  SEQ CHAPTER \h \r 1              		United States Environmental
Protection Agency		

			INFORMATION COLLECTION REQUEST (ICR)

Part A of the Supporting Statement

					(DRAFT - January 2010)

1. 	IDENTIFICATION OF THE INFORMATION COLLECTION

	1(a)	Title:	Registration of Fuels and Fuel Additives:

			Requirements for Manufacturers (40 CFR 79)

			EPA ICR Number 0309.13, OMB Control Number 2060-0150

			Docket ID Number EPA-HQ-OAR-2006-0894

	1(b)	Abstract

	In accordance with the regulations at 40 CFR 79, Subparts A, B, C, D
and F, Registration of Fuels and Fuel Additives, manufacturers of (1)
motor vehicle gasoline, (2) motor vehicle diesel fuel, and (3) additives
for those fuels, are required to have their products registered by the
Environmental Protection Agency (EPA) prior to their introduction into
commerce.  Registration involves providing (1) a chemical description of
the fuel or additive, (2) certain technical and marketing information,
and (3) any health-effects information in company files.  (The portion
of Subpart F requiring the development of health-effects data is covered
by a separate information collection.)  Manufacturers are also required
to submit periodic reports on production and related information.  The
program is run by the Transportation and Regional Programs Division,
Office of Transportation and Air Quality, Office of Air and Radiation. 
The information is used to (1) identify products whose evaporative or
exhaust emissions pose a particular threat to public health, thus
meriting further investigation and/or regulation, (2) ensure that EPA
compositional requirements for unleaded gasoline are met before a
product is registered and introduced into commerce, and (3) maintain a
comprehensive data base of motor vehicle fuel and additive composition. 
Most of the compositional information is confidential.  Lists of
registered fuels and additives are available at
www.epa.gov/otaq/additive.htm.  The information is collected and stored
in hard copy, with most entered into a computer data base.  There are
approximately 500 fuel manufacturers, 1,000 additive manufacturers, 700
registered fuels, and 7,200 registered additives.  These numbers change
daily.  The annual cost to industry is estimated at $2.2 million.  The
annual cost to the government is estimated at $450,000.  	

	

	This program also serves as a vehicle for the administration of the
program for the certification of deposit control/detergent gasoline
additives at 40 CFR 80.  By using this existing registration program the
EPA avoided having to establish an additional registration program for
gasoline detergent additives.  The reporting and recordkeeping
requirements unique to this certification program are covered by a
separate information collection.

	

	In addition, per 30 CFR 75.1901(c), only registered diesel fuel
additives may be used in diesel-powered equipment for underground coal
mining.  Thus the Mine Safety and Health Administration of the
Department of Labor is able to utilize this program. 

2.	NEED FOR AND USE OF THE COLLECTION

	2(a)	Need/Authority for the Collection

	Motor vehicles comprise the major source of air pollution in most urban
areas, and account for about half the toxic air emissions in the United
States.  Congress demonstrated its strong concern for the protection of
public health by providing broad legislative authority to monitor and
regulate fuels, fuel additives, and their emissions.  This registration
program was established by the Air Quality Act of 1967, carried forward
into the Clean Air Act (Act) of 1970, and strengthened in the Act’s
1977 and 1990 reauthorizations.

