100,000
lbs/
yr
of
an
intermediate
called
Monomer
#
1
(
Accession
#
99999)
at
the
Big
Lot
site.
Monomer
#
1
is
used
for
the
manufacture
of
a
polyamide
and
is
sitelimited
meaning
it
is
only
used
at
the
Big
Lot
site.
Monomer
#
1
is
produced
as
part
of
a
liquid
solution
at
89.6%
concentration
and
transferred
to
an
on­
site
storage
tank
for
future
use.
Monomer
#
1
is
subsequently
consumed
during
the
reaction
to
produce
the
polyamide.
Twelve
workers
are
potentially
exposed
during
the
manufacture
of
Monomer#
1
during
sampling
and
equipment
cleaning.
Two
additional
workers
transfer
Monomer
#
1
from
the
storage
tank
to
the
reactor
that
produces
the
polyamide.
Four
administrative
workers
are
on­
site
but
not
directly
involved
with
the
manufacture
of
any
chemicals.

John
Doe
is
the
plant
manager
for
the
Company
A's
Big
Lot
site.
The
mailing
address
for
this
site
is
100
John
Doe
Highway,
Richmond,
VA
23222.
The
Dun
&
Bradstreet
number
for
the
site
is
099999999.
The
mailing
address
for
Company
A's
headquarters
is
100
First
Street,
Suite
100,
New
York,
NY
10001.
The
Dun
&
Bradstreet
number
for
this
office
is
999999999.

EPA
Approach:
Criterion
I:
Monomer
#
1
is
on
the
TSCA
Inventory
and
in
not
subject
to
a
special
regulatory
action
under
TSCA.
Monomer
#
1
is
used
to
produce
a
polyamide.
The
polyamide
is
excluded
from
reporting
under
the
polymer
exemption,
but
Monomer
#
1
does
not
qualify
for
this
exemption.

Criterion
II:
Company
A
manufactures
25,000
pounds
or
more
of
Monomer
#
1
and
does
not
qualify
as
a
small
manufacturer.
Monomer
#
1
is
considered
to
be
site­
limited
because
it
is
not
imported
to
the
site
and
does
not
leave
the
site.
Monomer
#
1
is
defined
as
isolated
because
the
transfer
operation
from
the
reactor
to
the
storage
tank
isolates
Monomer
#
1;
therefore,
Monomer
#
1
does
not
qualify
for
the
nonisolated
intermediate
exemption.

Criterion
III:
Company
A
manufactures
300,000
pounds
for
more
of
Monomer
#
1
and
Monomer
#
1
does
not
qualify
for
any
partial
exemptions.
Therefore,
Company
A
must
complete
Parts
I,
II,
and
III.

Key
Points:


Company
A
estimates
12
exposed
workers
from
sampling
and
equipment
cleaning
DRAFT:
Appendix
G
Case
Studies
G­
6
during
manufacture
of
Monomer
#
1.
The
administrative
workers
are
not
included
in
this
total
because
they
are
not
likely
to
be
exposed
to
this
chemical.
The
2
workers
responsible
for
transferring
Monomer
#
1
from
the
storage
tank
to
the
reactor
are
reported
in
Part
III.
DRAFT:
Appendix
G
Case
Studies
G­
7
Completing
the
Form:
Part
II.
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
2.
A.
1
Chemical
ID
Number
99999
Accession
number.

2.
A.
2
ID
Code
A
IUR
code
for
accession
number.

2.
A.
3
Chemical
Name
Monomer
#
1
Chemical
Abstracts
Index/
Preferred
name.
Note:
if
this
were
a
real
chemical,
the
chemical
name
should
be
reported.

2.
B.
3
Site
limited
Y
Monomer
#
1
is
site
limited
because
it
is
not
imported
and
it
never
leaves
the
site
because
it
is
destroyed
during
the
reaction
to
produce
polyamide.

2.
B.
4
Activity
Manufacture
Monomer
#
1
is
manufactured
by
Company
A
and
not
imported.

2.
B.
5
Production
Volume
(
lbs)
1,100,000
Amount
manufactured.

2.
B.
7
Number
of
Workers
W2
At
least
10
but
fewer
than
25.
Company
A
estimates
12
exposed
workers
from
sampling
and
equipment
cleaning
during
manufacture
of
Monomer
#
1.
The
administrative
workers
are
not
included
in
this
total
because
they
are
not
likely
to
be
exposed
to
this
chemical.

2.
B.
8
Maximum
Concentration
M4
From
61%
to
90%
by
weight.
The
maximum
concentration
is
89.6%.

2.
B.
14
Physical
Form
Percent
of
PV
a.
Liquid;
b.
100
100%
of
the
product
is
produced
as
a
liquid.

Part
III
­
Section
I.
Industrial
Processing
and
Use
Information
Block
Block
Title
Report
Basis/
Rationale
3.
A.
1
Type
of
Process
or
Use
PC
Processing
as
a
reactant.

NAICS
32619
Other
plastics
product
manufacturing.

IFC
U16
Intermediate.

Percent
PV
100
100%
of
the
PV
is
used
as
an
intermediate.

Number
of
Sites
S1
Fewer
than
10.
Only
one
site
uses
this
chemical.

Number
of
Workers
W1
Fewer
than
10.
Company
A
estimates
2
workers
are
exposed
during
transfer
operations
during
the
reaction
that
produces
polyamide.

Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
DRAFT:
Appendix
G
Case
Studies
G­
8
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.
The
intermediate
is
destroyed
during
the
production
of
polyamide
and
therefore
never
leaves
this
site
for
further
processing
or
use.
DRAFT:
Appendix
A
Forms
G­
9
FOR
EPA
USE
ONLY
Report
Number
Mark
"
X"
here
if
this
is
a
revision
to
the
previous
report
Previous
Report
Number
Form
U
­
Case
Study
A
PAGE
1
of
_
2_
(
IMPORTANT:
Type
only,
read
instructions
before
completing
form)

U.
S.
Environmental
Protection
Agency
Washington,
DC
20460
Partial
Updating
of
TSCA
Inventory
Data
Base
Production
and
Site
Report
(
Section
8(
a)
Toxic
Substances
Control
Act,
15
U.
S.
C.
2607)

PART
I.
SITE
IDENTIFICATION
INFORMATION
SECTION
A.
CERTIFICATION
Certification
Statement:
I
hereby
certify
that
I
have
reviewed
the
attached
documents
and
that,
to
the
best
of
my
knowledge
and
belief,
the
submitted
information
is
true
and
complete
and
that
the
amounts
and
values
in
this
report
are
accurate
based
on
reasonable
estimates
using
data
available
to
the
preparers
of
this
report.

1.
A.
1
Signature
1.
A.
2
Date
signed
1.
A.
3
Name
John
Doe
1.
A.
4
Official
Title
Plant
Manager
SECTION
B.
PARENT
COMPANY
AND
TECHNICAL
CONTACT
INFORMATION
1.
B.
1
Parent
Company
Name
Company
A,
Inc.

1.
B.
2
Parent
Company
Dun
&
Bradstreet
Number
999999999
1.
B.
3
Technical
Contact
Name
John
Doe
1.
B.
4
Technical
Contact
Telephone
(
w/
Area
Code)
555­
555­
5555
1.
B.
5
Technical
Contact
Email
Address
john.
doe@
companya.
com
Technical
Contact
Mailing
Address
1.
B.
6
Technical
Contact
Address
(
Line1)
100
First
Street
1.
B.
7
Technical
Contact
Address
(
Line
2)
Suite
100
1.
B.
8
City
New
York
1.
B.
9
State
NY
1.
B.
10
Zip
Code
10001
SECTION
C.
PLANT
SITE
IDENTIFICATION
1.
C.
1
Plant
Site
Name
Company
A,
Inc.

