  SEQ CHAPTER \h \r 1  			INFORMATION COLLECTION REQUEST (ICR)

				Part A of the Supporting Statement

					(July 2007) 

	IDENTIFICATION OF THE INFORMATION COLLECTION

	1(a)	Title:	Detergent Gasoline:

Certification Requirements for Manufacturers of Detergent Additives;
Requirements for Transferors and Transferees of Detergent Additives;  

Requirements for Blenders of Detergents into Gasoline or Post-refinery
Component;

Requirements for Manufacturers, Transferors, and Transferees of Gasoline
 or Post-refinery Component (40 CFR 80 - Subpart G)

			EPA ICR No. 1655.06, OMB Control No. 2060-0275

	1(b)	Abstract

	Gasoline combustion results in the formation of engine deposits.  The
accumulation of deposits, particularly in the orifices of fuel injectors
and on intake valves,  typically results in increased emissions and
reduced engine performance.  As fuel injectors replaced carburetors in
the 1980's, a number of vehicle manufacturers experienced problems with
deposit formation.  Detergent additives, which had been available for
years to control deposits in carbureted vehicles, were improved to
accommodate the new technology.  However, their use was voluntary and
there were no regulatory standards by which to gauge their
effectiveness.  Congress recognized the importance of effective
detergent additives in minimizing vehicle emissions, and added Section
211(1) in the Clean Air Act Amendments of 1990.  It required gasoline to
contain detergent additives, effective January 1, 1995,  and provided
the Environmental Protection Agency (EPA) with the authority to
establish specifications for such additives.  The regulations at 40 CFR
80 - Subpart G implemented certification requirements for detergents and
imposed a variety of recordkeeping and reporting requirements for
certain parties involved with detergents, gasoline, or post-refinery
component (any gasoline blending stock or any oxygenate which is blended
with gasoline subsequent to the gasoline refining process (PRC)).  All
gasolines must contain certified detergents, with the exception of
research, racing, and aviation gasolines.

	The EPA maintains a list of certified gasoline detergents at  
HYPERLINK www.epa.gov/otaq/regs/fuels. www.epa.gov/otaq/regs/fuels.   As
of June 2007 there were 393 certified detergents and 18 detergent
manufacturers.  Most of the certification activity occurred during the
early years of the program.  In 2006 only 9 detergents were certified. 
During January-June 2007, 1 detergent was certified.

	There are approximately 250 refiners and importers of gasoline, 1350
blenders of detergent into gasoline or PRC, 8000 carriers of gasoline or
PRC, 200,000 gasoline retail outlets, and 100,000 fleet facilities which
handle gasoline.  The program is run by the Transportation and Regional
Programs Division, Office of Transportation and Air Quality, Office of
Air and Radiation, EPA, in Washington, DC.

											

	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 of the toxic air emissions in the
United States.  Gasoline detergents help to minimize emissions. 
Detergents are typically added to gasoline as it is loaded into tank
trucks at terminals.  Section 211(l) of the Clean Air Act (Act) requires
that all gasoline contain effective detergent additives.  Section 114 of
the Act provides EPA with the authority to impose recordkeeping and
reporting requirements if necessary for enforcement of statutory
requirements.  The recordkeeping and reporting requirements for this
program, at 40 CFR 80 - Subpart G, are necessary in order for EPA to
certify detergents, to demonstrate that certified detergents are
effective, to assure that gasoline contains certified detergents at the
minimum concentration (also known as the lowest additive
concentration(LAC)) necessary to be effective, and to deter violations. 
There is no standard test procedure for testing qualitatively and
quantitatively for specific detergents in gasoline, thus necessitating
reliance on recordkeeping and reporting as detergents, gasoline, and PRC
pass through the distribution system.   Blenders of detergent into
gasoline or PRC are required to maintain records that demonstrate that
the LAC is met, on average, each month at each automated blending
facility, and by batch at non-automated facilities.  These records are
known as volumetric additive reconciliation (VAR) records.   There is
economic incentive to violate because uncertified detergents are
typically less expensive, and blending a certified detergent at less
than the minimum specified concentration will also save money.  