	Section 211(a) of the Act provides EPA with the authority to designate
any mobile source fuel or additive for registration.  Any fuel or
additive with the potential for a significant emissions impact on the
public would be an appropriate candidate.  Once designated, it may not
be introduced into commerce until it has been registered by EPA. 
Section 211(b) requires, for the purpose of registration, that the
manufacturer provide certain compositional and related information, and
available health-effects data.  Section 211(b) also provides EPA with
the authority to require health-effects testing.  The original
regulations were promulgated by the Department of Health, Education, and
Welfare in 1970, and transferred to the EPA shortly thereafter.  They
ultimately resided at 40 CFR 79 (available at regulations.gov) and were
revised in 1975, 1976, and 1978.  Due to their broad public emissions
exposure, motor vehicle gasolines and diesel fuels, and their additives,
were designated.  Section 211(e) (1977 amendments) directs EPA to
establish health-effects testing requirements, and those regulations
were promulgated in 1994 as Subpart F of 40 CFR 79.  (Changes to the
regulations have reduced the burdens, particularly for small
businesses.)  They are structured into three tiers of requirements for
specific fuel/additive categories.  Tier 1, due in May 1997, required an
emissions characterization and a literature search for health-effects
information on those emissions.  Tier 2, due in May 2000, required
short-term inhalation exposures of laboratory animals to emissions to
screen for adverse health effects.  The regulations also allow for
alternative Tier 2 testing if more appropriate.  The major gasoline
oxygenates and a manganese additive for gasoline have undergone such
alternative testing.  Follow-up studies, if required, would occur under
Tier 3.  (The reporting and recordkeeping requirements of these tiers
are covered by a separate information collection.)  The objective of the
program is to determine if there are any fuels and/or additives whose
evaporative emissions or products of combustion pose a particular danger
to public health or welfare.  Section 211(c) of the Act provides EPA
with the authority to regulate such fuels and additives.  For example,
the use of lead additives in gasoline, gasoline volatility, and the
sulfur content of gasoline and diesel fuel, have been regulated.  In
order to assist the EPA in assessing the extent of public exposure to a
given fuel or additive, the regulations require additive manufacturers
to submit annual reports on production.  Fuel manufacturers are required
to submit quarterly production reports.  The manufacturers are also
required to report annually on any new health effects data they may have
acquired.  Copies of the sections of the Act mentioned above are
available at www.epa.gov/otaq.

	

	Another objective of the program is the review of an unleaded gasoline
additive’s composition for compliance with EPA restrictions.  In order
to protect catalytic converters and other emission control devices,
there are specific compositional limitations.  On a number of occasions
the EPA has informed a manufacturer that its additive could not be
registered until the formulation was modified to comply with those
requirements.

	An added benefit of the program has been the development of a
comprehensive data base of gasoline and diesel fuel/additive
composition.  These data have proven useful in a number of fuels issues,
such as the identification of additives with a high sulfur content.

	2(b)	Practical Utility/Users of the Data

	The lists of registered fuels and additives are available to the public
at www.epa.gov/otaq/additive.htm.  The fuel, additive, and motor vehicle
industries are well aware that gasolines, diesel fuels, and their
additives, must be registered before they may be introduced into
commerce for use in motor vehicles.  A separate list of registered
gasoline detergent additives is also available.  These lists are
frequently requested by consumers and the manufacturers in order to
maintain an awareness of competing products.  In accordance with
regulations promulgated by the Mine Safety and Health Administration,
only registered diesel additives may be used in diesel-powered equipment
for underground coal mining.

	Most of the data have been claimed as business confidential by the
manufacturers.   Thus access is restricted to authorized EPA personnel
and contractors.  The data have been extremely valuable in EPA’s
evaluation of certain fuels issues.  Most notably, the compositional
data required since the program’s inception were instrumental in
establishing the fuel/additive testing categories in the 1994
health-effects testing rules (Subpart F, 40 CFR 79).  If  these data 
indicate a particular threat to public health from the evaporative or
exhaust emissions of a fuel or additive, they will be used to support
regulatory action under section 211(c) of the Act.

	Section 211(f) of the Act prohibits the introduction into commerce of
fuels and additives which are not “substantially similar” to those
used by the vehicle manufacturers in emissions certification (unless a
waiver is granted).  The objective is to protect emission controls from
potentially damaging fuels and additives.  The term “substantially
similar” for unleaded gasoline has been defined via interpretive rule.
 Elemental composition is restricted to carbon, hydrogen, oxygen,
nitrogen, and sulphur.  On a number of occasions additive manufacturers
have attempted to register additives for unleaded gasoline which did not
meet these requirements.  Thus, the registration program has been
instrumental in enforcing requirements that were established
independently of the registration regulations at 40 CFR 79.