1.
C.
2
Plant
Site
Dun
&
Bradstreet
Number
099999999
EPA
Facility
Identification
Number
(
for
Agency
Use
Only)
LEAVE
BLANK
1.
C.
3
Street
Address
(
Line
1)
100
Joe
Doe
Highway
1.
C.
4
Street
Address
(
Line
2)

1.
C.
5
City
Richmond
1.
C.
6
County/
Parish
Chesterfield
1.
C.
7
State
VA
1.
C.
8
Zip
Code
23222
FORM
U
2006
DRAFT:
Appendix
A
Forms
G­
10
EPA
Form
Number
<
XXXX­
X>
(
Rev
8/
22/
03)
­
Previous
editions
are
obsolete
Form
Approved
OMG
Number
:
XX/
X­
XXXX
DRAFT:
Appendix
A
Forms
G­
11
Form
U
­
Case
Study
A
(
continued)
Page
___
of
___

PART
II.
MANUFACTURING
INFORMATION
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
99999
2.
A.
2
ID
Code
A
2.
A.
3
Chemical
Name
Monomer
#
1
SECTION
B.
MANUFACTURING
INFORMATION
2.
B.
1
Company
Information
CBI
2.
B.
2
Plant
Site
Identity*
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
Check
All
That
Apply
CBI
Percent
CBI
2.
B.
3
Site
Limited
(
Y/
N)
Y
CBI
2.
B.
9
Dry
Powder
2.
B.
4
Activity
(
Check
all
that
apply)

Manufacture
G
Import
CBI
2.
B.
10
Pellets
or
Large
Crystals
2.
B.
5
Production
Volume
(
LB)
1,100,000
CBI
2.
B.
11
Water
or
Solvent
Wet
Solid
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
CBI
2.
B.
12
Other
Solid
2.
B.
7
Number
of
Workers
(
code)
W2
CBI
2.
B.
13
Gas
or
Vapor
2.
B.
8
Maximum
Concentration
(
code)
M4
CBI
2.
B.
14
Liquid

100
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.

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
PC
32619
U16
100
S1
W1
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
*
Substantiation
required
for
CBI
claims
on
chemical
identity
and
plant
site
identity.
FOR
EPA
USE
ONLY
DRAFT:
Appendix
G
Case
Studies
G­
12
CASE
STUDY
B
This
example
illustrates
how
to
report:


A
chemical
substance
that
is
imported
only;


TSCA­
exempt
uses
(
cosmetic
lotions).

Scenario:
Company
B
imports
400,000
pounds
of
2­
propanol
(
IPA)
(
CAS#
67­
63­
0)
to
its
only
site
during
a
reporting
year
as
part
of
a
liquid
solution
at
95%
concentration.
Company
B
employs
5
workers
per
shift
for
3
shifts
(
15
total
workers)
to
incorporate
the
IPA
into
mixtures
and
formulations
ranging
from
10%
to
50%
in
concentration.
Half
the
production
volume
(
200,000
pounds)
is
incorporated
into
industrial
solvents
and
cleaners
and
is
sold
to
hundreds
of
sites.
Company
B
estimates
3
workers
are
exposed
at
each
of
these
sites.
100,000
pounds
of
IPA
is
used
in
commercially­
used
soaps
and
cleaners.
The
remaining
100,000
pounds
is
incorporated
into
cosmetic
lotions
for
consumer
use.
The
soap
and
lotion
products
are
used
at
thousands
of
sites.

EPA
Approach:
Criterion
I:
IPA
is
on
the
TSCA
Inventory
and
is
not
a
substance
excluded
from
reporting.

Criterion
II:
Company
B
imported
25,000
pounds
or
more
of
IPA
and
does
not
qualify
as
a
small
manufacturer.
Company
B
does
not
qualify
for
any
additional
reporting
exemptions
for
IPA.

Criterion
III:
Company
B
imported
300,000
pounds
or
more
of
IPA
and
the
IPA
is
not
listed
as
a
partial
exemption;
therefore,
Company
B
must
report
Parts
I,
II,
and
III
for
IPA.

Key
Points:
Since
IPA
is
imported,
no
exposed
workers
are
reported
for
the
manufacturing
section
in
Part
II.
Use
of
cosmetic
lotions
is
exempt
from
TSCA
reporting
because
it
is
regulated
by
the
Food
and
Drug
Administration
(
FDA),
but
the
manufacture
and
processing
of
IPA
into
these
products
is
not
exempt.
Therefore,
the
consumer
use
of
cosmetic
lotions
is
not
required
in
Part
III
of
Form
U
and
does
not
need
to
be
reported.
DRAFT:
Appendix
G
Case
Studies
G­
13
Company
B
incorporates
the
IPA
into
liquid
formulations
and
solutions
at
concentrations
of
10
­
50%
(
Block
3.
A.
1)
400,000
lbs.
of
IPA
is
imported
to
Company
B
at
95%
concentrations
200,000
lbs.
IPA
sold
as
industrial
solvents
and
cleaners
(
Block
3.
A.
2)

100,000
lbs.
IPA
sold
as
soaps
and
cleaners
(
Block
3.
B.
1)
100,000
lbs.
IPA
sold
as
cosmetic
lotions
(
Exempt
because
regulated
by
FDA)
INDUSTRIAL
PROCESSING
AND
USE
COMMERCIAL
AND
CONSUMER
END
USE
CASE
STUDY
B
­
Flow
Diagram
DRAFT:
Appendix
G
Case
Studies
G­
14
Completing
the
Form:
Part
II.
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
2.
A.
1
Chemical
ID
Number
67­
63­
0
CAS
Number.

2.
A.
2
ID
Code
C
Code
for
CAS
Number.

2.
A.
3
Chemical
Name
2­
propanol
Chemical
Abstracts
Index/
Preferred
name.

2.
B.
3
Site
limited
N
Imported
chemicals
cannot
be
claimed
as
site
limited
and
IPA
leaves
the
site
of
manufacture.

2.
B.
4
Activity
Import
IPA
is
imported
only
(
not
domestically
manufactured).

2.
B.
5
Production
Volume
(
lbs)
400,000
Amount
of
IPA
imported.

2.
B.
7
Number
of
Workers
W1
Fewer
than
10.
Since
the
product
is
imported,
no
workers
are
exposed
during
the
manufacture
of
IPA.

2.
B.
8
Maximum
Concentration
M3
From
31%
to
60%
by
weight.
The
maximum
concentration
leaving
the
site
is
50%.
The
imported
concentration
of
95%
is
not
pertinent
to
this
assessment.

2.
B.
14
Physical
Form
Percent
of
PV
a.
Liquid;
b.
100
100%
of
the
product
is
produced
as
liquid
formulations
and
mixtures.

Part
III
­
Section
I.
Industrial
Processing
and
Use
Information
Block
Block
Title
Report
Basis/
Rationale
3.
A.
1
Type
of
Process
or
Use
PF
Incorporation
into
formulations
and
mixtures.

NAICS
32519
Other
basic
organic
chemical
manufacturing.

IFC
U28
Solvent
(
which
becomes
part
of
product
formulation
or
mixture).

Percent
PV
100
All
of
the
production
volume
is
formulated
into
a
mixture.

Number
of
Sites
S1
Less
than
10
sites.
Company
B
imports
IPA
to
a
single
site.