	A detergent manufacturer has a variety of options under which it may
certify a detergent.  The primary option is “National Generic
Certification,” which allows the detergent to be used in any gasoline.
 We estimate that over 99% of detergents have been certified under this
option.  Other options include limiting a detergent to a Petroleum
Administrative Defense District (PADD Certification), a specific
gasoline pool (Fuel-specific Certification), or California gasoline
(CARB-based Certification), under California’s detergent certification
rule.  All the options may be found at 40 CFR 80.163.	

	

REPORTING REQUIREMENTS

Detergent Manufacturers

	For each detergent, the detergent manufacturer (includes an importer or
a party which is not the manufacturer but is requesting certification as
a detergent for a product manufactured by another party) is required to:


(1) submit a certification letter to EPA containing a variety of
information concerning the certification testing and options for which
certification is requested (80.161(b)(3), 80.163(c)(1)(iii), 80.164(a));
 

											

(2) submit certification test data, and/or the acceptance criteria a
supplier must meet for detergent reactant materials, upon EPA request
(80.165, 80.162(b)(1)); 

(3) submit a detailed description of the detergent’s composition to
EPA pursuant to the registration requirements for fuel additives at 40
CFR 79,  addressing specific compositional descriptions identified in 40
CFR 80 and the LAC for each certification option
(80.161(b)(1)(i),(ii),(ii)(A), 80.162);  

(4) ship a sample of the detergent and certain information concerning
the sample to EPA, and if requested by EPA, ship an additional sample
(80.161(b)(2), 80.167(d)); 

(5) notify EPA in writing, with supporting data, if there is a change in
the LAC for which the additive is effective (80.161(b)(1)(ii)(C));  

(6) notify, in writing, gasoline manufacturers (includes importers),
detergent blenders, and all others who purchase the detergent, of the
LAC and any use restrictions (80.161(c)); 

(7) submit certain information annually for each fuel-specific
certification option (80.164(c)(3)); 

(8) notify customers if a fuel-specific certification is no longer valid
(80.164(c)(3)(iii)); 

(9) if, upon receipt from EPA of a notice of intent of detergent
disqualification, wishing to respond, submit written comments in an
attempt to demonstrate compliance (80.161(e)(3), (4); and

(10) submit a list of customers to EPA if EPA should issue a final
decision to disqualify a certified detergent (80.161(e)(6)).

Detergent Blenders

	A blender of detergent into gasoline or PRC: 

(1) is required to notify EPA in writing if it intends to use a
detergent at lower than its LAC, and, if requested by EPA, must submit
the data supporting the use of the lower concentration (80.161(d)(1),
(2), (3));  

(2) who has certified under a fuel-specific option, is required to
supply, upon request,  EPA with a sample of the test fuel or with
blendstocks with which to formulate the test fuel (80.167(d)); and

(3) is required to generate VAR records (80.170), and, upon request, to
provide EPA with VAR records and supporting documentation (80.170(g)).

											

Transferors and Transferees

	A transferor of gasoline, detergent, or PRC, including any gasoline
refiner, importer, reseller, distributor, carrier, retailer, wholesale
purchaser-consumer (WPC), oxygenate blender, detergent manufacturer,
distributor, carrier, or blender, shall:

(1) generate or obtain documentation for each shipment and provide this
documentation (product transfer document (PTD)) to the transferee (with
exception of delivery of detergent-additized gasoline to motorists and
small volumes to fleets) identifying the product, its detergent status
if gasoline or PRC, and certain additional information (80.171); and 

(2) as a defense against liability, along with transferees, may
establish quality assurance (QA) procedures that involve the development
of records in addition to those required by the rules (80.169).

Researchers

	A party conducting research on gasoline that does not contain a
certified detergent is required to notify EPA annually, in writing
(80.173(a)(3)).

Racing Gasoline/Aviation Gasoline

	Parties handling racing gasoline or aviation gasoline are required to
generate or transfer PTDs indicating that these products are limited to
those uses (80.173(b)(1)).  Pump stands for racing gasoline or aviation
gasoline must be appropriately labeled if located at a facility that
dispenses gasoline to motor vehicles (80.173(b)(2)).