	The fuel/additive data base has proven extremely useful in the analysis
of other fuels issues.  For example, the data have been used to assess
the development and use of gasoline detergent additives.

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

	3(a)	Nonduplication

	To our knowledge, this is the only program which requires additive
manufacturers to report the composition of their additives, and gasoline
and diesel fuel manufacturers to report the usage of additives in their
fuels.  It is the only program under which these manufacturers must
develop information on the emissions health effects of their products. 
Production volumes for additives are not reported elsewhere.  Nowhere
else are the production volumes for gasoline and diesel fuels reported
in conjunction with additive usage in those fuels.  Such data are
necessary in order to gauge the extent of public exposure to the
emissions of a fuel, additive, or particular fuel/additive combinations.

	3(b)	Public Notice

	A notice will be published in the Federal Register requesting public
comment on this draft ICR.

	3(c)	Consultations

	The Agency has routinely consulted with the manufacturers on the effort
to comply with the reporting requirements.  See section 6.

	

	The Mine Safety and Health Administration (MSHA), U. S. Department of
Labor, views this program as beneficial in that it will provide
information on the diesel emissions to which underground coal miners are
exposed.  MSHA regulations limit the diesel additives used in
underground coal mining to those that have been registered by EPA.  

	3(d)	Effects of Less Frequent Collection

	Registration of a designated fuel or additive is required only once,
although the manufacturer is required to notify EPA if changes occur in
the information provided.  The quarterly and annual reports for fuel
manufacturers, and annual reports for additive manufacturers, are
appropriate in order to monitor patterns of fuel and additive usage in a
timely manner.  Should the health-effects data indicate that certain
fuel/additive combinations are of concern, their history of usage would
be necessary in order to assess the extent of public exposure.  If these
fuel/additive combinations were to experience a significant increase in
usage, it would be important to know that on a quarterly basis.  

	With refiners and importers reporting their usage of additives
quarterly, the annual production report from the additive manufacturers
remains adequate. If an additive were to experience a dramatic increase
in production, it would be important to have that reported on at least
an annual basis. 

	3(e)	General Guidelines

	All Office of Management and Budget (OMB) guidelines are met.  

	3(f)	Confidentiality

	The availability to the public of information submitted for this
program is governed by the Freedom of Information Act (FOIA) regulations
for EPA at 40 CFR 2, with the exception that all health and safety test
data and other information concerning health and welfare effects,
submitted pursuant to Subpart F, shall be public.  Lists of the
registered fuels and additives are publicly available.

	The majority of the manufacturers consider, for competitive reasons,
the compositional information for their fuels and additives to be
confidential.  EPA’s Office of General Counsel has consistently ruled
that confidentiality is justified when such information has been
requested under the FOIA.

	Because most of the information is confidential, this program is housed
in a separate office protected by a multi-sensor alarm system with
24-hour monitoring.  Access is via a keyfob system for authorized
personnel only.  Paper files are secured in combination lock, fireproof
cabinets with each cabinet requiring its own unique sequence to be
unlocked. 

	Data processing is performed solely on computers in the secure area. 
These computers have no connections outside the secure area and employ
password security measures.

	Contractor personnel handle routine administrative tasks, data input,
and data analysis.

EPA personnel work closely with contractor personnel and handle the
technical review of the data and questions involving regulatory
interpretation.

	3(g)	Sensitive Questions

	There are no sensitive questions.

4.	THE RESPONDENTS AND THE INFORMATION COLLECTED

	4(a)	Respondents/NAICS Codes

	The fuel and fuel additive manufacturers are related to the following
major group North American Industry Classification System (NAICS) codes:

324110 - Petroleum Refineries

324199 - All Other Petroleum and Coal Products Manufacturing

325110 - Petrochemical Manufacturing

325193 - Ethyl Alcohol Manufacturing

325199 - All Other Basic Organic Chemical Manufacturing

	

	4(b)	Information Requested

	(i)       	Data Items

	The following definitions at 40 CFR 79.2 are important to the
understanding of the reporting requirements:

	“Fuel manufacturer” means any person who, for sale or introduction
into commerce, produces, manufacturers, or imports a fuel or causes or
directs the alteration of the chemical composition of a bulk fuel, or
the mixture of chemical compounds in a bulk fuel, by adding to it an
additive, except:

	(1)  A party (other than a fuel refiner or importer) who adds a
quantity of additive(s) amounting to less than 1.0 percent by volume of
the resultant additive(s)/fuel mixture is not thereby considered a fuel
manufacturer.

