1
INFORMATION
COLLECTION
REQUEST
United
States
Environmental
Protection
Agency
Part
A
of
the
Supporting
Statement
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title:
Regulation
of
Fuel
and
Fuel
Additives
(
Renewal),
EPA
ICR
No.
1591.15,
OMB
Control
No.
2060­
0277
1(
b)
Abstract
Gasoline
combustion
is
the
major
source
of
air
pollution
in
most
urban
areas.
In
the
1990
amendments
to
the
Clean
Air
Act,
section
211(
k),
Congress
required
that
gasoline
dispensed
in
nine
areas
with
severe
air
quality
problems,
and
areas
that
opt
in,
be
reformulated
to
reduce
toxic
and
ozone­
forming
emissions.
Congress
also
required
that,
in
the
process
of
producing
reformulated
gasoline
(
RFG),
dirty
components
removed
in
the
reformulation
process
not
be
"
dumped"
into
the
remainder
of
the
country's
gasoline,
known
as
conventional
gasoline
(
CG).
The
Environmental
Protection
Agency
(
EPA)
promulgated
regulations
at
40
CFR
part
80,
subpart
D
­
Reformulated
Gasoline,
subpart
E
­
Anti­
Dumping,
and
subpart
F
­
Attest
Engagements,
implementing
the
statutory
requirements,
which
include
standards
for
RFG
(
80.41)
and
CG
(
80.101).
The
regulations
also
contain
reporting
and
recordkeeping
requirements
for
the
production,
importation,
transport
and
storage
of
gasoline,
in
order
to
demonstrate
compliance
and
facilitate
compliance
and
enforcement.
The
program
is
run
by
the
Transportation
and
Regional
Programs
Division,
Office
of
Transportation
and
Air
Quality,
Office
of
Air
and
Radiation.
Enforcement
is
done
by
the
Air
Enforcement
Division,
Office
of
Regulatory
Enforcement,
Office
of
Enforcement
and
Compliance
Assurance.
This
program
excludes
California,
which
has
separate
requirements
for
gasoline.

The
United
States
has
an
annual
gasoline
consumption
of
about
130
billion
gallons.
About
30%
is
RFG.
In
2002
EPA
received
reports
from
275
refineries,
68
importer
facilities/
facility
groups,
32
oxygenate
blending
facilities,
23
independent
laboratory
facilities,
and
the
RFG
Survey
Association,
Inc.
under
this
program.

1(
c)
Response
to
OMB's
Terms
of
Clearance
Comment:
OMB
notes
that
EPA
should
review
the
paper
and
intenet
versions
of
its
forms
to
ensure
that
the
expiration
dates
are
correct
and
update
Form
3520­
20C
to
include
non­
2
certified
FRGAS.

Response:
The
forms
are
up
to
date.
Non­
certified
FRGAS
is
to
be
reported
on
Form
3520­
20C
as
reformulated
gasoline
or
conventional
gasoline.
Thus,
a
separate
category
for
noncertified
FRGAS
is
not
necessary.

Comment:
As
a
term
of
this
approval,
OMB
recommends
that
EPA
continue
to
monitor
the
burden
and
practical
utility
of
this
collection.
In
particular,
OMB
is
concerned
that
the
collection
of
the
T50
and
T90
parameters
on
the
RFG
and
CG
batch
reports
may
lack
practical
utility.
In
its
renewal
of
this
collection,
EPA
should
carefully
examine
the
practical
utility
of
collecting
these
parameters.
If
EPA
proposes
to
continue
collecting
these
parameters,
the
renewal
ICR
should
provide
documentation
explaining
how
these
parameters
have
been
used
during
the
present
approval
period.

Response:
While
the
Agency
continues
to
believe
that
T50
and
T90
data
are
useful
to
EPA
and
Industry,
the
instructions
have
been
revised
to
indicate
that
they
are
no
longer
required
to
be
reported.
The
Agency
continues
to
monitor
various
trends
in
the
properties
of
gasoline,
and
T50
and
T90
are
some
of
those
properties
which
have
been
identified
in
the
standards
for
gasoline
established
by
the
American
Society
for
Testing
and
Materials
(
ASTM).

Comment:
More
generally,
OMB
notes
that
EPA
standards
for
low­
sulfur
gasoline
will
take
effect
in
2004.
OMB
recommends
that
EPA
evaluate
the
practical
utility
of
this
collection
(
and
the
RFG
program)
in
light
of
the
significant
air
quality
benefits
of
the
Tier
2
low
sulfur
gasoline
program
and
other
existing
or
planed
fuel
regulations.

Response:
While
it
is
true
that
the
sulfur
reduction
of
the
Tier
2
program
bring
about
substantial
reductions
in
Nox,
a
primary
objective
of
Phase
II
fo
the
RFG
program,
there
are
other
important
benefits
from
RFG
that
do
not
overlap
with
other
programs.

S
The
major
VOC
emissions
reductions
brought
about
by
the
RFG
program
are
much
larger
than
those
ensured
by
previously
existing
volatility
control
regulations.

S
The
air
toxics
benefits
of
the
RFG
program(
as
augmented
by
the
Mobile
Source
Air
Toxics
rule)
are
major
benefits
that
would
be
lost
without
RFG.

S
Congress
considered
the
inclusion
of
oxygenates
in
RFG
to
be
important
from
a
number
of
perspectives,
including
that
of
energy
security.

S
The
implementation
and
enforcement
infrastructue
of
the
RFG
program
will
perform
the
same
functions
for
the
Tier
2
sulfur
program.

S
Congress
made
the
RFG
program
a
statutory
requirement,
but
even
absent
such
a
requirement,
the
continuing
unique
benefits
justify
the
program's
continued
existence.

Comment:
OMB
notes
that
EPA
has
recently
issued
a
proposed
rule
that
would
revise
this
collection
to
enhance
refiner
flexibility.
EPA
should
submit
a
separate
ICR
to
OMB
containing
these
revisions.

Response:
Due
to
regulatory
changes,
the
reporting
requirements
with
respect
to
blend
stock
accounting
have
been
deleted.
3
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
Section
211(
k)
of
the
Clean
Air
Act
requires
the
Administrator
to
promulgate
regulations
establishing
requirements
for
RFG
to
be
used
in
gasoline­
fueled
vehicles
in
the
nine
specified
nonattainment
areas,
and
opt­
in
areas.
The
Act
specifically
provides
that
recordkeeping,
reporting,
and
sampling
and
testing
requirements
are
among
the
tools
EPA
may
use
in
enforcement
of
the
provisions,
and
also
provides
that
EPA
must
develop
an
enforceable
scheme.
Sections
114
and
208
of
the
Clean
Air
Act,
42
U.
S.
C.
§
§
7414
and
7542
authorize
EPA
to
require
recordkeeping
and
reporting
regarding
enforcement
of
the
provisions
of
Title
II
of
the
Clean
Air
Act.