RECORDKEEPING REQUIREMENTS

	Most records are required to be kept for five years, with exceptions
for certain small businesses and California gasoline (80.164(c)(4),
80.169(c)(8), 80.170(g), 80.171(d)).  This retention period is necessary
in order to provide EPA with adequate time for inspection, is consistent
with the relevant civil statute of limitations, and is consistent with
the retention period for PTDs under the reformulated
gasoline/anti-dumping rules at 40 CFR 80 - Subpart D (except for
retailers in anti-dumping areas).  There is no regulatory burden because
businesses retain such records as a customary business practice.

Detergent Manufacturers	

	For each detergent, the detergent manufacturer is required to maintain
records for: 

(1) the acceptance criteria for suppliers of detergent reactive
materials (80.162(b)(1)); 

(2) the test data for fuel parameters supporting a fuel-specific
certification (80.164(c)(1)); 

(3) the fuel composition survey results, and documentation on test
methods and statistical procedures, used to support a fuel-specific
certification (80.164(c)(4)); 

(4) the certification test (80.165); and 

(5) in order to have an affirmative defense for a potential violation of
the certification program controls and prohibitions, the fourier
transform infrared spectroscopy (FTIR) and related data for each
detergent batch (80.169(c)(4)(i)(C),(D)).

Detergent Blenders	

	A blender of detergent into gasoline or PRC is required to maintain the
VAR records on the use of the detergent (80.170).  Gasoline or PRC 
additized in California is exempt, provided the records required by
California are maintained (80.173(c)).

                                                                        
                                            

Transferors and Transferees	

	Transferors and transferees of gasoline, detergent, or PRC: 

(1) are required to maintain the PTDs for each shipment (80.171); and 

(2) as a defense against liability, may establish QA procedures that
involve retaining records in addition to those required to be retained
by the rules (80.169).  

Researchers	

	A party conducting research on gasoline that does not contain a
certified detergent is required to maintain documentation demonstrating
that the gasoline has been used only for research (80.173(a)(1)).

Racing Gasoline/Aviation Gasoline	

	Parties handling racing gasoline or aviation gasoline are required to
maintain the PTDs for each shipment (80.173(b)(1)).  

	 	

	2(b)	Practical Utility/Users of the Data

	The list of certified detergents is publicly available.  The fuel,
additive, and motor vehicle industries are well aware that gasoline must
contain certified detergents.  The list is monitored by the additive
manufacturers in order to maintain an awareness of competitors. 
Manufacturers and distributors of gasoline, and blenders of detergent
into gasoline, monitor the list to ensure that gasoline contains
certified detergents and that the documentation accompanying gasoline
indicates such.

	Most of the data submitted by the detergent manufacturers are
confidential.  Thus access is restricted to authorized EPA personnel and
authorized contractors.  Review of the data is necessary to determine if
the detergent manufacturer has met the certification requirements for a
specific detergent and can be certified by EPA.  The documentation
accompanying the detergent, with the LAC and any use restrictions, is
used by the detergent blender to ensure proper additization.  PTDs are
monitored by transferors and transferees to ensure that they are
handling legal detergents and gasolines.   VARs are necessary for
detergent blenders to demonstrate that they have additized properly.

	As mentioned above, there is not a method of analyzing gasoline for the
proper level of a certified detergent.  Thus, the records required by
this rule, particularly the VAR and certification records, are essential
in EPA’s monitoring for compliance.

	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

	3(a)	Nonduplication

	The records required here are not available elsewhere.  In many
instances the records are already produced as a customary business
practice.

	3(b)	Public Notice

	The draft ICR was announced in the Federal Register (69 FR 30896, June
1, 2004).  No comments were received.   

3(c)	Consultations

	Certification by the detergent manufacturers, and the development of
VAR and QA records by blenders of detergent into gasoline or PRC,
account for the regulatory burden.  The other burdens discussed above
are minor or customary business practices upon which the regulations did
not impose significant additional burdens.