	(2) A party (other than a fuel refiner or importer) who adds an
oxygenate compound to fuel in any otherwise allowable amount is not
thereby considered a fuel manufacturer.

	“Additive” means any substance, other than one composed solely of
carbon and/or hydrogen, that is intentionally added to a fuel named in
the designation (including any added to a motor vehicle’s fuel system)
and that is not intentionally removed prior to sale or use.

	“Additive manufacturer” means any person who produces,
manufacturers, or imports an additive for use as an additive and/or
sells or imports for sale such additive under the person’s own name.

	Motor vehicle gasolines, motor vehicle diesel fuels, and additives to
those fuels, have been designated at 40 CFR 79.  For the purpose of
registration, the following is required to be submitted by each
manufacturer of a designated fuel (40 CFR 79.11): (See EPA Form 3520-12,
Fuel Manufacturer Notification for Motor Vehicle Fuel, Attachment 1, and
instructions, Attachment 2)



Brand name(s) of the fuel:

2.	Company name;



Company identification number (issued by EPA);

4.	Address;

5.	Type of fuel;

6.	Fuel properties as specified in the regulations;

7.	A list of additives the manufacturer intends to use, additive
manufacturer names,

	purpose-in-use of each additive, and range of additive concentration;  
                       

8.	To the extent known, information on analytical techniques that can be
used to detect the 	presence of the additives listed above in the fuel;

9.	To the extent known to the manufacturer, information on the
mechanisms of action of the 	additives listed, reactions between the
additives and the fuel, emission products, additive 	effects on
emissions, health or welfare effects of additive emission products, and
effects  	of additive emission products on emission controls;

10.	Anticipated sales, in percent, by Petroleum Administration for
Defense Districts;

Yes/no response on if fuel is derived only from conventional petroleum,
heavy oil deposits, coal, tar sands, and/or oil sands:

12.	If applying for a small business provision, annual sales revenue for
the past three years and identification of any parent company;

13.	If not applicable for a small business provision, identification of
membership in a testing group:

Indication of which portions of the form are confidential:

List of attachments:

Assurances that the information is correct, EPA will be notified in
writing if certain information were to change, and that registration
will not be used in advertising to imply government approval;

Signature, date, printed name, title, phone number, fax number, and
e-mail address of signer.

	

	Note that in item 16 above the manufacturer is required to notify EPA
in writing if certain information, listed in the regulations, were to
change.  This usually involves updating the list of additives being
used, and is accomplished with a brief letter.  This will be referred to
later in this ICR as a “fuel notification update.”

	

	For the purpose of registration, the following is required to be
submitted by each manufacturer of a designated fuel additive (40 CFR
79.21): (See EPA Form 3520-13, Fuel Additive Manufacturer Notification,
Attachment 3, and instructions, Attachment 4)

1.	Commercial name(s) of the additive;

2.	Company name and company identification number (issued by EPA);

3.	Address;

4.	Method of use (bulk and/or aftermarket);

5.	Fuels for which the additive is recommended and range of
concentration;

6.	Recommended purpose-in-use of the additive;

7.	Chemical composition of the additive;

8.	Chemical structure of the additive;

9.	To the extent known, impurities at greater 0.1% by weight;

10.	To the extent known, information on analytical techniques that can
be used to detect the 	additive in fuel;

11.	To the extent known to the manufacturer, information on additive
mechanisms of action, 	reactions between the additive and fuel,
identification and measurement of additive 	emission products, effects
of the additive on emissions, toxicity or any other health  	effects of
the additive emission products, and effects on emission controls;