Number
of
Workers
W2
At
least
10
but
fewer
than
25.
Company
B
employs
15
workers
to
formulate
the
IPA.
DRAFT:
Appendix
G
Case
Studies
Block
Block
Title
Report
Basis/
Rationale
G­
15
3.
A.
2
Type
of
Process
or
Use
U
Use
as
an
industrial
solvent
and
cleaner.

NAICS
32519
Other
basic
organic
chemical
manufacturing.

IFC
U27
Solvents
for
cleaning
and
degreasing.

Percent
PV
50
Half
of
the
production
volume
(
200,000
lbs.)
is
used
in
industrial
solvents.

Number
of
Sites
S5
From
251
to
1,000.
Company
B
estimates
hundreds
of
sites.

Number
of
Workers
W7
At
least
1,000
but
fewer
than
10,000.
Company
B
estimates
3
exposed
workers
for
each
industrial
processing
site
during
transfer
and
use
operations.
3
workers
per
site
x
1,000
sites
=
3,000
workers.

Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Related
Data
Block
Block
Title
Report
Basis/
Rationale
3.
B.
1
Commercial
and
Consumer
Product
Category
C16
Soaps
and
detergents.

Use
in
Children's
Product
Y
Some
soaps
and
detergents
may
be
used
by
children.

Percent
PV
30
Of
the
400,000
lbs
imported,
100,000
lbs
(
25%)
is
used
in
soaps
and
detergents.
Round
up
to
30%
based
on
standard
rounding
convention.

Maximum
Concentration
M3
From
31%
to
60%
by
weight.
The
maximum
concentration
used
in
formulations
is
50%.
DRAFT:
Appendix
G
Case
Studies
G­
16
Form
U
­
CASE
STUDY
B
Page
___
of
___

PART
II.
MANUFACTURING
INFORMATION
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
67­
63­
0
2.
A.
2
ID
Code
C
2.
A.
3
Chemical
Name
2­
Propanol
SECTION
B.
MANUFACTURING
INFORMATION
2.
B.
1
Company
Information
CBI
2.
B.
2
Plant
Site
Identity*
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
Check
All
That
Apply
CBI
Percent
CBI
2.
B.
3
Site
Limited
(
Y/
N)
N
CBI
2.
B.
9
Dry
Powder
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture

Import
CBI
2.
B.
10
Pellets
or
Large
Crystals
2.
B.
5
Production
Volume
(
LB)
400,000
CBI
2.
B.
11
Water
or
Solvent
Wet
Solid
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
CBI
2.
B.
12
Other
Solid
2.
B.
7
Number
of
Workers
(
code)
W1
CBI
2.
B.
13
Gas
or
Vapor
2.
B.
8
Maximum
Concentration
(
code)
M3
CBI
2.
B.
14
Liquid

100
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.

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
PF
32519
U28
100
S1
W2
3.
A.
2
U
32519
U27
50
S5
W7
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
C16
Y
30
M3
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
*
Substantiation
required
for
CBI
claims
on
chemical
identity
and
plant
site
identity.
FOR
EPA
USE
ONLY
DRAFT:
Appendix
G
Case
Studies
G­
17
CASE
STUDY
C
This
example
illustrates
how
to
report:

$
A
chemical
substance
that
is
exported
only
(
production
volume
is
300,000
lbs/
yr
or
more).

Scenario:
Company
C
manufactures
400,000
pounds
of
liquid
cyclohexane
(
CAS#
110­
82­
7)
in
solution
at
90%
concentration
during
a
reporting
year.
The
manufacturer
exports
the
entire
production
volume
outside
the
United
States.
Since
cyclohexane
is
extremely
volatile,
all
manufacturing
operations
occur
in
closed
systems
with
engineering
controls
to
minimize
releases
and
worker
exposures.
However,
Company
C
estimates
4
workers
will
perform
transfer
and
drumming
operations
and
4
workers
will
perform
maintenance
and
equipment
cleaning
activities.

EPA
Approach:
Criterion
I:
Cyclohexane
is
on
the
TSCA
Inventory
and
is
not
excluded
from
reporting.

Criterion
II:
Company
C
manufactures
25,000
pounds
or
more
of
cyclohexane
and
does
not
qualify
as
a
small
manufacturer.
Company
C
does
not
qualify
for
any
additional
reporting
exemptions.

Criterion
III:
Company
C
manufactures
300,000
pounds
or
more
of
cyclohexane
and
cyclohexane
does
not
qualify
for
any
partial
exemptions.
Therefore,
Company
C
must
complete
Parts
I,
II,
and
III
of
Form
U
for
cyclohexane.

Key
Points:


Company
C
should
report
8
workers
potentially
exposed
during
manufacturing
operations
despite
the
use
of
engineering
controls
and
personal
protection
equipment.


Reporting
the
industrial,
commercial,
and
processing
use
information
of
this
chemical
is
not
required
for
activities
outside
the
United
States.

Completing
the
Form:
Part
II.
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
2.
A.
1
Chemical
ID
Number
110­
82­
7
CAS
Number
2.
A.
2
ID
Code
C
Code
for
CAS
Number
2.
A.
3
Chemical
Name
Cyclohexane
Chemical
Abstracts
Index/
Preferred
name
2.
B.
3
Site
limited
N
Cyclohexane
is
distributed
off­
site
for
commercial
purposes.

2.
B.
4
Activity
Manufacture
Cyclohexane
is
manufactured
and
not
imported.
DRAFT:
Appendix
G
Case
Studies
Block
Block
Title
Report
Basis/
Rationale
G­
18
2.
B.
5
Production
Volume
(
lbs)
400,000
Amount
manufactured.

2.
B.
7
Number
of
Workers
W1
Fewer
than
10.
Company
C
estimates
8
workers
exposed
during
the
manufacturing
process.

2.
B.
8
Maximum
Concentration
M4
From
61%
to
90%
by
weight.
The
maximum
concentration
leaving
the
site
is
90%.

2.
B.
14
Physical
Form
Percent
of
PV
a.
Liquid;
b.
100
100%
of
the
product
is
produced
as
liquid
formulations
and
mixtures.

Part
III
­
Section
I.
Industrial
Processing
and
Use
Information
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.

Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.
DRAFT:
Appendix
G
Case
Studies
G­
19
Form
U
­
CASE
STUDY
C
Page
___
of
___

PART
II.
MANUFACTURING
INFORMATION
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
110­
82­
7
2.
A.
2
ID
Code
C
2.
A.
3
Chemical
Name
Cyclohexane
SECTION
B.
MANUFACTURING
INFORMATION
2.
B.
1
Company
Information
CBI
2.
B.
2
Plant
Site
Identity*
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
Check
All
That
Apply
CBI
Percent
CBI
2.
B.
3
Site
Limited
(
Y/
N)
N
CBI
2.
B.
9
Dry
Powder
2.
B.
4
Activity
(
Check
all
that
apply)

Manufacture
G
Import
CBI
2.
B.
10
Pellets
or
Large
Crystals
2.
B.
5
Production
Volume
(
LB)
400,000
CBI
2.
B.
11
Water
or
Solvent
Wet
Solid
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
CBI
2.
B.
12
Other
Solid
2.
B.
7
Number
of
Workers
(
code)
W1
CBI
2.
B.
13
Gas
or
Vapor
2.
B.
8
Maximum
Concentration
(
code)
M4
CBI
2.
B.
14
Liquid

100
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.