	As this program has matured, just about all of the applications for
detergent certification now rely on previous vehicle testing.  We
estimate only one application annually is based on new  testing.

	Consultations with detergent manufacturers indicate that they have
become quite familiar with submitting applications based on previous
testing, with burden estimates ranging from one to four hours for
preparation and submittal of the application.  For an application based
on new testing, however, there was a broad range of estimates, from 30
hours to 2000 hours.  We believe that, as with the previous ICR, a
reasonable average continues to be 60 hours for a detergent
certification.

	Consultations with detergent blenders which use automated blending
equipment (the vast majority of blenders) also indicates a  range of
estimated VAR/QA burden, from about 30 to 260 hours per year per
facility.  This is to be expected since there is a wide range in the
size of these facilities and a wide range in the degree of
sophistication utilized in implementing the VAR requirements and
voluntary QA procedures.  The estimate for a detergent blender which
does not use automated equipment is 500 hours per year.  A major reason
for the difference in burden between automated and non-automated
equipment is the VAR period, which may be up to 30 days for automated
equipment, but is by batch for non-automated equipment and calculated
manually.

	3(d)	Effects of Less Frequent Collection

	Certification of an additive is one-time, with the exception of an
annual fuel-property report in the case of a fuel-specific
certification.  (As of June 2007, there were no fuel-specific
certifications, and no indication that any would be forthcoming.)  VAR
records and PTDs are ongoing and necessary for enforcement.  The
generation and transfer of PTDs are customary business practices. 
Researchers using gasoline without a certified detergent are required to
submit a brief annual report on their activities.  EPA believes that the
annual reporting requirements are reasonable and that a less frequent
collection would hamper enforcement.  Thus, less frequent collection is
not a practicable alternative.

	3(e)	General Guidelines

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

	3(f)	Confidentiality

	Most of the information reported to EPA is business confidential and is
governed by the Freedom of Information Act regulations for EPA at 40 CFR
2.

	3(g)	Sensitive Questions

	There are none.

	THE RESPONDENTS AND THE INFORMATION COLLECTED

	4(a)	Respondents/SIC/NAICS Codes

	The respondents are related to the following major group Standard
Industrialization Classification (SIC) codes:

5172 - Petroleum Products

2911 - Petroleum Refining

	The respondents are related to the following major group NAICS codes:

324110 - Petroleum Refineries

324199 - All Other Petroleum and Coal Products Manufacturing

325110 - Petrochemical Manufacturing

325199 - All Other Basic Organic Chemical Manufacturing

424710 - Petroleum Bulk Stations and Terminals

424720 - Petroleum and Petroleum Products Merchant Wholesalers (except
Bulk Stations and                       Terminals)

	4(b)	Information Requested

	Data Items

	

	The information to be reported to EPA and the information to be
retained by the respondents was identified by category and regulatory
cite in section 2 above.  The regulations may be found at
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=19d815bd77aba4a
b7b00672c42b09691&rgn=div5&view=text&node=40:16.0.1.1.9&idno=40#40:16.0.
1.1.9.7.  Please refer to the regulations for a detailed description of
the information requested.

	(ii)       Respondent Activities

	The following are required:

	Read and comprehend the regulatory requirements (Task 1 (T1)).

	Train personnel to meet the requirements, employing new technology and
procedures as necessary (Task 2 (T2)).

	Develop the information that is not already available (Task 3(T3)).		

	Gather and organize the information (Task 4 (T4)).

	Review the information and, if necessary, take corrective action such
that it can be concluded that the regulatory requirements have been met
(Task 5 (T5)).

	Report the information to EPA and/or retain the information in storage,
as specified in the regulations (Task 6(T6)).

	THE INFORMATION COLLECTED–AGENCY ACTIVITIES, COLLECTION METHODOLOGY,
AND INFORMATION MANAGEMENT

	5(a)	Agency Activities

	The following are required:

	Develop a thorough understanding of the regulatory requirements.

	Develop the skills necessary to convey the requirements to the
respondents and others such that it can be comprehended easily.  