Congress
mandated,
at
§
211(
k)(
1),
that
the
RFG
regulations
"
shall
require
the
greatest
reduction
in
emissions
of
ozone
forming
volatile
organic
compounds
(
VOCs)
(
during
the
high
ozone
season)
and
emissions
of
toxic
air
pollutants
(
during
the
entire
year)
achievable
through
the
reformulation
of
conventional
gasoline
.
.
.
."
There
are
also
requirements
for
oxygenate
content,
limitations
on
emissions
of
oxides
of
nitrogen,
benzene
content
and
toxics.
The
Act
also
provides
for
RFG
certification
procedures
and
for
EPA
determination
of
baseline
emission
levels.

The
Act
provides
for
credits
for
some
RFG
parameters,
and
for
the
application
and
transfer
of
such
credits.
The
Act
specifies,
at
§
211(
k)(
7)(
C),
that
regulations
concerning
credits
"
shall
ensure
the
enforcement
of
the
requirements
for
the
issuance,
application
and
transfer
of
the
credits."
The
regulations
must
prohibit
oxygen
and
benzene
credits
to
the
extent
such
credits
would
result
in
average
oxygen
or
benzene
levels
that
exceed
the
levels
that
would
exist
in
the
absence
of
a
credit
program.

The
Act
also
requires,
at
§
211(
k)(
8)(
A),
that
the
Administrator
must
promulgate
"
antidumping
rules
to
ensure
that
gasoline
sold
outside
the
areas
covered
by
the
RFG
requirements
"
does
not
result
in
average
per
gallon
emissions
.
.
.
of
[
various]
pollutants
in
excess
of
such
emissions
of
such
pollutants
attributable
to
gasoline
sold
or
introduced
into
commerce
in
calendar
year
1990
by
that
refiner,
blender,
or
importer."
The
Act
requires
that
the
regulation
prohibit
the
sale
of
CG
in
any
RFG
covered
area,
and
requires
the
segregation
of
CG.

The
purpose
of
the
rule
is
to
implement
the
Congressional
mandate
to
reduce
levels
of
various
pollutants
in
the
control
areas
and
to
prevent
the
increase
of
specified
pollutants
from
CG
in
the
remainder
of
the
country.
Without
the
recordkeeping
and
reporting
requirements
of
the
rule,
Congressional
intent
to
improve
air
quality
with
RFG
would
be
thwarted
because
neither
4
EPA
nor
industry
would
have
sufficient
information
to
monitor
compliance.
Because
the
Act's
requirements
create
a
significant
economic
incentive
for
noncompliance,
noncomplying
fuel
would
likely
be
introduced
into
commerce
on
a
wide­
spread
basis,
but
for
requirements
that
make
it
possible
for
EPA
to
cross­
check
records
of
various
entities
in
order
to
determine
compliance.
Industry
had
expressed
a
desire
for
EPA
to
create
an
enforcement
scheme
that
would
be
effective.
Noncomplying
parties
would
enjoy
a
great
competitive
advantage
if
EPA
could
not
effectively
enforce
the
rule.

2(
b)
Practical
Utility/
Users
of
the
Data
The
collection
of
information
is
necessary
for
the
proper
performance
of
the
functions
of
the
Agency,
and
has
practical
utility.
Section
211(
k)
of
the
Act
specifically
recognizes
the
need
for
recordkeeping,
reporting
and
sampling/
testing
requirements
for
enforcement
of
this
program.
This
is
understandable
given
the
complicated
performance
requirements
and
the
averaging
and
trading
provisions
set
forth
in
the
Act.
These
provisions
make
it
impossible
for
EPA
to
determine
compliance
merely
by
taking
samples
of
gasoline
at
various
facilities,
unlike
some
other
fuels
programs.
Moreover,
in
the
negotiated
regulation
process,
EPA
agreed
to
accept
industry's
desire
for
national
averaging,
credits,
yearly
averaging
periods,
etc.
EPA
cannot
enforce
the
regulations,
as
negotiated,
without
the
recordkeeping
controls
included
in
the
rule,
some
of
which
were
specifically
agreed
to
by
industry
(
e.
g.,
covered
area
sampling
and
testing
surveys
and
quarterly
RFG
refiner
reporting).
For
example,
EPA
believes
the
attest
procedures
(
discussed
later)
have
led
to
discovery
of
significant
violations
and
the
prevention
of
future
violations
and
believes
that
this
process
is
very
important.
Further,
the
World
Trade
Organization
ruled
that
the
original
RFG
regulations
discriminated
against
foreign
refiners.
EPA
revised
the
RFG
regulations
to
be
GATTconsistent
If
EPA
could
not
use
these
enforcement
tools
for
domestic
refineries
it
would
not
be
able
to
use
them
for
foreign
refineries.
This
would
greatly
hinder
EPA's
ability
to
regulate
foreign
refiners.

A
past
fuels
program
involving
credits
(
the
lead
phase­
down
program)
proved
very
difficult
to
enforce,
in
part
because
of
the
lack
of
express
recordkeeping
requirements
other
than
summary
reports,
and
would
have
been
impossible
to
enforce
effectively
without
the
auditing
of
regulated
parties'
records
and
the
regulatory
reporting
requirements.
EPA
was
also
helped
in
that
program
by
the
existence
of
lead­
producers
sales
records
and
reports
and
other
outside
information
that
allowed
EPA
to
cross­
check
refiners'
records
and
reports.
Such
records
exist
for
RFG
only
because
of
the
requirements
of
the
rule.
Enforcement
of
the
lead
phase­
down
program
was
relatively
simple
in
comparison
to
the
RFG
program.
In
the
RFG
program,
it
is
unlikely
that,
in
the
absence
of
specific
record
keeping
requirements,
all
companies,
especially
violators,
would
maintain
the
records
necessary
for
EPA
to
determine
compliance.
This
absence
of
records
would
result
partially
from
normal
business
record
keeping
practices,
as
well
as
sloppy
record
keeping,
and
other
practices
designed
to
withhold
needed
information
from
EPA
and
from
other
industry
entities
in
need
of
information.
5
The
anti­
dumping
provision
of
the
Act
apply
nationally
to
refiners
and
importers.
This
provision,
which
is
based
on
average
emission
characteristics
of
gasoline
in
comparison
with
the
characteristics
of
1990
baseline
gasoline,
would
be
impossible
to
enforce
without
record
keeping
and
reporting
requirements.
However,
the
requirements
are
significantly
less
than
for
RFG
and
almost
all
the
reporting
burden
and
almost
all
the
recordkeeping
burden
is
at
the
refinery
level.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
This
information
collection
request
is
not
unnecessarily
duplicative
of
information
otherwise
reasonably
accessible
to
the
Agency.
The
information
requested
is
not
available
from
other
sources
since
it
is
information
for
a
type
of
product
which
has
not
been
tracked
previously
(
the
RFG
regulations
went
into
effect
January
1,
1995).

3(
b)
Public
Notice
A
Federal
Register
notice
requesting
public
comment
on
this
ICR
was
published
on
Wednesday,
November
19,
2003
(
68
FR
65276).
No
comments
were
submitted
within
the
time
period
established,
and
the
one
late
comment
was
very
general
in
nature,
not
directly
applying
to
this
ICR.