Yes/no response on if the additive is a relable of a currently
registered additive;

Estimated annual production during the third year of production;

Estimated market distribution for the third year of production;

Yes/no response on if the additive is derived only from conventional
petroleum, heavy oil deposits, coal, tar sands, and/or oil sands;

If applying for a small business provision, annual sales revenue for the
past three years and identification of any parent company;

Yes/no response on if the additive is an aerosol, and if so, if applying
for the aerosol provision;

If not applicable for a small business or aerosol provision,
identification of membership in a testing group;

19.	Indication of which portions of the form are confidential;

List of attachments;

21.	Assurances that the information is correct, EPA will be notified in
writing if certain 	information were to change, and that registration
will not be used in advertising to imply 	government approval;

22.	Signature, date, printed name, title, phone number, fax number, and
e-mail address of signer.

 	Note that in item 21 above, the EPA would be notified in writing if
certain information, listed in the regulations, were to change.  This is
accomplished by a brief letter, and involves minor issues such as an
additional name under which the additive will be sold.  This will be
referred to later in this ICR as an “additive notification update.”

	Additive manufacturers are also required to report annually the
following information for each registered additive (40 CFR 79.5(b)):
(See EPA Form 3520-13A, Fuel Additive Manufacturer Annual Report,
Attachment 5, and instructions, Attachment 6, and, if reporting for more
than 16 additives, EPA Form 3520-13B, Supplemental Additive Manufacturer
Annual Report, Attachment 7) 

1.	Company name and company identification number;

2.	Report year;

3.	Type of report (original or resubmission); 

4.	Impurities, if greater than 0.1% by weight, to the extent known;

5.	Any information known to the manufacturer and not previously reported
on mechanisms 	of action, reactions with fuels, emission products, or
emission effects;

6.	Production (volume or weight) for the year for the additive(s);

7.	Indication of which portions of the form are confidential;

8.	Signature, date, printed name, title, phone, fax, e-mail;

9.         Indication if a supplemental report is attached.

	Additive manufacturers who are merely relabeling a registered additive
or blend of registered additives are not required to submit an annual
report, since the information would be covered by the original
manufacturer(s).

	Fuel manufacturers are also required to report quarterly the following
information for each registered gasoline and diesel fuel (40 CFR
79.5(a)(1)): (See EPA Form 3520-12Q, Fuel Manufacturer Quarterly Report
for Motor Vehicle Gasoline or Diesel Fuel, Attachment 8, and
instructions, Attachment 9)

1.	Company name and identification number;

2.	Address;

3.	Fuel identification number;

4.	Report year;

5 	Quarterly production volume;

6.	Quarter;

7.	Brand name of the fuel;

8.	Range of concentration during the quarter for each additive
previously reported for use in the fuel;

9.	Indication of which items are confidential;

10.       Signature, date, printed name, title, phone, fax, e-mail.

	Fuel manufacturers are also required to report annually the following
information for each registered gasoline and diesel fuel (40 CFR
79.5(a)(2)): (See EPA Form 3520-12A,  Fuel Manufacturer Annual Report
for Motor Vehicle Gasoline or Diesel Fuel, Attachment 10, and
instructions, Attachment 11)

1.	Company name and identification number;

2.	Address;

3.	Fuel identification number;

4.	Report year;

5.	Brand names(s);

6.	Fuel properties, to the extent known by the manufacturer;

7.	If not previously reported, information known by the manufacturer on
mechanisms of 	action, reactions between additives and fuels, emission
products, and emission effects;

8.	Indication of which items are confidential;

9.	Signature, date, printed name, title, phone, fax, and e-mail. 

	

	

There are no recordkeeping requirements.