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
*
Substantiation
required
for
CBI
claims
on
chemical
identity
and
plant
site
identity.
FOR
EPA
USE
ONLY
DRAFT:
Appendix
G
Case
Studies
G­
20
CASE
STUDY
D
This
example
illustrates
how
to
report:


A
hydrate
of
a
chemical
substance;


Inorganic
chemical
substances
(
partial
exemption
for
2006
reporting
year);
and

TSCA­
exempt
use
(
as
a
pesticide).

Scenario:
Company
D
produces
800,000
lbs/
yr
of
copper
sulfate
pentahydrate
(
CuSO
4
·
5H
2
O)
crystals
at
93%
purity.
70%
of
the
production
volume
is
used
for
metal
electroplating
and
30%
is
used
as
pesticides.
This
site
employs
60
workers
in
the
manufacturing
area.

EPA
Approach:
Criterion
I:
Copper
sulfate
pentahydrate
is
a
hydrate
and
not
listed
on
the
TSCA
Inventory.
However,
copper
sulfate
is
on
the
TSCA
Inventory
and
is
required
to
be
reported
under
IUR.
Copper
sulfate
does
not
qualify
as
a
substance
excluded
from
reporting.

Criterion
II:
Company
D
manufacturers
25,000
pounds
or
more
of
copper
sulfate
(
not
copper
sulfate
pentahydrate)
and
does
not
qualify
as
a
small
manufacturer.
Company
D
does
not
qualify
for
any
additional
reporting
exemptions.

Criterion
III:
Company
D
manufactures
300,000
pounds
or
more
of
copper
sulfate
(
not
copper
sulfate
pentahydrate).
Copper
sulfate
is
an
inorganic
substance
and
is
partially
exempted
for
the
2006
reporting
period.
Therefore,
Company
D
must
complete
Parts
I
and
II
of
Form
U
for
copper
sulfate.

Key
Points:


This
material
is
a
hydrate,
therefore
only
the
weight
fraction
of
the
non­
hydrated
form
of
copper
sulfate
(
CuSO
4)
(
CAS#
7758­
98­
7)
should
be
reported.
To
determine
the
weight
fraction,
multiply
the
production
volume
of
the
copper
sulfate
pentahydrate
by
the
molecular
weight
of
copper
sulfate
(
CuSO
4)
divided
by
the
molecular
weight
of
the
copper
sulfate
pentrahydrate
(
CuSO
4
·
5H
2
O).
The
molecular
weight
of
CuSO
4
is
159.6
lbs/
lb
·
mole
and
the
molecular
weight
of
CuSO
4
·
5H
2
O
is
249.7
lbs/
lb
·
mole.
Calculation:

800,000
lbs
CuSO
4
5H
2
O
yr
159.6
lbs
/
lb
mole
CuSO
4
249.7
lbs
/
lb
mole
CuSO
4
5H
2
O
511,386
lbs
CuSO
4
/
yr
 
×
 

 
 
=


The
manufacture
and
use
of
pesticides
is
regulated
by
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
and
is
exempt
from
TSCA­
regulations;
therefore,
the
portion
of
the
production
volume
used
in
pesticides
does
not
need
to
DRAFT:
Appendix
G
Case
Studies
G­
21
Company
D
produces
800,000
lbs.
of
copper
sulfate
pentahydrate
crystals
(
511,386
lbs.
CuSO4)
at
93%
purity
560,000
lbs.
of
copper
sulfate
pentahydrate
(
357,970
lbs.
CuSO4)
is
used
for
metal
electroplating
INDUSTRIAL
PROCESSING
AND
USE
240,000
lbs.
of
copper
sulfate
pentahydrate
(
153,416
lbs.
CuSO
4)
is
used
as
a
pesticide
(
Exempt
because
regulated
by
FIFRA)
be
reported
for
Part
III.


Copper
sulfate
is
an
inorganic
substance.
For
the
2006
reporting
year,
inorganic
substances
are
partially
exempt,
so
only
Parts
I
and
II
need
to
be
reported.


Company
D
should
report
60
workers
potentially
exposed
because
they
work
in
the
manufacturing
area.

CASE
STUDY
D
­
Flow
Diagram
DRAFT:
Appendix
G
Case
Studies
G­
22
Completing
the
Form:
Part
II.
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
2.
A.
1
Chemical
ID
Number
7758­
98­
7
CAS
Number
2.
A.
2
ID
Code
C
Code
for
CAS
Number
2.
A.
3
Chemical
Name
Copper
(
II)
sulfate
Chemical
Abstracts
Index/
Preferred
name
2.
B.
3
Site
limited
N
Copper
sulfate
is
distributed
off­
site
for
commercial
purposes.

2.
B.
4
Activity
Manufacture
Copper
sulfate
is
manufactured
and
not
imported.

2.
B.
5
Production
Volume
(
lbs)
357,970
Calculated
amount
of
anhydrous
copper
sulfate
produced
for
non­
pesticidal
uses.
511,386
lbs
x
70%
PV
=
357,970
lbs.

2.
B.
7
Number
of
Workers
W4
At
least
50
but
fewer
than
100.
Company
D
estimates
60
workers
exposed
during
the
manufacturing
process,
mostly
due
to
cleaning,
sampling,
handling,
and
transfer
operations.

2.
B.
8
Maximum
Concentration
M5
Greater
than
90%
by
weight.
The
maximum
concentration
leaving
the
site
is
93%.

2.
B.
10
Physical
Form
Percent
of
PV
a.
Large
crystals;
b.
100
100%
of
the
product
is
produced
as
large
crystals.

Part
III
­
Section
I.
Industrial
Processing
and
Use
Information
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.

Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.
DRAFT:
Appendix
G
Case
Studies
G­
23
Form
U
­
CASE
STUDY
D
Page
___
of
___

PART
II.
MANUFACTURING
INFORMATION
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
7758­
98­
7
2.
A.
2
ID
Code
C
2.
A.
3
Chemical
Name
Copper
(
II)
Sulfate
SECTION
B.
MANUFACTURING
INFORMATION
2.
B.
1
Company
Information
CBI
2.
B.
2
Plant
Site
Identity*
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
Check
All
That
Apply
CBI
Percent
CBI
2.
B.
3
Site
Limited
(
Y/
N)
N
CBI
2.
B.
9
Dry
Powder
2.
B.
4
Activity
(
Check
all
that
apply)

Manufacture
G
Import
CBI
2.
B.
10
Pellets
or
Large
Crystals

100
2.
B.
5
Production
Volume
(
LB)
357,970
CBI
2.
B.
11
Water
or
Solvent
Wet
Solid
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
CBI
2.
B.
12
Other
Solid
2.
B.
7
Number
of
Workers
(
code)
W4
CBI
2.
B.
13
Gas
or
Vapor
2.
B.
8
Maximum
Concentration
(
code)
M5
CBI
2.
B.
14
Liquid
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.

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
*
Substantiation
required
for
CBI
claims
on
chemical
identity
and
plant
site
identity.
FOR
EPA
USE
ONLY
DRAFT:
Appendix
G
Case
Studies
G­
24
CASE
STUDY
E
This
example
illustrates
how
to
report:


A
chemical
listed
on
the
"
partially
exempt
chemical
substances"
list.

Scenario:
Company
E
produces
500,000
lbs/
yr
of
a
benzene,
mono­
C14­
16­
alkyl
derivs.
(
CAS
#
129813­
60­
1)
liquid
solution
at
concentrations
up
to
95%.
Company
E
distributes
the
entire
amount
produced
(
500,000
lbs)
to
twelve
companies
for
formulation
into
laundry
detergents.
These
detergents
are
intended
for
use
by
approximately
200
commercial
companies.