3(
c)
Consultations
The
Agency
has
had
numerous
consultations
with
respondents
on
the
reporting
and
recordkeeping
requirements.
Due
to
the
numerous
requirements,
please
see
the
discussion
accompanying
each
requirement.

3(
d)
Effects
of
Less
Frequent
Collection
Quarterly
reporting
(
required
only
for
RFG
refiners/
importers)
was
an
element
of
the
negotiated
regulation
process.
The
calculations
necessary
for
4
reports
would
all
have
to
be
done
even
if
the
information
were
reported
only
once
per
year.
The
reports
can
be
sent
via
electronic
data
interchange
(
EDI).
The
entities
with
any
reporting
burden
are
large
businesses
(
refiners,
importers
and
oxygenate
blenders).
For
CG,
only
one
report
per
year
and
one
audit
report
are
required.
Where
quarterly
reports
are
required,
as
for
RFG
refiners,
these
entities
will
have
to
be
6
keeping
track
of
compliance
and
credits
as
they
go
anyway.
Sending
the
reports
quarterly
is
a
matter
of
sending
it
in
4
increments
instead
of
1.
Refiners
agreed
to
this
requirement
in
regulatory
negotiations.
Any
less
frequent
reporting
would
make
discovery
and
correction
of
violations
take
a
long
time
from
the
date
of
violation,
possibly
creating
year­
long
violations,
and
would
give
noncomplying
parties
a
competitive
advantage
for
long
periods
of
time.
Less
recordkeeping
burden
would
make
verification
of
compliance
extremely
difficult
or
impossible
and
other
regulated
parties
would
not
have
needed
information
to
be
able
to
monitor
their
own
compliance
and
to
know
what
type
and
amount
of
oxygen
to
add,
etc.

3(
e)
General
Guidelines
Required
records
are
to
be
kept
for
five
years.
Refiners
keep
production
records
for
that
length
of
time
anyway,
although
they
would
perhaps
be
archived.
EPA
believes
that
all
records
required
by
the
regulation
need
to
be
kept
for
at
least
five
years
since
that
is
the
relevant
statute
of
limitations
and
because
Agency
resources
will
not
allow
EPA
to
visit
and
audit
all
regulated
parties
on
a
yearly
basis,
or
probably
even
within
a
3
or
4
year
period.
When
EPA
does
audit,
it
will
be
possible
to
check
for
both
current
and
past
violations
by
that
entity,
helping
to
assure
deterrence
and
prevent
unfair
competitive
advantage
through
cheating.
A
violation
pattern
dating
back
five
years
would
be
reason
for
substantial
penalties,
not
only
because
of
the
competitive
advantage,
but
also
because
of
the
environmental
importance
of
this
program,
which
significantly
reduces
most
of
the
most
significant
air
pollutants
in
major
urban
areas.
Retention
of
records
for
5
years
creates
very
little
new
burden
on
these
entities,
which
generally
keep
such
records
for
several
years
anyway.
Also,
it
is
EPA's
experience
in
other
fuels
programs
that
without
a
requirement
to
keep
records,
some
parties
operating
facilities
where
violations
are
found,
including
retailers,
have
often
not
been
cooperative
in
divulging
identities
of
suppliers
or
information
on
volumes
of
product
received.
Retailers
already
are
required
to
keep
their
transfer
documents
for
up
to
4
or
5
years
under
state
tax
laws
(
CG
area
retailers
are
not
required
to
keep
the
records
at
all).

3(
f)
Confidentiality
Information
claimed
as
confidential
is
handled
in
accordance
with
EPA
Freedom
of
Information
Act
regulations
at
40
CFR
2.
Most
of
the
information
submitted
is
claimed
as
such,
and
the
forms
have
a
simple
check­
off
for
this.
Data
submitted
electronically
are
encrypted.
Hard
copies
are
housed
in
a
secure
area.
Electronic
files
are
in
the
same
area
on
a
secure
database.

3(
g)
Sensitive
Questions
There
are
no
sensitive
questions.
7
4.
THE
RESPONDENTS
AND
THE
INFORMATION
COLLECTED
4(
a)
Respondents/
SIC
Codes
Recordkeeping
and,
in
some
cases,
reporting
are
required
by
the
following
gasoline
marketing­
related
industries:
refiners
(
2911),
importers
(
5172),
terminals
(
5171),
pipelines
(
4613),
truckers
and
other
distributors
(
4212),
and
retailers/
wholesale
purchaser­
consumers
(
5541).
NAICS
codes:
refiners(
324110),
pipelines
(
486910)
and
terminals
(
424710).
Not
all
NAICS
for
the
responsible
reporting
parties
were
found.
These
are,
however,
parties
which
are
obligated
to
report:
importers,
truckers
and
other
distributors
and
retailers/
wholesale
purchaserconsumers
Some
refiners
are
importers
but
that
is
nor
always
the
case.
Many
of
the
required
records
are
generated
and
maintained
currently
in
the
normal
course
of
business.
Without
the
required
records
EPA
would
be
unable
to
enforce
the
Congressionally­
mandated
RFG
and
antidumping
requirements.

4(
b)
Information
Requested
1.
Data
Items
Knowledge
of
the
following
definitions
at
40
CFR
80.2
is
important
for
a
thorough
understanding
of
the
reporting
and
recordkeeping
requirements:

"
Gasoline"
means
any
fuel
sold
in
any
State
(
State
means
a
State,
the
District
of
Columbia,
the
Commonwealth
of
Puerto
Rico,
the
Virgin
Islands,
Guam,
American
Samoa,
and
the
Northern
Mariana
Islands)
for
use
in
motor
vehicles
and
motor
vehicle
engines,
and
commonly
or
commercially
known
or
sold
as
gasoline.

"
Refinery"
means
a
plant
in
the
United
States
at
which
gasoline
or
diesel
fuel
is
produced.

"
Foreign
Refinery"
means
a
refinery
that
is
located
outside
the
United
States.

"
Refiner"
means
any
person
who
owns,
leases,
operates,
controls,
or
supervises
a
refinery.

"
Importer"
means
a
person
who
imports
gasoline,
gasoline
blending
stocks
or
components,
or
diesel
fuel
from
a
foreign
country
into
the
United
States
(
including
the
Commonwealth
of
Puerto
Rico,
the
Virgin
Islands,
Guam,
American
Samoa,
and
the
Northern
8
Mariana
Islands).

"
Gasoline
Blending
Stock
or
Component"
means
any
liquid
compound
which
is
blended
with
other
liquid
compounds
to
produce
gasoline.

"
Reformulated
Gasoline"
means
any
gasoline
whose
formulation
has
been
certified
under
40
CFR
80.40
and
which
meets
each
of
the
standards
and
requirements
prescribed
under
80.41.

"
Conventional
Gasoline"
means
any
gasoline
which
has
not
been
certified
under
40
CFR
80.40.

"
Batch
of
reformulated
gasoline"
means
a
quantity
of
reformulated
gasoline
which
is
homogeneous
with
regard
to
those
properties
which
are
specified
for
reformulated
gasoline
certification.