	 (ii)	Respondent Activities

	The following activities are required:

1.	Read or hear the regulations at 40 CFR 79 and the instructions for
each of the 

	applicable forms;

2.	Gather information from company files;

3.	Review the information;

4.	Enter information onto the forms and sign;

5.	If indicated on the forms that additional information is attached,
copy such information;

6.	Transmit the information.

5.	THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION 
METHODOLOGY, AND INFORMATION MANAGEMENT

	5(a)	Agency Activities

	The following activities are required:

1.	Respond to inquiries on the reporting requirements;

2.	Mail copies of the forms/instructions, regulations, list of all
registered additives, list of 	registered gasoline detergent additives,
list of registered diesel additives, and/or list of 	registered fuels
upon request;

3.	Review the forms and other submitted data;

4.	Contact the manufacturer when the information has not been submitted
in accordance  	with the regulations and discuss how the problem can be
resolved;

5.	Store the information in hard copy;

6.	Enter the data submitted on the forms into the database.

7.	Issue a letter to the manufacturer for each fuel and additive that is
registered;

8.	Administer a contract for the day-to-day operation of the
registration program;

9.	Maintain rigorous security for the protection of confidential
business information;

10.	Maintain a record of all confidential business information provided
to the contractor;

11.	Maintain computer hardware and software;

12.	Provide general program oversight.

	5(b)	Collection Methodology and Management

	The manufacturers are completing forms which are very straightforward
and whose basic structure dates back to 1975.  We have not had
complaints on the design of the forms.  

Much of the information is maintained in the normal course of business,
such as the chemical composition of an additive and its annual
production.  For information which may not normally be maintained, such
as mechanisms of reaction, the manufacturer is not required to search
beyond its company files.  EPA and its contractor review the forms and
in some cases the manufacturer must be contacted for clarification or
additional information.  Since most of the information is confidential,
the data are handled exclusively on a physically and electronically
isolated IBM/PC-based local area network using Novell NetWare as an
operating system and running FOXPRO database software as the database
platform.  Data are input and reports generated on workstations located
entirely within the locked facility and connected to the network through
direct connections.  EPA personnel routinely compare the data that have
been entered into the database with hard copy.  The network is not
connected to the Agency’s LAN backbone and has no modem connections. 
The facility is protected by an advanced security system described
earlier.   

	All of the forms and instructions are available for downloading at:  
HYPERLINK "http://www.epa.gov/otaq/regs/fuels/ffarsfrms.htm." 
http://www.epa.gov/otaq/regs/fuels/ffarsfrms.htm.   Manufacturers may
also submit the quarterly and annual reports in the format of their
choice, including on diskette, if they prefer not to use the forms.

	

	5(c)	Small Entity Flexibility

	The reporting requirements have been kept as simple as possible to
minimize the burden on all manufacturers.  EPA is not aware of any
simpler format to provide the chemical descriptions and related
information.  Changes to the regulations in 1997 removed many small
businesses from the program, by excluding those who only add oxygenates
or small amounts of additives to fuels from the definition of a fuel
manufacturer.  For manufacturers who merely relabel additives, which are
usually small businesses, the one-time notification is very simple, and
there are no periodic reporting requirements.

	5(d)	Collection Schedule

	For the manufacturer of a fuel, there is a one-time registration for
the fuel, and an on-occasion requirement to inform the Agency if the
information provided for registration were to change.  There are also
quarterly and annual reports that a fuel manufacturer is required to
submit for the registered fuel.

	For the manufacturer of a fuel additive, there is a one-time
registration for the additive, and an on-occasion requirement to inform
the Agency if the information provided for registration were to change. 
There is also an annual report that the additive manufacturer is
required to submit for the registered additive.

6.	ESTIMATING THE BURDEN AND THE COST OF THE COLLECTION

	6(a) and (b)	Estimating Respondent Burden and Costs

	Estimating the burden is straightforward.  For the most part, the
manufacturer is collecting and reporting information that is available
in the normal conduct of business, such as product composition and
production volume.  Other information, such as health effects data, only
have to be reported if they reside in the company files.  No searching
beyond company files is required.  There are no recordkeeping
requirements.  There are no third party activities.  Thus, there are no
capital/start-up costs.  The only operating and maintenance (O&M) cost
is for copying and postage for each submission.  Instead of including
this in each burden table, a cost of $5.00 per submission will be
included in the total burden estimate.   

