             		United States Environmental Protection Agency		
			INFORMATION COLLECTION REQUEST (ICR)
                      Part A of the Supporting Statement
					
1. 	IDENTIFICATION OF THE INFORMATION COLLECTION

	1(a)	Title:	Registration of Fuels and Fuel Additives: Requirements for Manufacturers 			(Renewal)
			EPA ICR Number 0309.14, 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 Compliance 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 may pose a particular threat to public health, thus meriting further investigation and/or regulation, (2) ensure that EPA compositional requirements 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: http://www.epa.gov/otaq/fuels/registrationfuels/registeredfuels.htm.  The information is collected and stored in hard copy, with most entered into a computer data base.  There are approximately 650 fuel manufacturers, 1,200 additive manufacturers, 760 registered fuels, and 7,700 registered additives.  These numbers change frequently.  The annual cost to industry is estimated at $1.9 million.  The annual cost to the government is estimated at $477,000.  	
	
	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, Subpart G.  By using this existing registration program 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 may 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 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.  
	
	Another objective of the program is the review of an additive's composition for compliance with EPA restrictions.  In order to protect catalytic converters and other emission control devices, there are 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 for certain 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 http://www.epa.gov/otaq/fuels/registrationfuels/registeredfuels.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 reviewed 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 valuable in EPA's evaluation of certain fuels issues.  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 (40 CFR 79, Subpart F).  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 sulfur.  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 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  Federal Register notice requesting public comment on this ICR was published on March 15, 2013 (78 FR 16498).  No comments were received.  

	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 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 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.  High-level security is employed.

	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)

1.	Brand name(s) of the fuel:
 2.	Company name;
3. 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;
 

11. 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:
14. Indication of which portions of the form are confidential:
15. List of attachments:
16. 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;
17. 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;

12. Yes/no response on if the additive is a relable of a currently registered additive;
13. Estimated annual production during the third year of production;
14. Estimated market distribution for the third year of production;
15. Yes/no response on if the additive is derived only from conventional petroleum, heavy oil deposits, coal, tar sands, and/or oil sands;
16. If applying for a small business provision, annual sales revenue for the past three years and identification of any parent company;
17. Yes/no response on if the additive is an aerosol, and if so, if applying for the aerosol provision;
18. 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;

20. 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 in a secure environment. 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 facility is protected by an advanced security system.   
 
 	All of the forms and instructions are available for downloading at: http://www.epa.gov/otaq/fuels/registrationfuels/registeredfuels.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 2011 National  Occupational Employment and Wage Estimates, mean wages were:
 
 Wages
 Managerial 	$62.19 per hour
 Legal		$62.74 per hour
 Prof/Tech	$47.81 per hour
 Clerical	$15.34 per hour
 
 	Doubling for company overhead and employing a 2% annual inflation factor to bring the rates to the year 2013, and, for convenience, rounding up to the nearest dollar, gives the follow rates that will be used in this ICR:
 
 Total Employer Cost
 Managerial	$130 per hour
 Legal		$132 per hour
 Prof/Tech	$100 per hour
 Clerical	$  34 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 $90 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 @ $90 = $720
 
 Fuel Notification Update - 1 hour @ $90 = $90
 
 Fuel Additive Manufacturer Notification - 8 hours @ $90 = $720
 
 Additive Notification Update - 1 hour @ $90 = $90
 
 Additive Manufacturer Annual Report - 1 hour @ $90 = $90
 
 Fuel Manufacturer Quarterly Report - 3 hours @ $90 = $270
 
 Fuel Manufacturer Annual Report - 3 hours @ $90 = $270
 
 
       6(c)	Estimating Agency Burden and Cost
 
 	The Agency activities listed in section 5(a) are handled primarily by contractor personnel for about $200,000 per year.  A part time Senior Environmental Employee (SEE) is employed at $15,000 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		$ 200,000
 Part time SEE		$  15,000
 Lease			$  25,000
 Security		$    5,000
 FTE's			$232,000
 Total			$477,000
 
 	Thus, the annual estimated cost to the government is $477,000.  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 760 registered fuels (up from 700 in the previous ICR) and 7,700 registered additives (up from 7,200 the previous ICR).  Of the additives, about 3,500 are relabels, so only 7,700-3,500 = 4,200 additives will require annual reports.  Recent data indicate that EPA is receiving approximately 75 new fuel notifications, 200 fuel notification updates, 500 new additive notifications, and 200 additive notification updates  annually. These are unchanged from the previous ICR.
 
 Worksheet 10: Annual Industry Burden
 Form			Number		Hours/Cost			Total Hours/Cost
 Additive
 Notification		500			8.0/$720			4000/$360,000
 
 Additive Update	200			1.0/$90			200/$18,000
 
 Additive Annual	4200			1.0/$90			4200/$378,000
 
 Fuel Notification	75			8.0/$720			600/$54,000
 
 Fuel Update		200			1.0/$90			200/$18,000
 
 Fuel Annual		760			3.0/$270			2280/$205,200
 
 Fuel Quarterly		3040			3.0/$270			9120/$820,800
 
 Totals			8,975						20,600/$1,854,000
 	
 	Thus, the net burden to industry is 20,600 hours and $1,854,000, plus 8,975 submissions x $5.00 each for copying and postage, or $44,875+$1,854,000=$1,898,875.  (The net burden for the previous ICR was $2,210,375.)  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 $477,000.  It is recommended that the above costs be increased 2% annually for inflation.
 	
 	6(f)	Reasons for Change in Burden
 
 	Despite a small increase in the number of periodic reports, the net cost burden has decreased due to a decrease in some of the 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		200		200		0		
 
 additive 
 annual		4200		4200		0		
 
 fuel								 
 notification	600		600		0		
 
 fuel
 annual		2100		2280		+180		adjustment
 
 fuel 
 quarterly	8400		9120		+720		adjustment
 
 fuel 
 update		200		200		0		
 
 totals		19,700		20,600		+900
 
 	
 	6(g)	Burden Statements
 
 		Burden Statement:  The annual public reporting and recordkeeping burden for this collection of information is estimated to average 2 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), William Jefferson Clinton Building West, Room 3334, 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 docket 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
 
 
 
 
 
 
 
 

