1
SUPPORTING
STATEMENT
FOR
STANDARD
FORM
83­
I
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
TITLE
AND
NUMBER
OF
THE
INFORMATION
COLLECTION
Modifications
to
Standards
and
Requirements
for
Reformulated
and
Conventional
Gasoline
Including
Recordkeeping
and
Reporting
Requirements
Regarding
Previously
Certified
Gasoline.
Current
OMB
control
number
is
2060­
0277.
The
EPA
number
for
these
modifications
is
1591.12.

(
b)
SHORT
CHARACTERIZATION
Section
211(
k)
of
the
Clean
Air
Act
("
Act")
mandates
a
complex
reformulated
gasoline
program
requiring
that
reformulated
gasoline
(
RFG)
which
meets
various
requirements
be
exclusively
sold
in
nine
statutory
control
areas
and
in
other
ozone
nonattainment
areas
that
"
opt­
in"
to
the
reformulated
gasoline
program.
The
Act
also
requires
EPA
to
regulate
the
production
and
sale
of
conventional
gasoline
(
non­
RFG)
throughout
the
rest
of
the
country.
Refiners
and
importers
of
gasoline
are
required
to
demonstrate
compliance
by
conducting
sampling
and
testing
of
the
gasoline
and
reporting
the
results
to
EPA's
Office
of
Transportation
and
Air
Quality.
The
burden
and
cost
estimates
in
this
ICR
are
those
costs
associated
with
modifications
to
the
final
rule
establishing
standards
and
requirements
for
reformulated
and
conventional
gasoline
pursuant
to
§
211(
k)
of
the
Act.
Previous
ICRs
have
covered
start
up
costs
and
other
record
keeping,
reporting,
and
testing
requirements
associated
with
the
final
rule.

One
of
the
revisions
in
today's
rule,
regarding
previously
certified
gasoline
(
PCG),
provides
industry
with
greater
flexibility
regarding
certain
gasoline
processing
activities,
but
necessitates
some
additional
recordkeeping
and
reporting
requirements
for
refiners
who
avail
themselves
of
this
flexibility.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION
The
basic
need
and
authority
for
the
collection
of
information
have
been
established
in
the
ICR
for
the
RFG
final
rule.
Section
211(
k)
of
the
Act
specifically
provides
that
2
recordkeeping
and
sampling
and
testing
requirements
are
among
the
tools
EPA
may
use
in
enforcement
of
the
provisions
of
§
211(
k)
and
also
provides
that
EPA
must
develop
an
enforceable
scheme.
Sections
114
and
208
of
the
Act
authorize
EPA
to
require
recordkeeping
and
reporting
regarding
enforcement
of
the
provisions
of
Title
II
of
the
Act.
The
additional
information
collection
required
in
these
revisions
to
the
RFG
final
rule
are
necessary
to
ensure
that
regulated
parties
comply
with
the
standards
and
limitations
of
the
rules
for
RFG
and
conventional
gasoline.

(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
practical
utility
and
use
of
the
collection
of
information
under
the
RFG
rule
generally
has
been
established
in
the
ICR
for
the
RFG
final
rule.
The
information
collection
requirements
associated
with
the
provisions
for
PCG
are
necessary
enforcement
mechanisms
to
ensure
that
the
increased
flexibility
allowed
by
these
provisions
will
not
result
in
any
environmental
degradation.

The
EPA's
Office
of
Enforcement
and
Compliance
Assurance
and
EPA's
Office
of
Air
and
Radiation,
Office
of
Transportation
and
Air
Quality,
will
be
the
governmental
users
of
the
information
contained
in
this
information
collection.
In
addition,
the
required
information
collection
is
necessary
for
parties
to
track
their
own
compliance
with
applicable
standards.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
(
a)
NONDUPLICATION
The
information
collection
is
not
unnecessarily
duplicative
of
information
otherwise
reasonably
accessible
to
the
Agency
and
is
not
available
from
other
sources.
The
collection
activities
associated
with
these
revisions
are
approved
under
the
ICR
for
the
final
RFG
rule.

(
b)
CONSULTATIONS
Representatives
from
the
affected
industry
have
participated
in
the
development
process
regarding
the
revisions
in
this
action.
The
primary
industry
contacts
are
representatives
of
the
National
Petrochemical
&
Refining
Association
and
the
American
Petroleum
Institute.