	Respond to inquiries on the requirements.

	Provide access to the regulations and the list of certified
detergents..

	Review the reported information.

	Contact the respondent when the information has not been submitted
properly and discuss how the deficiency can be corrected.

	Store the information.

	Enter the information into the database.

	Upon concluding that all requirements have been met, issue a letter to
the manufacturer indicating that the detergent has been certified, and
update the list of certified detergents.

	Maintain rigorous security for the protection of confidential business
information.

	Maintain computer hardware and software.

	Monitor compliance via on-site inspections.

	5(b)	Collection Methodology and Management

	The EPA has not issued forms.  The respondents may submit and store the
information in the format of their choice, including electronically. 
Because most of the information reported to EPA is confidential, it is
housed in an office with an advanced security system.  The computers on
which the data are handled have no linkage outside this office.

	5(c)	Small Entity Flexibility 

	The reporting requirements have been made as simple as practical in
order to minimize the burden on all parties, large and small.  For small
businesses subject to this rule, the vast majority are merely
transporters or retailers of gasoline.  Their only burden is the
transfer and storage of PTDs, which is a customary business practice. 
Transfers of small volumes of additized gasoline to WPCs and other
ultimate consumers are exempt from the PTD requirements (80.171(c)).

	5(d) Collection Schedule

	Reporting only required on occasion.							

	ESTIMATING THE BURDEN AND THE COST OF THE COLLECTION

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

 	Estimating the burden is straightforward.  Capital/start-up costs were
incurred by industry in 1995.  Third party activity, the transmittal or
storage of PTDs, is a customary business practice.  Operating and
maintenance (O&M) costs are in three categories.  First, the on-road
engine testing to demonstrate that the detergent meets the
deposit-control standards is performed at contractor facilities.  The
cost of this testing is about $200,000.  As discussed above, this
testing is being performed for only one new certified detergent each
year, with the other certifications based on previous testing. The
second O&M cost is for copying and postage for the estimated 10
submissions annually for detergent certification and eight submissions
annually for research notification.  At an estimated $10 per submission,
the annual cost is $180.  The third O&M cost is for the storage of the
VAR records at the 1300 automated detergent blending facilities and 50
non-automated detergent blending facilities.  The estimated annual cost
per facility is $100, for a total of $135,000.  Thus, the total annual
O&M cost is $200,000 + $180 + $135,000 = $335,180.

	Three labor categories are involved: managerial (includes legal and
professional review), technical, and clerical.  According to the Bureau
of Labor Statistics, Employer Costs for Employee Compensation (December
2005), for private industry, the following wages and benefits apply:

Wages and Benefits

Managerial	$43.48 per hour

Technical	$43.48 per hour

Clerical	$19.61 per hour

	Adding 3% inflation per year to bring the rates to 2007, doubling for
company overhead beyond wages and benefits, and for convenience,
rounding to the nearest dollar, gives the following rates that will be
used in this ICR:

Total Employer Cost

Managerial	$ 92 per hour

Technical	$ 92 per hour

Clerical	$ 42 per hour

											

Worksheet 1: Detergent Manufacturer Submissions for Certification

	Our review of the submissions indicates a fairly wide range of burden. 
Many submissions are minor changes to existing certified detergents and
are able to rely on previously submitted data.  We estimate that they
require about 4 hours to prepare.  About one out of 10 undergoes the
complete development cycle with estimates of 30 to 2000 hours of burden.

Thus, we continue to believe that the average burden per detergent is
estimated at about 60 hours, with the hours and costs allocated as
follows (we estimate 10 submissions annually (18 manufacturers) for the
next three years):

											