Company
E
has
two
production
lines
on
this
site
that
produce
benzene,
mono­
C14­
16­
alkyl
derivs.
Each
line
employs
20
workers
(
covering
3
shifts)
to
operate
and
maintain
equipment
during
manufacturing
operations,
including
sampling,
handling,
and
equipment
cleaning.

EPA
Approach:
Criterion
I:
Benzene,
mono­
C14­
16­
alkyl
derivs.
is
listed
on
the
TSCA
Inventory
and
is
not
a
substance
excluded
from
reporting.

Criterion
II:
Company
E
manufactures
25,000
pounds
or
more
of
benzene,
mono­
C14­
16­
alkyl
derivs.
and
does
not
qualify
as
a
small
manufacturer.
Company
E
does
not
qualify
for
any
additional
reporting
exemptions.

Criterion
III:
Company
E
manufactures
300,000
pounds
or
more
of
benzene,
mono­
C14­
16­
alkyl
derivs.
Benzene,
mono­
C14­
16­
alkyl
derivs.
is
listed
as
a
partially
exempted
substance
in
Appendix
E;
therefore,
Company
E
must
complete
Parts
I
and
II
of
Form
U.
Company
E
does
not
need
to
complete
Part
III
because
it
is
partially
exempted.

Key
Points:


Benzene,
mono­
C14­
16­
alkyl
derivs.
is
partially
exempt
from
reporting
(
see
40
CFR
710.46(
b)(
2)(
iv)
and
Appendix
E),
therefore
only
Parts
I
and
II
need
to
be
completed.
DRAFT:
Appendix
G
Case
Studies
G­
25
Completing
the
Form:
Part
II.
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
2.
A.
1
Chemical
ID
Number
129813­
60­
1
CAS
Number
2.
A.
2
ID
Code
C
Code
for
CAS
Number
2.
A.
3
Chemical
Name
Benzene,
mono­
C14­
16­
alkyl
derivs.
Chemical
Abstracts
Index/
Preferred
name
2.
B.
3
Site
limited
N
Benzene,
mono­
C14­
16­
alkyl
derivs.
is
distributed
off­
site.

2.
B.
4
Activity
Manufacture
Benzene,
mono­
C14­
16­
alkyl
derivs.
is
manufactured
and
not
imported.

2.
B.
5
Production
Volume
(
lbs)
500,000
Reported
to
amount
reasonably
obtainable.

2.
B.
7
Number
of
Workers
W2
At
least
25
but
fewer
than
50.
Company
E
estimates
40
workers
exposed
(
20
workers
per
line
x
2
lines
=
40
workers).

2.
B.
8
Maximum
Concentration
M5
Greater
than
90%
by
weight.
The
maximum
concentration
leaving
the
site
is
95%.

2.
B.
14
Physical
Form
Percent
of
PV
a.
Liquid;
b.
100
100%
of
the
product
is
produced
as
liquid
formulations
and
mixtures.

Part
III
­
Section
I.
Industrial
Processing
and
Use
Information
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.

Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.
DRAFT:
Appendix
G
Case
Studies
G­
26
Form
U
­
CASE
STUDY
E
Page
___
of
___

PART
II.
MANUFACTURING
INFORMATION
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
129813­
60­
1
2.
A.
2
ID
Code
C
2.
A.
3
Chemical
Name
Benzene,
Mono­
C14­
16­
Alkyl
Derivs.

SECTION
B.
MANUFACTURING
INFORMATION
2.
B.
1
Company
Information
CBI
2.
B.
2
Plant
Site
Identity*
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
Check
All
That
Apply
CBI
Percent
CBI
2.
B.
3
Site
Limited
(
Y/
N)
N
CBI
2.
B.
9
Dry
Powder
2.
B.
4
Activity
(
Check
all
that
apply)

Manufacture
G
Import
CBI
2.
B.
10
Pellets
or
Large
Crystals
2.
B.
5
Production
Volume
(
LB)
500,000
CBI
2.
B.
11
Water
or
Solvent
Wet
Solid
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
CBI
2.
B.
12
Other
Solid
2.
B.
7
Number
of
Workers
(
code)
W2
CBI
2.
B.
13
Gas
or
Vapor
2.
B.
8
Maximum
Concentration
(
code)
M5
CBI
2.
B.
14
Liquid

100
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.

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
*
Substantiation
required
for
CBI
claims
on
chemical
identity
and
plant
site
identity.
FOR
EPA
USE
ONLY
DRAFT:
Appendix
G
Case
Studies
G­
27
CASE
STUDY
F
This
example
illustrates
how
to
report:


When
two
different
physical
forms
are
manufactured;


The
use
in
a
children's
product;
and

Children's
Product
Use
as
"
not
readily
obtainable";
when
the
sum
of
the
percent
production
volume
is
greater
than
100%.

Scenario:
At
one
site,
Company
F
manufacturers
a
total
of
800,000
lb/
yr
of
C.
I.
Pigment
Yellow
100
(
CAS#
12225­
21­
7)
in
both
powdered
and
liquid
forms.
Company
F
manufactures
and
sells
300,000
lb/
yr
of
powdered
C.
I.
Pigment
Yellow
100
(
100%
concentration)
to
6
sites
that
incorporate
it
into
plastic
pellets
at
less
than
1%
concentration.
These
pellets
are
then
molded
into
plastic
articles
which
are
sold
to
consumers.
The
remaining
500,000
pounds
of
C.
I.
Pigment
Yellow
100
is
sold
as
a
liquid
at
concentrations
between
1%
and
30%
as
a
coloring
agent
to
approximately
50
paint
manufacturers.
The
paint
manufacturers
then
sell
60%
of
this
paint
(
300,000
lbs.)
directly
to
the
consumer
and
the
other
40%
to
about
10
toy
manufacturers
that
paint
wooden
toys
(
200,000
lbs.).
The
toys
are
then
sold
to
consumers,
including
children.

Company
F
employs
25
workers
to
manufacture
C.
I.
Pigment
Yellow
100
as
a
powder
and
an
additional
20
workers
to
manufacture
the
liquid
formulations.
Company
F
estimates
that
5
workers
are
exposed
to
C.
I.
Pigment
Yellow
100
at
each
plastic
manufacturing
site
and
5
workers
are
exposed
at
each
paint
manufacturing
site.
Company
F
estimates
5
workers
are
exposed
at
to
C.
I.
Pigment
Yellow
100
at
each
wooden
toy
manufacturer
site.

EPA
Approach:
Criterion
I:
C.
I.
Pigment
Yellow
100
is
listed
on
the
TSCA
Inventory
and
does
not
qualify
as
an
excluded
substance
for
IUR
reporting.

Criterion
II:
Company
F
manufactures
25,000
pounds
or
more
of
C.
I.
Pigment
Yellow
100
and
does
not
qualify
as
a
small
manufacturer.
Company
F
does
not
qualify
for
any
additional
reporting
exemptions.

Criterion
III:
Company
F
manufactures
300,000
pounds
or
more
of
C.
I.
Pigment
Yellow
100,
which
does
not
qualify
as
a
partial
exemption.

Key
Points:


Company
F
should
report
45
workers
potentially
exposed
during
manufacturing
operations.


