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
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 part 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 part 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 part 79 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 part 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 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 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 was published in the Federal Register (75 FR 5581, February 3, 2010) requesting public comment on the draft ICR. No comments were received.
3(c) Consultations
The Agency has routinely consulted with the manufacturers on the effort to comply with the reporting requirements. Below are the manufactures consulted with for this renewal and the hour estimates they offered.
Innospec Fuel Specialties
Ms. Ann Marie Savini
Regulatory Affairs Administrator
(302) 451-1362
Fuel Additive Manufacturer Notification (EPA Form 3520-13) - 20 minutes
Fuel Additive Manufacturer Annual Report (EPA Form 3520-13A) - 5 minutes
Afton Chemical Corporation
Ms. Mignon P. Robinson
Environmental Engineer
(804) 788-6027
Fuel Additive Manufacturer Notification (EPA Form 3520-13) - 1 hour
Fuel Additive Manufacturer Annual Report (EPA Form 3520-13A) - 5 minutes
Lubrizol Corporation
Dr. Dennis Dishong
Manager, Product Compliance
(440) 347-2307
Fuel Additive Manufacturer Notification (EPA Form 3520-13) - 4 hours
Fuel Additive Manufacturer Annual Report (EPA Form 3520-13A) - 2 minutes
Western Refining Southwest, Inc.
Mr. Ron Weaver
Terminals Supervisor
(505) 632-4185
Fuel Manufacturer Notification for Motor Vehicle Fuel (EPA Form 3520-12) - 30 minutes
Fuel Manufacturer Quarterly Report for Motor Vehicle Gasoline or Diesel Fuel (EPA Form 3520-12Q) - 3 hours
Fuel Manufacturer Annual Report for Motor Vehicle Gasoline or Diesel Fuel (EPA Form 3520-12A) - 1.5 hours
There is a general consensus that updates, such as a change of address, for which there is not a form, average 1 hour
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 part 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 part 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
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, 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: 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 changes. 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
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), EPA 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 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
| File Type | application/msword |
| Last Modified By | Courtney Kerwin |
| File Modified | 2010-06-15 |
| File Created | 2010-06-10 |