"
Reformulated
gasoline
credit"
means
the
unit
of
measure
for
the
paper
transfer
of
oxygen
or
benzene
content
resulting
from
reformulated
gasoline
which
contains
more
than
2.1
weight
percent
oxygen
or
less
than
0.95
volume
percent
benzene.

"
Oxygenate"
means
any
substance
which,
when
added
to
gasoline,
increases
the
oxygen
content
of
that
gasoline,
and
complies
with
EPA
restrictions
on
oxygenates.

"
Reformulated
Gasoline
Blendstock
for
Oxygenate
Blending
(
RBOB)"
means
a
petroleum
product
which,
when
blended
with
a
specific
type
and
percentage
of
oxygenate,
meets
the
definition
of
reformulated
gasoline,
and
to
which
the
specific
type
and
percentage
of
oxygenate
is
added
other
than
by
the
refiner
or
importer
of
the
RBOB
at
the
refinery
or
import
facility
where
the
RBOB
is
produced
or
imported.

"
Oxygenate
Blending
Facility"
means
any
facility
(
including
a
truck)
at
which
oxygenate
is
added
to
gasoline
or
blendstock,
and
at
which
the
quality
or
quantity
of
gasoline
is
not
altered
in
any
other
manner
except
for
the
addition
of
deposit
control
additives.

"
Oxygenate
Blender"
means
any
person
who
owns,
leases,
operates,
controls,
or
supervises
an
oxygenate
blending
facility,
or
who
owns
or
controls
the
blendstock
or
gasoline
used
or
the
gasoline
produced
at
an
oxygenate
blending
facility.
9
"
FRGAS
"
("
Foreign
Refinery
Gasoline")
means
gasoline
produced
at
a
foreign
refinery
that
has
been
assigned
an
individual
refinery
baseline
and
that
is
imported
into
the
United
States.

"
Non­
FRGAS"
means
gasoline
that
is
produced
at
a
foreign
refinery
that
has
not
been
assigned
an
individual
refinery
baseline,
gasoline
produced
at
a
foreign
refinery
with
an
individual
refinery
baseline
that
is
not
imported
into
the
United
States,
and
gasoline
produced
at
a
foreign
refinery
with
an
individual
baseline
during
a
year
when
the
foreign
refiner
has
opted
not
to
participate
in
the
FRGAS
program.

"
Certified
FRGAS"
means
conventional
FRGAS
the
foreign
refiner
intends
to
include
in
the
foreign
refinery's
NOx
and
exhaust
toxics
anti­
dumping
compliance
calculations
and
does
include
in
these
compliance
calculations
when
reported
to
EPA.

"
Non­
certified
FRGAS"
means
FRGAS
that
is
not
certified
FRGAS.
Non­
certified
FRGAS
will
be
regulated
through
the
importer.
If
the
importer
classifies
it
as
reformulated
gasoline,
it
will
have
to
meet
the
reformulated
gasoline
requirements.
If
the
importer
classifies
it
as
conventional
gasoline,
it
will
have
to
meet
the
importer's
compliance
baseline
for
conventional
gasoline.

The
reporting
and
recordkeeping
requirements
are
(
cites
refer
to
40
C
FR
part
80
and
the
Question
and
Answer
(
Q&
A)
compilation):

REPORTING
REQUIREMENTS
Company
Registration
­
Registration
is
required
for
any
refiner,
importer,
or
oxygenate
blender
that
produces
or
imports
reformulated
gasoline
(
80.76),
any
refiner
or
importer
that
produces
or
imports
conventional
gasoline
(
80.103),
and
any
foreign
refiner
in
the
FRGAS
program
(
80.94(
c)).
The
information
required
to
be
submitted
is
specified
at
80.76.
See
EPA
Form
3520­
20A,
Reformulated
Gasoline
and
Anti­
Dumping
Company
Registration.
EPA
issues
a
four­
digit
identification
number
for
each
company.
Independent
laboratories
are
requested
to
complete
the
form
so
that
they
can
also
be
assigned
a
four­
digit
identification
number,
thus
facilitating
the
review
of
data
they
submit.

Facility
Registration
­
For
each
refiner,
each
refinery
that
produces
gasoline
must
be
registered.
For
each
oxygenate
blender,
each
oxygenate
blending
facility
which
produces
reformulated
gasoline
must
be
registered.
For
each
importer,
facilities
at
which
gasoline
is
imported
must
be
grouped
for
registration
by
Petroleum
Administration
for
Defense
Districts,
or
must
be
registered
individually
(
80.76,
80.103
and
Q&
A
page
139).
For
each
foreign
refiner,
each
refinery
in
the
10
FRGAS
program
must
be
registered
(
80.94(
c)).
See
EPA
Form
3520­
20B,
Reformulated
Gasoline
and
Anti­
Dumping
Facility
Registration.
EPA
issues
a
five­
digit
identification
number
for
each
facility.

Batch
and
Designation
Report
­
A
report
is
required
for
each
batch
of
RFG
and
each
batch
of
RBOB
(
80.65(
e),
80.75).
(
Each
refiner
or
importer
shall
determine
the
value
of
each
of
the
properties
specified
at
80.65(
e)(
2)(
i)
for
each
batch
it
produces
or
imports
prior
to
the
batch
leaving
the
refinery
or
import
facitlity.)
A
report
is
required
for
each
batch
of
CG
and
each
batch
of
certain
blendstocks
(
80.101(
i),
80.105),
which
are
sampled
and
tested
per
80.101(
i).
A
report
is
required
for
each
batch
of
FRGAS.(
80.94(
c)
and
(
s)).
Each
batch
must
be
designated
as
RFG,
CG,
or
RBOB
in
accordance
with
the
requirements
at
80.65(
d).
RFG
and
RBOB
are
further
designated
as
VOC­
controlled
(
Region
1
or
Region
2)
or
not
VOC­
controlled.
RFG
becomes
self­
certified
when
it
meets
the
standards
at
80.41.
Each
batch
of
imported
gasoline
shall
be
classified
by
the
importer
as
FRGAS
or
non­
FRGAS.
Each
FRGAS
batch
shall
be
classified
by
the
importer
as
certified
FRGAS
or
non­
certified
FRGAS
(
80.94(
o)(
1)).
An
oxygenate
blender
producing
RFG
shall
designate
each
batch
of
RFG
as
meeting
the
oxygen
standard
per­
gallon
or
on
average.
An
oxygenate
blender
producing
conventional
gasoline
or
"
per
gallon"
RFG
is
not
subject
to
this
report.
See
EPA
FORM
3520­
20C,
Reformulated
Gasoline
and
Anti­
Dumping
Batch
Report.
Also
see
EPA
FORM
3520­
20F,
Reformulated
Gasoline
and
Anti­
Dumping
Report
for
Batches
containing
Previously­
Certified
Gasoline.
Also
see
EPA
FORM
3520­
27,
Load
Port/
Port
of
Entry
Independent
Sampling,
Testing
and
Refinery/
Importer
Identification
Form.
Each
batch
is
tested
for
the
parameters
indicated
on
the
forms.