Company
F
based
its
estimates
for
Part
III
on
its
understanding
of
how
its
customers
process
and
use
C.
I.
Pigment
Yellow
100.
DRAFT:
Appendix
G
Case
Studies
G­
28
Company
F
produces
300,000
lbs.
of
powdered
CI
Pigment
Yellow
100
at
100%
concentration
INDUSTRIAL
PROCESSING
AND
USE
500,000
lbs.
of
CI
Pigment
Yellow
100
is
sold
to
50
paint
manufacturers
as
a
coloring
agent
and
is
blended
into
paint
formulations
at
concentrations
of
1
­
30%
(
Block
3.
A.
2)
Company
F
produces
500,000
lbs.
of
powdered
CI
Pigment
Yellow
in
liquid
solution
at
1
­
30%

300,000
lbs.
of
CI
Pigment
Yellow
100
sold
to
6
sites
that
incorporate
it
into
plastic
pellets
(
Block
3.
A.
1)

Plastic
pellets
containing
CI
Pigment
Yellow
100
are
molded
into
articles
(
Block
3.
B.
1)
300,000
lbs.
is
sold
directly
to
the
consumer
as
a
component
in
paint
(
Block
3.
B.
2)
200,000
lbs.
is
sold
to
10
toy
manufacturers
for
painting
wooden
toys
(
Block
3.
B.
3)

COMMERCIAL
AND
CONSUMER
END
USE
CASE
STUDY
F
­
Flow
Diagram
DRAFT:
Appendix
G
Case
Studies
G­
29
Completing
the
Form:
Part
II.
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
2.
A.
1
Chemical
ID
Number
12225­
21­
7
CAS
Number
2.
A.
2
ID
Code
C
Code
for
CAS
Number
2.
A.
3
Chemical
Name
C.
I.
Pigment
Yellow
100
Chemical
Abstracts
Index/
Preferred
name
2.
B.
3
Site
limited
N
C.
I.
Pigment
Yellow
100
is
distributed
off­
site
for
commercial
purposes.

2.
B.
4
Activity
Manufacture
C.
I.
Pigment
Yellow
100
is
manufactured
and
not
imported.

2.
B.
5
Production
Volume
(
lbs)
800,000
Reported
to
amount
reasonably
obtainable.

2.
B.
7
Number
of
Workers
W3
At
least
25
but
fewer
than
50.
Company
F
employs
45
workers
to
produce
C.
I.
Pigment
Yellow
100
(
25
for
powder
form
and
20
for
liquid
form).

2.
B.
8
Maximum
Concentration
M5
Greater
than
90%
by
weight.
The
maximum
concentration
leaving
the
site
is
100%.

2.
B.
9
Physical
Form
Percent
of
PV
a.
Powder;
b.
40
300,000
of
the
total
800,000
pounds
(
37.5%)
of
product
is
produced
as
a
powder.
Round
up
to
40%.

2.
B.
14
Physical
Form
Percent
of
PV
a.
Liquid;
b.
60
500,000
of
the
total
800,000
pounds
(
62.5%)
of
product
is
produced
as
a
liquid.
Round
down
to
60%.
DRAFT:
Appendix
G
Case
Studies
G­
30
Part
III
­
Section
I.
Industrial
Processing
and
Use
Information
Block
Block
Title
Report
Basis/
Rationale
3.
A.
1
Type
of
Process
or
Use
PA
Incorporation
into
an
article.
This
accounts
for
the
powder
form
being
incorporated
into
plastic
pellets.

NAICS
32619
Other
plastics
product
manufacturing.

IFC
U08
Coloring
agents,
pigments.

Percent
PV
40
37.5%
of
the
production
volume
is
used
for
this
use.
Round
up
to
40%.

Number
of
Sites
S1
Less
than
10.
Company
F
has
6
customer
sites.

Number
of
Workers
W3
At
least
25
but
fewer
than
50.
Company
B
estimates
5
exposed
workers
for
each
of
6
processing
sites.
5
workers
per
site
x
6
sites
=
30
workers.

3.
A.
2
Type
of
Process
or
Use
PF
Incorporation
into
formulations
and
mixtures.

NAICS
32551
Paint
and
coating
manufacturing.

IFC
U08
Coloring
agents,
pigments.

Percent
PV
60
62.5%
of
the
production
volume
is
used
for
this
use.
Round
down
to
60%.

Number
of
Sites
S3
From
26
to
100.
Company
F
estimates
50
paint
manufacturers
use
their
product.

Number
of
Workers
W5
At
least
100
but
fewer
than
500.
Company
F
estimates
5
exposed
workers
per
site
for
50
processing
sites
=
250
of
workers.
DRAFT:
Appendix
G
Case
Studies
G­
31
Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
Block
Block
Title
Report
Basis/
Rationale
3.
B.
1
Commercial
and
Consumer
Product
Category
C15
Rubber
and
plastics
products.

Use
in
Children's
Product
?
Information
not
readily
obtainable.

Percent
PV
40
40%
of
C.
I.
Pigment
Yellow
100
manufactured
by
Company
F
is
used
in
polymers/
plastics.

Maximum
Concentration
M1
Less
than
1%
by
weight.

3.
B.
2
Commercial
and
Consumer
Product
Category
C12
Paints
and
coatings.

Use
in
Children's
Product
N
Paints
sold
directly
to
consumer
are
not
expected
to
be
used
by
children.

Percent
PV
40
37.5%
of
C.
I.
Pigment
Yellow
100
manufactured
by
Company
F
is
used
in
paint.
Round
up
to
40%.

Maximum
Concentration
M2
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
30%.

3.
B.
3
Commercial
and
Consumer
Product
Category
C18
Wood
and
wood
furniture.

Use
in
Children's
Product
Y
Wooden
toys
are
expected
to
be
used
by
children.

Percent
PV
30
25%
of
PV
(
200,000
lbs.)
is
used
in
paint
for
wooden
toys.
Round
up
to
30%.

Maximum
Concentration
M2
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
30%.
DRAFT:
Appendix
G
Case
Studies
G­
32
Form
U
­
CASE
STUDY
F
Page
___
of
___

PART
II.
MANUFACTURING
INFORMATION
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
12225­
21­
7
2.
A.
2
ID
Code
C
2.
A.
3
Chemical
Name
C.
I.
Pigment
Yellow
100
SECTION
B.
MANUFACTURING
INFORMATION
2.
B.
1
Company
Information
CBI
2.
B.
2
Plant
Site
Identity*
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
Check
All
That
Apply
CBI
Percent
CBI
2.
B.
3
Site
Limited
(
Y/
N)
N
CBI
2.
B.
9
Dry
Powder

40
2.
B.
4
Activity
(
Check
all
that
apply)

Manufacture
G
Import
CBI
2.
B.
10
Pellets
or
Large
Crystals
2.
B.
5
Production
Volume
(
LB)
800,000
CBI
2.
B.
11
Water
or
Solvent
Wet
Solid
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
CBI
2.
B.
12
Other
Solid
2.
B.
7
Number
of
Workers
(
code)
W3
CBI
2.
B.
13
Gas
or
Vapor
2.
B.
8
Maximum
Concentration
(
code)
M5
CBI
2.
B.
14
Liquid

60
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.