Public
comments
on
this
action
will
be
addressed
in
the
final
rulemaking
package.
3
(
c)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
If
the
relevant
information
were
to
be
collected
less
frequently,
EPA
would
not
be
reasonably
assured
that
the
refiner
is
in
compliance
with
the
standards
for
RFG
and
conventional
gasoline.

(
d)
GENERAL
GUIDELINES
The
general
guidelines
for
the
collection
of
information
pursuant
to
the
RFG
rule
are
approved
in
the
ICR
for
the
final
RFG
rule.

(
e)
CONFIDENTIALITY
AND
SENSITIVE
QUESTIONS
(
i)
Confidentiality
Any
information
submitted
to
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
EPA
regulations
at
40
C.
F.
R.
2.201
et.
seq.

(
ii)
Sensitive
Questions
This
section
is
not
applicable
as
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
(
a)
RESPONDENTS/
SIC
CODES
Respondents
are
refiners
(
2911)
of
RFG
and
conventional
gasoline.
There
are
approximately
230
refiners
of
RFG
and
conventional
gasoline.
Much
of
the
required
information
collection
is
generated
and
currently
maintained
in
the
normal
course
of
business.
Without
the
required
information,
EPA
will
be
unable
to
ensure
compliance
with
the
RFG
and
conventional
gasoline
standards.

(
b)
INFORMATION
REQUESTED
(
i)
Data
Items,
Including
Record
keeping
Requirements
The
provisions
providing
flexibility
with
regard
to
PCG
require
refiners
to
maintain
documents
of
test
results
and
documents
that
reflect
the
storage
and
movement
of
the
PCG
to
the
point
it
is
used
to
produce
gasoline,
and
to
report
the
volume
and
properties
of
the
PCG
to
EPA.
Requirements
for
testing
batches
blended
with
PCG
would
be
no
different
than
the
4
requirements
for
testing
other
batches
of
gasoline.
These
provisions,
however,
will
allow
industry
the
flexibility
to
blend
more
batches
of
gasoline.

(
ii)
Respondent
Activities
The
information
collection
activities
for
recordkeeping
and
reporting
are
as
described
in
the
approved
ICR
for
the
RFG
final
rule.

5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY
AND
INFORMATION
MANAGEMENT
(
a)
AGENCY
ACTIVITIES
The
number
of
batch
reports
submitted
by
refiners
should
increase
only
slightly,
thereby
increasing
the
burden
on
the
Agency
to
review
and
analyze
additional
data
to
an
insignificant
degree.

(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
There
are
no
significant
changes
to
the
collection
methodologies
in
the
ICR
for
the
RFG
final
rule
anticipated
as
a
result
of
these
revisions
to
the
rule.

(
c)
SMALL
BUSINESS
FLEXIBILITY
This
rule
will
allow
all
refiners,
including
small
business
refiners,
to
use
conventional
gasoline
to
produce
RFG
and
to
reclassify
RFG
with
regard
to
VOC
designation,
activities
which
are
currently
prohibited.
Any
increase
in
the
information
collection
requirements
necessitated
by
the
increased
flexibility
associated
with
the
use
of
PCG
will
be
more
than
offset
by
the
savings
to
refiners
and
importers
resulting
from
this
additional
flexibility.

(
d)
COLLECTION
SCHEDULE
The
collection
schedule
contained
in
the
ICR
for
the
RFG
final
rule
would
apply
to
the
information
collection
in
these
proposed
revisions.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
(
a)
ESTIMATING
RESPONDENT
BURDEN
It
is
unknown
to
what
extent
industry
will
use
the
option
5
for
PCG.
However,
annual
recordkeeping
and
reporting
requirements
necessitated
by
the
provision
for
PCG
are
estimated
to
be
only
slightly
more
burdensome
than
the
requirements
associated
with
other
forms
of
gasoline
blending
and
refining
(
approximately
3
minutes
per
batch.)
It
should
be
noted
that
there
is
no
requirement
to
use
PCG
for
blending
gasoline.
The
provision
for
using
PCG
is
included
in
the
regulations
at
the
request
of
industry
to
provide
industry
with
additional
flexibility
in
blending
gasoline.
The
increased
recordkeeping/
reporting
burden
is
insignificant
when
compared
to
the
savings
which
industry
would
derive
from
the
increased
flexibility
that
the
provisions
for
PCG
provide.
The
amount
of
time
required
to
test
batches
blended
with
PCG
should
be
no
more
than
the
amount
of
time
required
to
test
other
batches
of
gasoline.