Quarterly
Report
for
Reformulated
Gasoline
­
Any
refiner
or
importer
that
produces
or
imports
any
RFG
or
RBOB,
any
foreign
refiner
that
produces
non­
certified
FRGAS,
and
any
oxygenate
blender
that
produces
RFG
meeting
the
oxygen
standard
on
average,
shall
submit
a
quarterly
report
for
each
refinery
or
oxygenate
blending
facility
at
which
such
RFG,
RBOB,
or
non­
certified
FRGAS
was
produced
and
for
all
such
RFG
or
RBOB
imported
by
each
importer
(
80.75,
80.94(
c)
and
(
s)).
The
report
shall
contain
the
information
specified
in
80.75.
See
EPA
FORM
3520­
20D,
Reformulated
Gasoline
and
Anti­
Dumping
Quarterly
Certification.
This
form
also
accompanies
the
Anti­
Dumping
Program
Annual
Report
discussed
below.
RFG
batch
reports
for
the
quarter
and
CG
batch
reports
for
the
year
are
included
with
this
report.

Annual
Compliance
Designation
­
Each
importer
of
RFG
must
file
an
annual
report
indicating
if
RFG
compliance
will
be
on
an
"
average"
or
"
per
gallon"
basis
for
its
facilities.
The
designation
must
be
the
same
for
each
facility
of
an
importer.
Each
refiner
and
oxygenate
blender
producing
RFG
must
file
this
report
for
each
facility.
However,
unlike
for
an
importer,
the
"
average"
or
"
per
gallon"
option
is
available
for
each
facility.
See
EPA
FORM
3520­
20E,
Reformulated
Gasoline
and
Anti­
Dumping
Annual
Compliance
Designation
­
this
form
no
longer
applies
to
antidumping
See
80.65(
d)(
2)(
v).
11
Conventional
Gasoline
Anti­
Dumping
Program
Annual
Report
­
Any
refiner
for
each
refinery
or
group
of
refineries
at
which
any
conventional
gasoline
is
produced,
any
importer
that
imports
any
conventional
gasoline,
and
any
foreign
refiner
producing
certified
FRGAS,
shall
submit
an
annual
report
containing
the
information
specified
in
80.105.
See
EPA
FORM
3520­
20H,
Anti­
Dumping
Program
Annual
Report
.

Reformulated
Gasoline
Program
Toxics
Emissions
Performance
Averaging
Report
­
Any
refiner
or
importer
that
produced
or
imported
any
reformulated
gasoline
or
RBOB
that
was
to
meet
the
toxics
emissions
performance
standard
on
average
("
average
reformulated
gasoline")
shall
submit,
with
the
fourth
quarterly
report,
a
report
for
each
facility
for
such
averaged
reformulated
gasoline
that
was
produced
or
imported
for
the
year
(
80.75(
e)(
1)).
The
report
shall
contain
the
information
specified
at
80.75(
e)(
2).
See
EPA
FORM
3520­
20I.

Reformulated
Gasoline
Program
Benzene
Content
Averaging
Report
­
Any
refiner
or
importer
that
produced
or
imported
any
reformulated
gasoline
or
RBOB
that
was
to
meet
the
benzene
content
standards
on
average
("
averaged
reformulated
gasoline")
shall
submit
with
the
fourth
quarterly
report
a
report
for
each
facility
for
such
averaged
reformulated
gasoline
that
was
produced
or
imported
during
the
year
(
80.75(
d)(
1)).
The
report
shall
contain
the
information
specified
at
80.75(
d)(
2).
See
EPA
FORM
3520­
20J.

Reformulated
Gasoline
Program
NOx
Emissions
Performance
Averaging
Report
­
Any
refiner
or
importer
that
produced
or
imported
any
reformulated
gasoline
or
RBOB
that
was
to
meet
the
NOx
emissions
performance
standard
on
average
("
averaged
reformulated
gasoline")
shall
submit,
with
the
fourth
quarterly
report,
a
report
for
each
facility
for
such
averaged
reformulated
gasoline
that
was
produced
or
imported
during
the
year
(
80.75(
g)(
1).
The
report
shall
contain
the
information
specified
at
80.75(
g)(
2).
See
EPA
FORM
3520­
20L.

Reformulated
Gasoline
Program
VOC
Emissions
Performance
Averaging
Report
­
Any
refiner
or
importer
that
produced
or
imported
any
reformulated
gasoline
or
RBOB
that
was
to
meet
the
VOC
emissions
performance
standard
on
average
("
averaged
reformulated
gasoline")
shall
submit,
with
the
third
quarterly
report,
a
report
for
each
facility
for
such
averaged
reformulated
gasoline
produced
or
imported
during
the
previous
VOC
averaging
period
(
80.75(
c)(
1).
The
report
shall
contain
the
information
specified
at
80.75(
c)(
1)
and
(
2).
See
EPA
FORM
3520­
20M
.

Reformulated
Gasoline
Program
Averaging
Areas
Report
­
Any
refiner
or
oxygenate
blender
that
produced
or
imported
any
reformulated
gasoline
that
was
to
meet
any
reformulated
gasoline
standard
on
average
("
averaged
reformulated
gasoline")
shall,
for
each
refinery
and
oxygenate
blending
facility
at
which
such
averaged
reformulated
gasoline
was
produced,
submit
with
the
fourth
quarterly
report,
a
report
that
contains
the
identity
of
each
covered
area
that
was
supplied
12
with
any
averaged
reformulated
gasoline
produced
at
each
refinery
or
blended
by
each
oxygenate
blender
during
the
year
(
80.75(
i)).
See
EPA
FORM
3520­
20N.

Reformulated
Gasoline
Program
Credit
Transfer
Summary
Report
­
Any
refiner,
oxygenate
blender,
or
importer,
shall,
for
each
facility,
supply
the
information
specified
at
80.75(
h)
with
the
fourth
quarterly
report,
for
any
oxygen
or
benzene
credits
that
are
transferred
during
the
year.
See
EPA
FORM
3520­
20P.

Reformulated
Gasoline
Program
Oxygen
Content
Averaging
Report
­
Any
refiner,
importer,
or
oxygenate
blender
that
produced
or
imported
any
reformulated
gasoline
that
was
to
meet
the
oxygen
standards
on
average
("
averaged
reformulated
gasoline")
shall
submit,
with
the
fourth
quarterly
report,
a
report
for
each
refinery
and
oxygenate
blending
facility
at
which
such
averaged
reformulated
gasoline
was
produced
and
for
all
such
averaged
reformulated
gasoline
imported
by
each
importer
during
the
year
(
80.75(
f)).
The
report
shall
contain
the
information
specified
at
80.75(
f)(
2).
See
EPA
FORM
3520­
20Q.