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
PA
32619
U08
40
51
W3
3.
A.
2
PF
32551
U08
60
53
W5
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
C15
?
40
M1
3.
B.
2
C12
N
40
M2
3.
B.
3
C18
Y
30
M2
3.
B.
4
3.
B.
5
3.
B.
6
3.
B.
7
3.
B.
8
3.
B.
9
3.
B.
10
*
Substantiation
required
for
CBI
claims
on
chemical
identity
and
plant
site
identity.
FOR
EPA
USE
ONLY
DRAFT:
Appendix
G
Case
Studies
G­
33
CASE
STUDY
G
This
example
illustrates
how
to
report:


A
chemical
substance
that
is
both
manufactured
and
imported
at
the
same
site;


Multiple
Types
of
Process
or
Use
codes;


Multiple
NAICS
codes

Multiple
IFC
codes;


When
the
sum
of
the
percent
production
volume
for
Industrial
Processing
is
greater
than
100%;
and

TSCA­
exempt
use
(
as
a
pesticide)

Scenario:
Company
G
produced
19,000,000
pounds
of
xylene,
mixed
isomers
(
CAS#
1330­
20­
7)
(
referred
to
as
xylene
throughout
this
case
study)
and
imported
an
additional
1,000,000
pounds
during
the
same
reporting
year
to
the
same
site.
The
xylene
is
manufactured
at
100%
concentration.
Company
G
estimates
8
exposed
workers
during
the
manufacture
of
xylene
for
sampling
and
maintenance,
in
addition
to
6
exposed
workers
during
the
drumming
of
product.

Company
G
distributes
4,000,000
pounds
of
xylene
directly
to
3
chemical
manufacturing
facilities
at
100%
concentration
to
be
used
as
a
chemical
reactant.
Company
G
estimates
4
workers
are
potentially
exposed
at
each
manufacturing
facility
to
transfer
the
xylene
from
shipping
containers
to
the
reactor.

The
remaining
16,000,000
pounds
of
xylene
is
shipped
to
15
different
distributors
for
formulation
of
products.
Company
G
estimates
6
workers
are
potentially
exposed
at
each
distribution
site.
The
distributors
formulate
4,000,000
pounds
of
xylene
and
sell
it
as
a
metal
degreaser
at
95%
concentration
to
200
hardware
manufacturers;
and
Company
G
estimates
3
workers
are
potentially
exposed
to
xylene
per
hardware
manufacturer.
The
formulator
dilutes
the
remaining
12,000,000
pounds
such
that
xylene
is
present
at
a
concentration
ranging
between
0.5%
and
95%
and
places
the
final
product
into
smaller
containers.
Of
the
12,000,000
pounds
of
xylene
that
is
processed,
6,000,000
pounds
is
used
in
automotive
care
products
(
35%
max.
conc.)
used
both
commercially
and
by
consumers.
3,200,000
pounds
will
be
used
in
paint
formulations
(
15%
max.
conc.)
which
are
then
sold
for
commercial
and
consumer
applications.
2,200,000
pounds
is
formulated
into
pesticides
(
10%
max
conc.)
which
is
then
sold
for
commercial
use.
400,000
pounds
is
sold
for
formulation
of
a
wood
preservative
(
20%
conc.)
to
be
used
on
furniture
for
residential
use.
200,000
pounds
is
sold
as
a
component
of
solvents
on
the
consumer
market
(
95%
max
conc.).

EPA
Approach:
Pesticides
are
regulated
by
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
and
are
exempt
from
TSCA
regulations.
Therefore,
the
portion
of
xylene
used
in
pesticides
does
not
need
to
be
reported
under
IUR.

Criterion
I:
Xylene
is
listed
on
the
TSCA
Inventory
and
is
not
a
substance
excluded
from
DRAFT:
Appendix
G
Case
Studies
G­
34
reporting.

Criterion
II:
Company
G
manufactures
25,000
pounds
or
more
of
xylene
and
does
not
qualify
as
a
small
manufacturer.
Company
G
does
not
qualify
for
any
additional
reporting
exemptions.

Criterion
III:
Company
G
manufactures
300,000
pounds
or
more
of
xylene
and
does
not
qualify
for
any
partial
exemptions.
Therefore,
Company
G
must
complete
Parts
I,
II,
and
III
of
Form
U
for
xylene.

Key
Points:


Pesticides
are
exempt
from
regulation
under
TSCA,
therefore
the
use
of
xylene
for
the
preparation
of
a
commercial
pesticide
formulation
does
not
need
to
be
included
in
Form
U.


The
200,000
lbs.
of
xylene
used
as
a
component
of
solvents
sold
to
consumers
should
not
be
reported
in
Part
III
because
it
is
less
than
5%
of
the
total
production
volume
and
less
than
the
300,000
pounds
threshold.


The
percent
production
volumes
for
use
as
wood
preservatives
and
paint
used
by
consumers
should
be
reported
to
the
nearest
percentage
point
because
it
is
less
than
5%
of
the
production
volume
and
totals
300,000
lbs.
or
more.


The
furniture
that
contains
xylene
may
be
used
by
children.


Company
G
based
its
estimates
for
Part
III
on
information
readily
obtainable
from
its
knowledge
of
how
its
customers
use
the
xylene.
Some
information
about
how
its
customers
processed
and
used
xylene
for
paint
formulations
and
wood
preservatives
were
left
blank
because
it
was
not
readily
obtainable.
DRAFT:
Appendix
G
Case
Studies
G­
35
19,000,000
lbs.
xylene
produced
by
Company
A
at
100%
concentration
INDUSTRIAL
PROCESSING
AND
USE
Paint
sold
for
commerical
and
consumer
applications
(
Block
3.
B.
2)

COMMERCIAL
AND
CONSUMER
END
USE
1,000,000
lbs.
xylene
imported
by
Company
A
at
100%
concentration
Company
A
manufactures
20,000,000
lbs.
of
xylene
at
100%
concentration
16,000,000
lbs.
shipped
to
15
different
forulators
for
formulation
and
packaging
at
0.5%
­
95%
(
Block
3.
A.
2)

4,000,000
lbs.
used
at
95%
concentration
as
a
metal
degreaser
at
200
hardware
manufacturers
(
Block
3.
A.
3)
4,000,000
lbs.
shipped
directly
to
3
chemical
manufactures
at
100%
concentration
for
use
as
a
chemical
reactant
(
Block
3.
A.
1)

2,200,000
lbs.
reformulated
into
pesticides
at
10%
concentration
(
Exempt
because
regulated
by
FIFRA)

3,200,000
lbs.
reformulated
into
paint
at
15%
maximum
concentration
(
Block
3.
A.
4)
400,000
lbs.
sold
as
a
component
in
wood
preservatives
at
20%
maximum
concentration
(
Block
3.
A.
5)

Pesticides
sold
for
commerical
and
consumer
applications
(
Exempt
because
regulated
by
FIFRA)
Applied
to
residential
furniture
(
Block
3.
B.
3)

6,000,000
lbs.
used
as
a
component
in
automotive
care
products
at
35%
maximum
concentration
(
Block
3.
B.
1)
200,000
lbs.
used
as
a
component
of
solvents
sold
to
consumers
at
95%
maximum
concentration
(
Exempt:
Less
than
300,000
lbs.
and
5%
PV)
CASE
STUDY
G
­
Flow
Diagram
DRAFT:
Appendix
G
Case
Studies
G­
36
Completing
the
Form:
Part
II
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
2.
A.
1
Chemical
ID
Number
1330­
20­
7
CAS
Number
2.
A.
2
ID
Code
C
Code
for
CAS
Number
2.
A.
3
Chemical
Name
Xylene,
mixed
isomer
Chemical
Abstracts
Index/
Preferred
name
2.
B.
3
Site
limited
N
Xylene
is
distributed
off­
site
for
commercial
purposes.

2.
B.
4
Activity
Manufacture
and
import
Xylene
is
both
manufactured
and
imported.

2.
B.
5
Production
Volume
(
lbs)
17,800,000
Combined
manufacture
and
import
volumes,
but
not
including
the
2,200,000
lbs
used
in
pesticide
formulations.