	In discussions with fewer than ten fuel and fuel additive
manufacturers, four labor categories were identified as having
involvement: managerial, legal, professional/technical (prof/tech), and
clerical.  According to the Bureau of Labor Statistics, May 2008
National Industry-Specific Occupational Employment and Wage Estimates,
mean wages were:

Wages

Managerial 	$60.42 per hour

Legal		$84.56 per hour

Prof/Tech	$60.05 per hour

Clerical	$17.34 per hour

	Doubling for company overhead and employing a 2% annual inflation
factor to bring the rates to the year 2010, and, for convenience,
rounding up to the nearest dollar, gives the follow rates that will be
used in this ICR:

Total Employer Cost

Managerial	$126 per hour

Legal		$176 per hour

Prof/Tech	$125 per hour

Clerical	$  36 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 0.05
hour managerial, 0.05 hour legal, 0.7 hour professional/technical, and
0.2 hour clerical.  This gives an average labor cost of about $110 per
hour, which will be used in this ICR.  The burden estimates for each
activity are the same as for the previous ICR.  That is, a fuel
manufacturer notification will require 8 hours on average to complete. 
Likewise, the fuel additive manufacturer notification will require 8
hours to complete.  The additive update, fuel update, and additive
annual report each require one hour on average to complete.  The fuel
annual and fuel quarterly reports each require 3 hours on average to
complete.

Cost per Report

Fuel Manufacturer Notification - 8 hours @ $110 = $880

Fuel Notification Update - 1 hour @ $110 = $110

Fuel Additive Manufacturer Notification - 8 hours @ $110 = $880

Additive Notification Update - 1 hour @ $110 = $110

Additive Manufacturer Annual Report - 1 hour @ $110 = $110

Fuel Manufacturer Quarterly Report - 3 hours @ $110 = $330

Fuel Manufacturer Annual Report - 3 hours @ $110 = $330

6(c)	Estimating Agency Burden and Cost

	The Agency activities listed in section 5(a) are handled primarily by
contractor personnel for $174,000 per year.  A part time Senior
Environmental Employee (SEE) is employed at $14,000 per year for data
entry.  Eight hundred twenty square feet of space are leased at $25,000
per year.  Security monitoring is $5,000 per year.  Portions of the
following EPA personnel are involved (with 1.6 overhead factor):

	GS -14 Environmental Engineer (EE), $120K x 1.6=$192K

	GS-13 Chemical Engineer (CE), $100K x 1.6=$160K

	GS-13 Program Analyst (PA), $100K x 1.6=$160K

	GS-13 Computer Specialist (CS), $100K x 1.6=$160K

Worksheet 9: Annual Agency Burden in Full Time Equivalents (FTE’s)

activity		EE		CE		PA		CS

respond to

inquiries		0.1/$19200	0.1/$16000	0		0

mail info		by contractor

review data		0.1/$19200	0.2/$32000	0		0

contact manu.		0		0.1/$16000	0		0

store info		by contractor

enter data		by contractor and Senior Environmental Employee

issue letters		by contractor

contract ad.		0.1/$19200	0		0.2/$32000	0

security		0		0		0.1/$16000	0

record cbi		division clerical support

maintain computer	by contractor 					0.05/$8000

program oversight	0.2/$38400	0.1/$16000	0		0

totals			0.5/$96000	0.5/$80000	0.3/$48000	0.05/$8000	

total			1.35 FTE/$232,000

Total Annual Cost to the Government

Contract		$ 174,000

Part time SEE		$  14,000

Lease			$  25,000

Security		$    5,000

FTE’s			$232,000

Total			$450,000

	Thus, the annual estimated cost to the government is $450,000.  The
total hours are 1.35 FTE x 2080 hours/FTE=2808.