Independent
Analysis
(
Sampling
and
Testing)
Reports
­
Any
refiner
or
importer
of
reformulated
gasoline
or
RBOB
shall
engage
an
independent
laboratory
to
carry
out
a
program
of
sample
collection
and
analyses
for
the
reformulated
gasoline
or
RBOB
it
produces
or
imports
(
80.65(
f)).
The
laboratory
shall
submit
quarterly
reports
to
EPA
containing
the
information
specified
in
80.65(
f).
EPA
FORM
3520­
20C
is
also
used
for
this
report.
A
refinery
that
uses
computercontrolled
in­
line
blending
equipment
and
has
received
an
exemption
from
EPA
(
see
the
next
reporting
requirement
concerning
the
necessary
petition
for
the
exemption)
has
a
separate
set
of
requirements,
as
specified
at
80.65(
f),
including
an
annual
report
submitted
by
an
independent
auditor.

In­
line
Blending
Petitions
­
Any
refiner
that
produces
reformulated
gasoline
using
computercontrolled
in­
line
blending
equipment
may
petition
to
be
exempt
from
the
independent
analysis
requirement
directly
above
and
the
requirement
to
obtain
test
results
for
each
batch
prior
to
the
gasoline
leaving
the
refinery
(
80.65(
f)(
4)).
The
petition
shall
contain
the
information
specified
at
80.65(
f)(
4)(
i).

Compliance
Survey
Reports
­
Any
refiner,
oxygenate
blender,
or
importer
of
reformulated
gasoline
or
RBOB
for
which
compliance
with
one
or
more
of
the
standards
is
determined
on
average,
is
required
to
conduct
or
participate
in
compliance
surveys
(
with
samples
procured
from
retail
outlets,
etc.
in
a
covered
area)
and
submit
survey
approval
plans
and
reports
as
specified
in
80.67
and
80.68.

Petitions
by
Refiners,
Importers,
or
Oxygenate
Blenders
Who
Chose
Not
to
Participate
in
13
Compliance
Surveys
but
Wish
to
Achieve
Compliance
for
Benzene
or
Oxygen
on
Average
­
Any
refiner,
importer,
or
oxygenate
blender
may
so
petition
by
submitting
the
information
specified
at
80.67(
a)(
2)(
B).

Attest
Engagement
"
Audit"
Reports
­
Any
refiner
and
importer
of
any
reformulated
gasoline,
conventional
gasoline,
or
RBOB,
any
foreign
refiner
of
FRGAS,
and
any
oxygenate
blender
of
any
RBOB
who
meets
the
oxygen
content
on
average,
shall
have
the
reformulated
gasoline,
conventional
gasoline,
and
RBOB
it
produced,
imported,
or
blended
during
each
calendar
year,
audited
by
an
independent
certified
public
accountant
for
compliance
in
accordance
with
the
requirements
of
40
CFR
part
80,
subpart
F
(
80.65(
h),
80.105(
c)).
Additional
requirements
for
FRGAS
are
at
80.94(
h).
A
report
of
the
compliance
audit
is
to
be
submitted
to
EPA
by
May
31
each
year
for
the
preceding
calendar
year.

Foreign
Refinery
Baseline
Petition
­
Any
foreign
refiner
may
submit
to
EPA
a
petition
for
an
individual
refinery
baseline,
under
80.90
through
80.93
(
80.94(
b)).
Petitions
must
be
submitted
before
January
1,
2002
and
meet
the
requirements
of
80.94
(
b)
and
(
s).

Independent
Third
Party
FRGAS
Reports
­
On
each
occasion
that
FRGAS
is
loaded
onto
a
vessel
for
transport
to
the
United
States,
a
foreign
refiner
shall
have
an
independent
third
party
prepare
and
submit
a
report
to
EPA
in
accordance
with
the
requirements
at
80.94(
f)
and
(
s).
For
each
FRGAS
batch,
the
United
States
importer
shall
submit
a
report
containing
the
information
specified
at
80.94(
o)(
3)
and
developed
by
an
independent
third
party.

Information
Reported
in
Response
to
an
EPA
Audit
­
A
foreign
refiner
which
has
been
audited
by
EPA
may
be
required
to
submit
information
as
specified
at
80.94(
i)
and
(
s).

Petitions
to
Augment
the
Complex
Emission
Model
Through
Vehicle
Testing
­
If
a
refiner,
importer,
or
oxygenate
blender
wishes
to
claim
emissions
benefits
from
gasoline
parameters
not
included
in
the
complex
model,
or
for
a
gasoline
whose
parameters
fall
outside
those
of
the
complex
model,
a
petition
must
be
submitted
in
accordance
with
the
requirements
of
80.48.

Submission
of
a
Report,
Upon
EPA
Request,
of
Records
Required
to
be
Maintained
Under
80.74
or
80.104
­
The
specified
records
shall
be
submitted
to
EPA
upon
EPA
request
(
80.74,
80.104).

Product
Transfer
Documents
(
PTDs)
­
On
each
occasion
when
any
person
transfers
custody
or
title
to
any
reformulated
gasoline
or
RBOB,
other
than
when
gasoline
is
sold
or
dispensed
for
use
in
motor
vehicles
at
a
retail
outlet
or
wholesale
purchaser­
consumer
facility,
the
transferor
shall
provide
to
the
transferee
documents
which
include
the
information
specified
at
80.77.
On
each
14
occasion
when
any
person
transfers
custody
or
title
to
any
conventional
gasoline,
the
transferor
shall
provide
to
the
transferee
documents
which
include
the
information
specified
at
80.106.
On
certain
occasions,
per
80.102(
d)(
2)(
ii),
such
documents
are
required
for
blendstocks
and
must
include
the
information
at
80.106(
b).

Quality
Assurance
Sampling
and
Testing
for
RFG
Oxygenate
Blenders
­
Oxygenate
blenders
who
produce
RFG
are
required
to
develop
the
data
specified
at
80.69.

Voluntary
Quality
Assurance
Programs
by
Parties
in
the
Distribution
System
(
excluding
retailers
and
wholesale
purchaser
consumers)
­
As
a
defense
against
liability
for
violations,
parties
may
perform
a
quality
assurance
program
and
develop
data
as
specified
at
80.79(
c).

Individual
Baseline
Determinations
­
Baselines
must
be
determined
for
newly
registered
domestic
refineries
in
accordance
with
the
requirements
at
80.91.

RECORDKEEPING
REQUIREMENTS
Reformulated
Gasoline
or
RBOB
­
All
parties
in
the
gasoline
distribution
network,
as
described
in
80.74,
shall
retain
the
records
specified
in
80.74
for
five
years
(
80.74).

Conventional
Gasoline
­
Any
refiner
or
importer
shall
retain
records
containing
the
information
specified
in
80.104
for
five
years
(
80.104).

(
ii)
Respondent
Activities
The
following
are
required:

1.
Read
and
comprehend
the
regulations
and
instructions
on
completing
the
forms.

2.
Train
personnel
to
meet
the
requirements,
employing
new
technologies
if
warranted.

3.
Develop
the
information
that
is
not
already
available.

4.
Gather
and
organize
the
information.

5.
Review
the
information,
perform
quality
assurance,
and
take
corrective
action,
if
necessary,
to
meet
the
regulatory
requirements.

6.
Report
the
information
to
EPA,
on
forms
as
appropriate,
and/
or
retain
the
information,
as
15
specified
in
the
regulations.