Activity	Management		Technical		Clerical

Read		2 hours/$184		4 hours/$368		1 hour/$42

Train		2 hours/$184		2 hours/$184		1 hour/$42

Develop

data		2 hours/$184		20 hours/$1840	1 hour/$42

Organize 

data		2 hours/$184		4 hours/$368		1 hour/$42

Review	2 hours/$184		10 hours/$920		1 hour/$42

Report or

retain		2 hours/$184		1 hour/$92		2 hours/$84

TOTALS	12 hours/$1104	41 hours/$2706	7 hours/$294	

GRAND

TOTAL	60 hours/$4104

Worksheet 2: VAR and QA by Detergent Blenders with Automated Equipment

	As noted above, respondents indicated a fairly wide range of burden,
from 30 to 260 hours per year per blending facility, for the 1300
facilities nationwide.  The VAR period may be as long as 30 days, but
can be shorter due to changes in detergents, maintenance downtime, etc. 
We believe that a reasonable average burden is 150 hours per year per
facility, representing 15 VAR periods, for a total of 1300 x 15 = 19,500
responses annually.  Thus, the estimated hours and costs per VAR period
are:

Activity	Management		Technical		Clerical

Read		0.1 hour/$9.20 	0.8 hour/$73.60	0.4 hour/$16.80

Train		0.1 hour/$9.20 	0.8 hour/$73.60	0.4 hour/$16.80

Develop

data		0.1 hour/$9.20 	1.4 hour/$128.80	1.33 hour/$55.86

Organize 

data		0.1 hour/$9.20 	0.8 hour/$73.60	1.33 hour/$55.86

Review	0.1 hour/$9.20 	0.8 hour/$73.60	0.73 hour/$30.66

Retain		0.1 hour/$9.20 	0.2 hour/$18.40	0.4 hour/$16.80

TOTALS	0.6 hour/$55.20	4.8 hours/$441.60	4.6 hours/$192.78

GRAND

TOTAL	10 hours/$689.58

Worksheet 3: VAR and QA by Detergent Blenders with Non-automated
Equipment

	There appears to be little blending occurring with non-automated
equipment.  However, since it is done manually, and the VAR is done per
batch, we estimate 500 hours per year for such blenders.  It is
estimated that a blender of this type will do about a thousand batches
per year, or a burden of 0.5 hour per batch.  Using the same labor mix
as Worksheet 2 gives a per batch cost of $34.48.  We estimate that there
are 50 blenders in this category, for a total of 50,000 responses
annually.

Worksheet 4: Notification by Researchers

	We estimate that we will receive eight letters annually from
researchers notifying us that a gasoline without a certified detergent
will be used for research purposes.  Assuming a management official
spent one-half hour on each letter and a clerical person also spent
one-half hour, gives a burden of one hour and $67 per letter.								

	6(c)	Estimating Agency Burden and Cost

	The Agency activities described in section 5(a) are handled by
engineers and scientists at the GS-13 level ($85 per hour, including
overhead).  The program is running smoothly and, as noted above, the
number of requests for certification has decreased from the previous
ICR.  It is estimated that 200 hours are spent annually, for a cost to
the government of $17,000.  Lease, computer, and security costs are
covered in the ICR for the Fuel and Fuel Additive Registration
requirements at 40 CFR 79 (EPA ICR Number 309.11, OMB Control Number
2060-1050), with which this program is closely integrated. 

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

			Bottom Line Burden and Costs

	The following worksheet is based on the above discussions.

Worksheet 5: Annual Industry Burden

Activity		Responses		Hours/Cost		Total Hours/Cost

Detergent

Certification		10			60/$4104		600/$41,040

(18 respondents)

Automated

VAR/QA		19,500			10/$689.58		195,000/$13,446,810

(1300 respondents)

Non-automated

VAR/QA		50,000			0.5/$34.48		25,000/$1,724,000

(50 respondents)

Researcher

Letters			8			1.0/$67.00		8/$536.00

(8 respondents)

TOTALS		69,518					220,608/$15,212,386

(1376 respondents)

	Thus, the net annual burden to industry is 220,608 hours and
$15,212,386, plus $335,180 in O&M costs.

	6(f)	Reasons for Change in Burden

	The previous clearance consisted of 69,538 responses, 221,808 hours,
and $13,277,604 in total costs. The small changes are due to a decrease
in annual certification applications, from 30 to 10, and an update in
labor costs.

											

	6(g)	Burden Statements

	There are no forms on which to
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