Cost
Savings
Estimate
of
Adding
1,2,3
Propanetriol
(
CASRN
56­
81­
5)
to
the
40
CFR
710.46(
b)(
2)
Chemical
Substance
List
The
Inventory
Update
Reporting
Rule
(
IUR)
requires
manufacturers
of
certain
chemicals
to
report
every
four
years
information
concerning
the
manufacturing,
processing,
and
use
of
their
subject
chemical.
Chemicals
listed
at
40
CFR
710.46(
b)(
2)
are
partially
exempt
from
this
reporting
requirement
and
do
not
report
the
processing
and
use
information
required
by
40
CFR
710.52(
c)(
4).
The
Environmental
Protection
Agency
is
adding
1,2,3­
propanetriol
(
CASRN
56­
81­
5)
to
this
partial
exemption
through
a
direct
final
rulemaking
action.
The
addition
of
this
chemical
results
in
a
cost
savings
of
$
119,483
to
$
128,960
in
the
first
cycle
and
$
95,586
to
$
103,168
in
future
cycles.
This
paper
provides
the
basis
for
this
conclusion.

Table
1:
Non­
CBI
Inventory
Update
Reporting
for
1,2,3­
Propanetriol
(
CASRN
56­
81­
5)

Reporting
Year
Number
of
Reports
Total
Production
Volume
2002
21
100
million
to
500
million
lbs.

1998
28
100
million
to
500
million
lbs.

The
non­
CBI
IUR
reporting
represents
only
a
portion
of
IUR
reporting.
Based
on
that,
EPA
assumes
22
reports
in
excess
of
300,000
pounds
would
be
received
for
1,2,3­
propanetriol
(
CASRN
56­
81­
5).

Table
2:
Estimate
of
Savings
Due
to
Addition
of
1,2,3­
Propanetriol
(
CASRN
56­
81­
5)
to
the
IUR
Partial
Exemption
First
Reporting
Period
Future
Reporting
Periods
Report
Type
Full
Partial
Difference
Full
Partial
Difference
Per
report
cost
estimate
High
$
7,228.00
$
1,366.70
$
5,861.84
$
5,919.40
1,229.9
3
$
4,689.47
Low
$
6,342.41
$
911.38
$
5,431.03
$
5,166,03
$
821.20
$
4,344.83
Number
of
reports
22
reports
with
production
volumes
of
300,000
lbs.
or
greater
Total
savings
estimate
High
$
128,960
$
103,168
Low
$
119,483
$
95,586
Note:
Figures
from
table
3­
13
in
the
Economic
Analysis
for
the
Amended
Inventory
Update
Final
Rule,
August
2002.