5.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
following
are
required:

1.
Develop
a
thorough
understanding
of
the
regulatory
requirements.
Prepare
guidance
documents
and
forms.

2.
Convey
the
requirements
in
a
manner
that
is
understandable.
Emphasize
the
benefits
of
submitting
data
electronically.

3.
Respond
to
inquiries.

4.
Provide
access
to
the
regulations,
guidance
documents,
and
forms.

5.
Review
the
submitted
information
prior
to
data
entry
for
compliance
with
submission
requirements.

6.
Contact
the
respondent
when
the
information
has
not
been
submitted
properly
and
provide
guidance
on
correction
of
the
problem.

7.
Maintain
and
refine
hardware
and
software
systems
for
handling
confidential
data
via
hard
copy
and
electronically.

8.
Administer
a
contract
for
data
entry.

9.
Input
information
into
databases
and
store
the
information.

10.
Perform
data
analysis
and
identify
violations.

5(
b)
Collection
Methodology
and
Management
The
information
collection
has
been
developed
by
EPA
offices
that
have
planned
and
allocated
resources
for
the
efficient
and
effective
management
and
use
of
the
information
to
be
collected,
including
the
processing
of
the
information
in
a
manner
which
shall
enhance
the
utility
of
the
information
for
the
Agency
and
the
public.
The
information
collection,
to
the
maximum
extent
practicable,
uses
appropriate
information
technology
to
reduce
burden
and
improve
data
quality,
Agency
efficiency,
and
responsiveness
to
the
public.
16
EPA
has
supplied
forms
and
electronic
formats
for
most
of
the
reporting
requirements.
(
For
some
of
the
requirements,
forms
or
formats
would
be
impractical.
The
information
may
be
submitted
in
a
manner
chosen
by
the
respondent.)
The
forms
use
a
bubble
format
(
a
pencil
is
used
to
darken
circles)
which
facilitates
reporting
for
the
respondent
and
allows
the
forms
to
be
machine­
read
for
data
entry.
Respondents
have
the
option
of
reporting
via
electronic
data
interchange
(
EDI)
for
the
batch
reports.
See
the
EDI
guidance
at
http://
www.
epa.
gov/
oms/
edi
and
http://
www.
epa.
gov.
oms/
fuels/
forms.
Many
have
found
this
to
be
more
convenient
and
costeffective

The
product
transfer
document
information
can
be
included
on
standard
transfer
documentation
customarily
used.
EPA
allows
the
information
to
be
encoded
to
facilitate
reporting
and
save
space.
Detailed
production
documents
are
already
used
and
maintained
by
refiners.
Forms
for
refiner/
importer
testing
are
short,
with
the
minimum
informational
requirements
to
be
able
to
associate
the
test
results
with
a
particular
batch
of
gasoline
and
its
transfer
document.

The
information
is
carefully
reviewed
for
compliance
with
the
requirements.
Most
of
the
information
submitted
to
the
Agency
is
confidential.
It
is
stored
in
a
secure
area
and
on
secure
databases.

5(
c)
Small
Entity
Flexibility
The
information
collection
reduces
to
the
extent
practicable
and
appropriate
the
burden
on
respondents,
including
small
entities.
The
major
reporting
requirements
apply
to
refiners
and
importers
of
gasoline,
which
are
not
small
businesses.
Some
oxygenate
blenders
are
small
businesses.
If
they
are
blending
oxygenate
with
RBOB,
the
reporting
is
simple
and
straightforward.
If
they
are
blending
oxygenate
with
conventional
gasoline,
there
are
no
reporting
requirements.
Other
small
businesses
which
are
covered,
gasoline
distributors,
retailers,
and
wholesale
purchaser
consumers,
have
no
mandatory
requirements
other
than
maintaining
the
transfer
documents,
which
is
already
done
in
the
normal
course
of
business.

6.
ESTIMATING
THE
BURDEN
AND
THE
COST
OF
THE
COLLECTION
6(
a)
and
(
b)
Estimating
Respondent
Burden
and
Costs
17
Estimating
the
burden
is
straightforward.
Most
capital/
start­
up
costs
were
incurred
by
industry
in
1994/
95.
However,
there
is
an
annualized
capital
cost
for
the
equipment
necessary
for
the
batch
testing.
Third
party
activity,
the
transmittal
or
storage
of
product­
transfer
documents,
is
a
customary
business
practice.
For
most
reporting
requirements,
the
only
operating
and
maintenance
(
O&
M)
costs
are
for
copying
and
postage,
or
EDI
transmittal,
estimated
at
$
3
per
report.
However,
some
have
significant
purchased
services
(
PS)
costs,
as
indicated
below.

Three
labor
categories
are
involved:
managerial
(
includes
legal
and
professional
review),
technical,
and
clerical.
According
to
the
Bureau
of
Labor
Statistics,
Employment
Cost
Trends
(
March
1996),
for
all
workers
in
manufacturing
industries,
wages
and
benefits
were:

Wages
and
Benefits
Managerial
$
37.72
per
hour
Technical
$
27.90
per
hour
Clerical
$
16.69
per
hour
Doubling
for
company
overhead
beyond
wages
and
benefits,
employing
a
3%
annual
inflation
factor
to
bring
the
rates
to
2004,
and
for
convenience,
rounding
to
the
dollar,
gives
the
following
rates
for
this
ICR:

Total
Employer
Cost
Managerial
$
96
per
hour
Technical
$
71
per
hour
Clerical
$
42
per
hour
The
labor
mix
for
the
activities
above
will
be
about
the
same
for
each.
It
is
assumed
that
for
each
hour
of
activity
the
mix
will
be
about
0.1
hour
managerial,
0.7
hour
technical,
and
0.2
hour
clerical.
This
gives
an
average
labor
cost
of
about
$
65
per
hour,
which
will
be
used
in
this
ICR.
The
annual
burden
estimates
given
below
are
based
on
the
number
of
reports
received
in
1999,
industry
contact,
and
our
knowledge
of
likely
industry
activity
over
the
next
three
years.
They
are
presented
in
the
same
order
as
above,
but
with
abbreviated
titles.
All
of
the
burden
is
for
reporting.
The
recordkeeping
requirements
are
already
customary
business
practices
and
thus
do
not
add
additional
burden.
The
estimated
respondent
population
is:
75
RFG
refineries,
25
RFG
import
facilities/
facility
groups,
25
RFG
oxygenate
blenders
(
for
a
total
of
125
RFG
respondents),
225
CG
refineries,
50
CG
import
facilities/
facility
groups
(
for
a
total
of
275
CG
respondents),
250
18
pipelines
and
terminals
in
the
RFG
distribution
system
that
conduct
voluntary
quality
assurance
(
QA),
500
truckers
in
the
RFG
distribution
system
that
conduct
voluntary
QA,
19
independent
laboratories,
20
auditors,
and
the
RFG
Survey
Association,
Inc.