(
b)
ESTIMATING
RESPONDENT
COST
The
cost
of
the
recordkeeping
and
reporting
requirements
associated
with
the
provision
for
PCG
is
estimated
to
be
only
slightly
greater
than
the
burden
associated
with
other
forms
of
gasoline
blending
(
approximately
$
1.50
per
batch,
assuming
3
min/
report
@
$
30/
hr.)
The
extent
to
which
industry
will
use
the
provision
for
PCG
is
unknown.
The
estimate
in
this
ICR
is
based
on
50
PCG
batch
reports
per
year.
As
noted
in
(
a)
above,
there
is
no
requirement
to
use
PCG
for
blending
gasoline.
The
provision
for
PCG
is
included
in
this
action
at
the
request
of
industry
to
provide
industry
with
additional
flexibility
in
blending
gasoline.
The
information
collection
is
insignificant
when
compared
to
the
savings
to
industry
derived
from
the
increased
flexibility
that
the
provisions
for
PCG
provide.
The
cost
to
test
a
batch
of
gasoline
blended
with
PCG
should
be
no
more
than
the
cost
to
test
any
other
batch
of
gasoline.

There
are
no
capital/
start­
up
costs
and
negligible
O&
M
costs
associated
with
this
information
collection.

(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST
Insignificant
additional
Agency
costs
are
anticipated
with
regard
to
the
provisions
for
PCG.

(
d)
BOTTOM
LINE
BURDEN
HOURS
AND
COSTS
The
bottom
line
burden
hours
and
costs
for
the
respondents
are
as
given
in
the
table
below:

TABLE
1.
Refiner/
Importer
Information
Collection
6
Information
Collection
Activity
Mgr.
$
58/
hr
Tech.
$
32/
hr
Cler.
$
19/
hr
Resp.
Hr/
Yr
Labor
Cost/
Yr
Capital
Startup
Cost
O&
M
Cost
No.
of
Resp.
Total
Hr/
Yr
Total
Cost/
Yr
PCG
Reporting
0
2.10
.40
2.50
$
75
0
Negl.
230
575
$
17,250
(
e)
REASONS
FOR
CHANGE
IN
BURDEN
These
changes
to
the
existing
ICR
for
the
RFG
final
rule
are
to
ensure
compliance
with
the
RFG
regulations
and
provide
adequate
enforcement
tools.
The
analysis
in
previous
sections
outlines
as
necessary
the
changes
from
the
current
ICR.

(
f)
BURDEN
STATEMENT
The
annual
reporting
and
record
keeping
burden
for
this
collection
of
information
is
estimated
to
average:

Two
and
one
half
hours
($
75)
for
record
keeping/
reporting
for
a
refiner
who
uses
the
PCG
option.

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,
processing
and
maintaining
information,
and
disclosing
and
providing
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;
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.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
to
the
Director,
Collection
Strategies
Division,
OIC,
OEI,
U.
S.
Environmental
Protection
Agency,
(
2822),
1200
Pennsylvania
Ave.,
NW,
Washington,
D.
C.
20460.
Include
the
OMB
control
number
in
any
correspondence
(
currently
valid
OMB
2060­
0277).
Do
not
send
completed
forms
to
the
address.
7
The
collection
of
information
informs
and
provides
reasonable
notice
to
the
potential
persons
to
whom
the
collection
of
information
is
addressed
of:
(
i)
the
reasons
the
information
is
planned
to
be
and/
or
has
been
collected;
(
ii)
the
way
such
information
is
planned
to
be
and/
or
has
been
used
to
further
the
proper
performance
of
the
functions
of
the
Agency;
(
iii)
an
estimate,
to
the
extent
practicable,
of
the
average
burden
of
the
collection
(
together
with
a
request
that
the
public
direct
to
the
Agency
any
comments
concerning
the
accuracy
of
this
burden
estimate
and
any
suggestions
for
reducing
this
burden);
(
iv)
whether
responses
to
the
collection
of
information
are
voluntary,
required
to
obtain
or
retain
a
benefit,
or
mandatory
(
under
sections
211(
k),
208
and
114
of
the
Clean
Air
Act);
(
v)
the
nature
and
extent
of
confidentiality
to
be
provided,
if
any,
under
40
CFR
Part
2;
and
(
vi)
the
fact
that
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.

B.
COLLECTION
OF
INFORMATION
EMPLOYING
STATISTICAL
METHODS
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
the
data
collection
associated
with
the
reformulated
and
anti­
dumping
regulations.