	6(d) and (e)	Estimating the Respondent Universe and Total Burden and
Costs, and 				Bottom Line Burden Hours and Costs

	The following worksheet is based on an inventory of 700 registered
fuels (up from 500 in the previous ICR) and 7,200 registered additives
(up from 5,800 the previous ICR).  Of the additives, about 3,000 are
relabels, so only 7,200-3,000 = 4,200 additives will require annual
reports.  Data for 2009 indicate that EPA is receiving approximately 75
new fuel notifications (down from 100), 200 fuel notification updates
(down from 250), 500 new additive notifications (unchanged), and 200
additive notification updates (down from 300) annually. 

Worksheet 10: Annual Industry Burden

Form			Number		Hours/Cost			Total Hours/Cost

Additive

Notification		500			8.0/$880			4000/$440,000

Additive Update	200			1.0/$110			200/$22,000

Additive Annual	4200			1.0/$110			4200/$462,000

Fuel Notification	75			8.0/$880			600/$66,000

Fuel Update		200			1.0/$110			200/$22,000

Fuel Annual		700			3.0/$330			2100/$231,000

Fuel Quarterly		2800			3.0/$330			8400/$924,000

Totals			8,675						19,700/$2,167,000

	

	Thus, the net burden to industry is 19,700 hours and $2,167,000, plus
8,675 submissions x $5.00 each for copying and postage, or
$43,375+$2,167,000=$2,210,375.  (The net burden for the previous ICR was
$1,411,750.)  The burden is gauged per form.  Some manufacturers have
hundreds of products, some have only one or two.  Per section 6(c), the
annual burden to the government is 2808 hours and $450,000.  It is
recommended that the above costs be increased 2% annually for inflation.

	

	6(f)	Reasons for Change in Burden

	The net burden has increased due to an increase in the number of fuels
and an increase in labor rates.  The following worksheet summarizes the
changes:

Worksheet 11: Changes in Burden - Hours

Form		Previous 	Requested	Change	Reason

additive							

notification	4000		4000		0		

additive 

update		300		200		-100		adjustment

additive 

annual		4300		4200		-100		adjustment

fuel								 

notification	800		600		-200		adjustment

fuel

annual		1500		2100		+600		adjustment

fuel 

quarterly	6000		8400		+2400		adjustment

fuel 

update		250		200		-50		adjustment

totals		17,150		19,700		+2,550

	

	6(g)	Burden Statements

	For the two notification forms, the statement is proposed to read as
follows:

	Burden Statement:  The annual public reporting and recordkeeping burden
for this collection of information is estimated to average 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.  The OMB control numbers for EPA's regulations are
listed in 40 CFR part 9 and 48 CFR chapter 15.     

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID No.
EPA-HQ-OAR-2006-0894, which is available for public viewing at the
Office of Air and Radiation Docket 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
Office of Air and radiation Docket is (202) 566-1742.  An electronic
version of the public docket is available through www.regulations.gov. 
Use the 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,
follow the on-line instructions.  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
Office for EPA.  Please include the EPA Docket ID No.
EPA-HQ-OAR-2006-0894 and OMB control number (2060-0150) in any
correspondence. 

	For the additive annual report form, the statement would be identical,
with the exception that the burden estimate would be one hour.  For the
quarterly and annual fuel report forms, the statement would be
identical, with the exception that the burden estimate would be three
hours.

Attachments (These are not attached.  For access, see the web address in
section 5(b).)

Attachment 1 - EPA Form 3520-12

Attachment 2 - Instructions for EPA Form 3520-12

Attachment 3 - EPA Form 3520-13

Attachment 4 - Instructions for EPA Form 3520-13

Attachment 5 - EPA Form 3520-13A

Attachment 6 - Instructions for EPA Form 3520-13A

Attachment 7 - EPA Form 3520-13B

Attachment 8 - EPA Form 3520-12Q

Attachment 9 - Instructions for EPA Form 3520-12Q

Attachment 10 - EPA Form 3520-12A

Attachment 11 - Instructions for EPA Form 3520-12A

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