ANNUAL
ESTIMATED
REPORTING
BURDENS
(
If
there
is
a
form
associated
with
an
activity,
its
form
number
is
indicated
in
parentheses.
For
most
activities
the
estimate
is
one
hour
per
report.
However,
some
reports
require
considerably
more
time,
as
estimated
below.
Based
on
responses
in
2003,
it
is
estimated
that
about
10%
of
the
RFG
and
CG
batch
reports
will
be
submitted
via
EDI.)

Reporting
Number
of
Reports
per
Hours
per
Labor
Non­
postage
Activity
Respondents
Respondent/
Total
Report/
Total
Costs­$
Other
Costs­$

Company
Registration
10
1/
10
1/
10
$
650
(
A4)

Facility
Registration
20
1/
20
1/
20
$
1,300
(
A5)

Batch
RFG
Reports
125
100/
12,500
1/
12,500
$
812,500
$
3,000,000
(
A6)
($
24K/
resp.)

(
A18)
(
Half
O&
M,

Half
annl.

Cap.
Cost
for
Equipment)

Batch
CG
Reports
275
130/
35,750
1/
35,750
$
2,324,000
$
6,600,000
(
A6)
($
24K/
resp.)

(
A18)
(
Same
as
Above)

Batch
Pre­
Cert.
30
20/
600
1/
600
$
39,000
19
(
A9)

Quarterly
RFG
Cert.
125
4/
500
1/
500
$
32,500
(
A7)

Annual
CG
Cert.
275
1/
275
1/
275
$
18,900
(
A7)

Annual
RFG
Report
125
1/
125
1/
125
$
8,100
(
A8)

Annual
CG
Report
275
1/
275
1/
275
$
17,900
(
A10)

Annual
Toxics
Report
100
1/
100
1/
100
$
6,500
(
A11)

Annual
Benzene
Rpt.
100
1/
100
1/
100
$
6,500
(
A12)

Annual
Nox
Report
100
1/
100
1/
100
$
6,500
(
A13)

Annual
VOC
Report
100
1/
100
1/
100
$
6,500
(
A14)
20
Annual
Areas
Report
100
1/
100
1/
100
$
6,500
(
A15)

Annual
Credit
Rpt.
100
1/
100
1/
100
$
6,500
(
A16)

Annual
Oxygen
Rpt.
100
1/
100
1/
100
$
6,500
(
A17)

Independent
Analysis
Rpt.
100
4/
400
10/
4000
$
260,000
$
2,000,000
(
A6)
(
PS)

For
the
following
activities,
agency­
issued
forms
would
not
be
practical.
The
respondent
chooses
the
format.

Annual
In­
line
Blend
Audit
25
1/
25
10/
250
$
16,300
$
250,000
(
PS)

In­
line
Blend
Petitions
2
1/
2
200/
400
$
26,000
RFG
Survey
Report
125
1/
125
20/
2500
$
162,500
$
6,000
,000
(
PS)

Survey
Exclusion
Petitions
None
expected.
21
RFG
Attest
Engagements
125
1/
125
120/
15,000
$
975,000
$
1,250,000­
PS
CG
Attest
Engagements
275
1/
275
40/
11,000
$
715,000
$
2,750,000­
PS
Foreign
Refinery
Baseline
Petitions
2
1/
2
200/
400
$
26,000
Independent
FRGAS
Reports
10
25/
250
2/
500
$
32,500
Response
to
EPA
Audit
5
1/
5
40/
200
$
13,000
Petitions
to
Augment
Complex
Model
None
expected.

EPA
Request
for
Records
2
1/
2
40/
80
$
5,200
Product
Transfer
Documents
A
customary
business
practice
(
CBP),
no
additional
burden.

QA
for
RFG
22
Oxy
Blenders
25
12/
300
10/
3000
$
195,000
$
125,000
(
PS)

($
5K/
resp.)

Voluntary
QA
by
Parties
in
RFG
Distribution
System
Truckers
500
1/
500
10/
5000
$
325,000
$
500,000
(
PS)

Refineries/

Importers
100
1/
100
10/
1000
$
65,000
$
100,000
(
PS)

Pipelines/

Terminals
250
1/
250
10/
2500
$
162,500
$
250,000
(
PS)

Individual
Baseline
Determinations
1
1/
1
40/
40
$
2,600
TOTALS:

TOTAL
NO.
OF
REPORTS:
53,117
TOTAL
BURDEN
HOURS:
96,625
23
TOTAL
LABOR
COSTS:
$
6,281,950
TOTAL
O&
M
COSTS:
$
4,959,357
TOTAL
PURCHASED
SERVICES
COSTS:
$
13,225,000
TOTAL
ANNUALIZED
CAPITAL
COST
FOR
EQUIPMENT:
$
4,800,000
6(
c)
Estimating
Agency
Burden
and
Cost
The
Agency
activities
listed
in
5(
a)
are
handled
by
a
contractor
for
$
218,000
per
year,
a
GS­
13
Step
5
computer
specialist
for
$
160,000
per
year
(
including
overhead),
a
GS­
13
Step
5
program
analyst
for
$
160,000
per
year,
and
the
equivalent
of
a
GS­
14
Step
5
program
manager
for
$
180,000
per
year.
Annual
cost
for
lease
and
security
of
the
secure
area
where
the
confidential
data
are
stored
and
analyzed
is
estimated
at
$
30,000.
Annual
computer
cost
is
estimated
at
$
30,000.
Thus,
the
annual
estimated
cost
to
the
government
is
$
778,000.
The
total
annual
hours
for
government
employees
are
3
full
time
equivalents
(
FTE)
x
2080
hours/
FTE
=
6,240
hours.

6(
d)
and
(
e)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs,
and
Bottom
Line
Burden
Hours
and
Costs
This
was
incorporated
into
6(
a)
and
(
b).

6(
f)
Reasons
for
change
in
Burden
There
were
minor
adjustments
due
to
deletion
of
reporting
requirements
related
to
blend
stock
accounting,
and
to
fact
that
date
for
submission
of
certain
petitions
had
passed,
so
these
activities
were
expected
to
present
no
further
burden.

6(
g)
Burden
Statement
This
form
is
a
component
of
the
Reformulated
Gasoline
(
RFG)
and
Anti­
Dumping
Program.
Section
211(
k)
of
the
Clean
Air
Act,
as
amended
in
1990,
directs
EPA
to
issue
regulations
that
require
gasoline
to
be
"
reformulated"
in
order
to
burn
more
cleanly.
RFG
is
required
in
the
most
severe
ozone
non­
attainment
areas
of
the
country.
The
Anti­
Dumping
program
helps
ensure
that
the
quality
of
gasoline
in
areas
of
the
country
that
do
not
have
RFG
does
not
degrade.
Data
24
submitted
under
the
RFG
and
Anti­
Dumping
Program
may
be
covered
by
claims
of
business
confidentiality
(
i.
e.,
CBI)
and
is
protected
by
established
Agency
procedures
for
handling
of
CBI,
including
the
procedures
described
in
40
CFR
part
2.

The
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
1.8
hours
per
response.
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;
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.

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
No.
OAR­
2003­
0213,
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
Ave.,
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.
Once
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
No.
OAR­
2003­
0213
and
OMB
control
number
2060­
0277
in
any
correspondence.