2.
B.
7
Number
of
Workers
W2
At
least
10
but
fewer
than
25.
Company
G
reports
14
workers
are
exposed
during
the
manufacture
of
xylene.

2.
B.
8
Maximum
Concentration
M5
Greater
than
90%
by
weight.
The
maximum
concentration
leaving
the
site
is
100%.

2.
B.
14
Physical
Form
Percent
of
PV
a.
Liquid;
b.
100
100%
of
the
product
is
manufactured
in
liquid
form.
DRAFT:
Appendix
G
Case
Studies
G­
37
Part
III
­
Section
I.
Industrial
Processing
and
Use
Information.

Block
Block
Title
Report
Basis/
Rationale
3.
A.
1
Type
of
Process
or
Use
PC
Processing
as
a
reactant.

NAICS
32519
Other
basic
organic
chemical
manufacturing.

IFC
U16
Intermediates.

Percent
PV
20
20%
PV
(
4,000,000
lbs)
is
distributed
directly
to
3
chemical
manufacturers.
4,000,000
lbs.
/
20,000,000
lbs.
total
=
20%.

Number
of
Sites
S1
Less
than
10
sites.

Number
of
Workers
W2
At
least
10
but
fewer
than
25.
Company
B
estimates
4
exposed
workers
for
each
of
3
industrial
sites.
4
workers
per
site
x
3
sites
=
12
workers.

3.
A.
2
Type
of
Process
or
Use
PF
Incorporation
into
formulations
and
mixtures.

NAICS
32519
Other
basic
organic
chemical
manufacturing.

IFC
U27
Solvents
(
for
cleaning
or
degreasing).

Percent
PV
80
80%
PV
(
16,000,000
lbs.)
is
repackaged.

Number
of
Sites
S2
From
10
to
25.
Company
G
distributes
xylene
to
15
distributor/
repackaging
centers.

Number
of
Workers
W4
At
least
50
but
fewer
than
100.
Company
F
estimates
6
exposed
workers
per
site
x
15
sites
=
90
workers.

3.
A.
3
Type
of
Process
or
Use
U
Industrial
grade
solvent.
Used
as
a
metal
degreaser.

NAICS
33251
Hardware
manufacturing.

IFC
U27
Solvents
(
for
cleaning
or
degreasing).

Percent
PV
20
20%
PV
(
4,000,000
lbs)
is
distributed
from
distribution/
repackaging
centers
to
200
hardware
manufacturers
for
use
as
a
metal
degreaser.

Number
of
Sites
S4
From
101
to
250.
200
hardware
manufacturers
use
xylene
as
a
metal
degreaser.

Number
of
Workers
W6
At
least
500
but
fewer
than
1000.
Company
B
estimates
3
exposed
workers
for
each
of
200
sites.
3
workers
per
site
x
200
sites
=
600
workers.
DRAFT:
Appendix
G
Case
Studies
Block
Block
Title
Report
Basis/
Rationale
G­
38
3.
A.
4
Type
of
Process
or
Use
PF
Incorporation
into
formulations
and
mixtures.

NAICS
32551
Paint
and
coating
manufacturing.

IFC
U28
Solvents
(
which
become
part
of
product
formulation
or
mixture).

Percent
PV
20
16%
PV
of
xylene
(
3,200,000
lbs.)
is
used
in
paint
formulations.
Round
to
20%.

Number
of
Sites
Company
G
has
determined
that
this
information
is
not
readily
obtainable.

Number
of
Workers
Company
G
has
determined
that
this
information
is
not
readily
obtainable.

3.
A.
5
Type
of
Process
or
Use
PF
Incorporation
into
formulations
and
mixtures.

NAICS
32111
Sawmills
and
wood
preservation.

IFC
U28
Solvents
(
which
become
part
of
product
formulation
or
mixture).

Percent
PV
2
2%
PV
(
400,000
lbs.)
of
xylene
is
used
as
a
component
in
wood
preservatives.
This
percentage
is
rounded
to
the
nearest
percentage
point
because
it
is
less
than
5%
and
volume
is
300,000
lbs.
or
greater.

Number
of
Sites
Company
G
has
determined
that
this
information
is
not
readily
obtainable.

Number
of
Workers
Company
G
has
determined
that
this
information
is
not
readily
obtainable.
DRAFT:
Appendix
G
Case
Studies
G­
39
Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
Block
Block
Title
Report
Basis/
Rationale
3.
B.
1
Commercial
and
Consumer
Product
Category
C03
Automotive
care
products.

Use
in
Children's
Product
N
Not
expected
to
be
used
by
children.

Percent
PV
30
30%
PV
(
6,000,000
lbs.)
is
used
in
the
formulation
of
automotive
care
products.

Maximum
Concentration
M3
From
31%
to
60%
by
weight.
The
maximum
concentration
used
in
formulations
is
35%.

3.
B.
2
Commercial
and
Consumer
Product
Category
C12
Paints
and
coatings
(
commercial
use).

Use
in
Children's
Product
N
Not
expected
to
be
used
by
children.

Percent
PV
20
16%
PV
(
3,200,000
lbs.)
is
used
in
paints
for
commercial
use.
Round
up
to
20%.

Maximum
Concentration
M2
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
15%.

3.
B.
3
Commercial
and
Consumer
Product
Category
C18
Wood
and
wood
furniture.

Use
in
Children's
Product
Y
Not
expected
to
be
used
by
children.

Percent
PV
2
2%

PV
(
400,000
lbs.
)
of
xylene
is
used
as
a
component
in
wood
preservatives.
Since
this
percentage
is
less
than
5%
and
totals
300,000
pounds
or
greater,
round
to
the
nearest
percentage
point
(
2%).

Maximum
Concentration
M2
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
20%.
DRAFT:
Appendix
G
Case
Studies
G­
40
Form
U
­
CASE
STUDY
G
Page
___
of
___

PART
II.
MANUFACTURING
INFORMATION
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
12225­
21­
7
2.
A.
2
ID
Code
C
2.
A.
3
Chemical
Name
C.
I.
Pigment
Yellow
100
SECTION
B.
MANUFACTURING
INFORMATION
2.
B.
1
Company
Information
CBI
2.
B.
2
Plant
Site
Identity*
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
Check
All
That
Apply
CBI
Percent
CBI
2.
B.
3
Site
Limited
(
Y/
N)
N
CBI
2.
B.
9
Dry
Powder
2.
B.
4
Activity
(
Check
all
that
apply)

Manufacture

Import
CBI
2.
B.
10
Pellets
or
Large
Crystals
2.
B.
5
Production
Volume
(
LB)
17,800,000
CBI
2.
B.
11
Water
or
Solvent
Wet
Solid
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
CBI
2.
B.
12
Other
Solid
2.
B.
7
Number
of
Workers
(
code)
W2
CBI
2.
B.
13
Gas
or
Vapor
2.
B.
8
Maximum
Concentration
(
code)
M5
CBI
2.
B.
14
Liquid

100
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.

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
PC
32519
U16
20
S1
W2
3.
A.
2
PF
32519
U27
80
S2
W4
3.
A.
3
U
33251
U27
20
S4
W6
3.
A.
4
PF
32551
U28
20
3.
A.
5
PF
32111
U28
2
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
C03
N
30
M3
3.
B.
2
C12
N
20
M2
3.
B.
3
C18
Y
2
M2
3.
B.
4
3.
B.
5
3.
B.
6
3.
B.
7
3.
B.
8
3.
B.
9
3.
B.
10
*
Substantiation
required
for
CBI
claims
on
chemical
identity
and
plant
site
identity.
FOR
EPA
USE
ONLY
