Survey

OMB Control number 2050-XXXX

Initial E-mail Contact/Invitation

From: [[email protected]]

To: [UST Compliance Testing Company, hereafter, [COMPANY]]

Cc: [contact@[CONTRACTOR].com]

Subject: EPA Office of Underground Storage Tanks Compliance Testing Data Collection

Dear [NAME],

EPA is conducting a survey to compile data from private companies providing compliance testing to owners of federally regulated underground storage tank systems (USTs). The completed dataset of test results will allow EPA to evaluate the effectiveness of several of the newly required measures to prevent fuel releases included in the 2015 federal UST regulation and help EPA execute national UST program goals and better protect human health and the environment. 

EPA has engaged the support of [CONTRACTOR] to assist with collecting testing data from participating companies. [CONTRACTOR] will work with [COMPANY] to submit data electronically using a standardized reporting form, which will correlate with the information categories requested on the form attached to this email. Alternatively, [COMPANY] will also have the option of electronically submitting raw data for [CONTRACTOR] to compile in the appropriate form on [COMPANY’s] behalf.

[COMPANY] was selected from a list of companies performing UST compliance testing generated by EPA. However, we recognize that this email may not be directed to the appropriate contact at your company. If an alternate individual from [COMPANY] may be better suited to respond, please ‘reply all’ to this message including their name and email address.

This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. (OMB Control No. 2050-XXXX). Responses to this collection of information are voluntary (40 CFR 152.132). 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 annual public reporting and recordkeeping burden for this collection of information is information is estimated to take 21.75 hours per company response. You may send comments regarding the EPA's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to XXXXXX, Program Analyst, Office of Underground Storage Tanks, U.S. Environmental Protection Agency(5401T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Please include the OMB Control No. in any correspondence. Send only comments to this address.

If you would like to assist EPA with this survey, please contact [CONTRACTOR] by email at [contact@[CONTRACTOR].com] (also copied here) or by phone at [XXX-XXX-XXXX].

Thank you in advance for your help,

[EPA Official]

[Signature]

Attachments to this email follow (ICR Part B, Appendix B, Tables 1 and 2):

Table 1: Example matrix of triennially-required testing and inspection data to be collected 

 

Voluntary Submission: Compliance Testing Results Reporting for Three Release Prevention Categories  State-Level Testing Results for State of:______________ Results taken from ___ (insert # of unique facilities at which you performed these tests) in this state Directions: Fill out the form with your compliance testing results. T=Tested; P= Passed Test or Inspection. Please see notes, below.*

Release Prevention Categories (columns, to right)

Spill Prevention

Containment Sumps

Overfill Prevention

Line

Legend:  T=Tested or Inspected P= Passed Test or Inspection.

Component Type **

n/a

n/a

n/a

n/a

n/a

n/a

Flapper valves

Ball Floats

Alarms

Other

1

Reporting Period (rows, below)

Test type*** (columns, to right)

Liquid (PEI RP1200)

Vacuum  (PEI RP1200)

Alternative test procedures

High liquid level/ standard tests  (PEI RP1200)

Low liquid level tests  (PEI RP1200 or EPA/state procedure)

Alternative test procedures

n/a

n/a

n/a

n/a

2

First round of testing (2015 to December 31, 2018)

Component or test type specific average, as appropriate

T:

T:

T:

T:

T:

T:

T:

T:

T:

T:

3

P:

P:

P:

P:

P:

P:

P:

P:

P:

P:

Category Totals

T:

Category Average Pass %

T:

Category Average Pass %

T:

Category Average Pass %

4

P:

P:

P:

Follow-up testing (2019 and on)

Component or test type specific average, as appropriate

T:

T:

T:

T:

T:

T:

T:

T:

T:

T:

5

P:

P:

P:

P:

P:

P:

P:

P:

P:

P:

Category Totals

T:

Category Average Pass %

T:

Category Average Pass %

T:

Category Average Pass %

6

P:

P:

P:

* Provide separate sheets for each state in which you operate. For each category, please report the total number of tests or inspections conducted and the total number of tests or inspections passing, as well as the percentage.

** Component type applies only to overfill prevention inspections. Report these subcategories only if able and interested. If not, you may report in the category averages on lines 4 and 6.

*** Test type applies only to spill prevention and containment sump testing. Report these subcategories only if able and interested. If not, you may report in the category averages on lines 4 and line 6.

Table 2: Example matrix of annually-required leak detection testing data to be collected 

 

Voluntary Submission: Compliance Testing Results Reporting for Two Leak Detection Categories  State-Level Testing Results for State of:______________ Results taken from ___ facilities
*Directions: Fill out the form with your compliance testing results. Please see notes, below. Include information for all years you have available, no earlier than 2015.		Leak Detection
Annual test year (below)	Component tested   (columns, to right)	Line Leak Detector  Performance Standard: able to detect 3 gallon per hour simulated leak rate  Types: includes mechanical (MLLD) and electronic (ELLD)**				Interstitial Sensors  Performance Standard: sensor is triggered  Locations: tank, piping, within containment sumps
2021	Results	Tested:		Average Pass %		Tested:		Average Pass %
		Passing:				Passing:
2020	Results	Tested:		Average Pass %		Tested:		Average Pass %
		Passing:				Passing:
2019	Results	Tested:		Average Pass %		Tested:		Average Pass %
		Passing:				Passing:
2018	Results	Tested:		Average Pass %		Tested:		Average Pass %
		Passing:				Passing:
2017	Results	Tested:		Average Pass %		Tested:		Average Pass %
		Passing:				Passing:
2016	Results	Tested:		Average Pass %		Tested:		Average Pass %
		Passing:				Passing:
2015	Results	Tested:		Average Pass %		Tested:		Average Pass %
		Passing:				Passing:
* Provide separate sheets for each state in which you operate.
** Please include results for both electronic and mechanical line leak detectors as a combined result.

Email Follow-Up

Hello, I’m emailing on behalf of EPA’s Office of Underground Storage Tanks. Recently, EPA sent you an email with a request (copied below) to participate in a survey compiling data from private companies providing compliance testing to owners of federally regulated underground storage tank systems (USTs). The completed dataset of survey results will allow EPA to evaluate the effectiveness of several of the newly required measures to prevent fuel releases included in the 2015 federal UST regulation and help EPA execute national UST program goals and better protect human health and the environment.

We would like [COMPANY’s] assistance with this survey if possible in order to generate as many responses as possible. Could you please let us know if you are willing to participate?

Thank you either way for your response,

[CONTRACTOR], on behalf of EPA Office of Underground Storage Tanks

Phone Follow-Up

Hello, my name is [CONTACT] and I’m calling from [CONTRACTOR], an EPA contractor, on behalf of EPA’s Office of Underground Storage Tanks. I’m contacting you by phone to follow up on some emails EPA and we recently sent about the opportunity to participate in a survey compiling data from private companies providing compliance testing to owners of federally regulated underground storage tank systems (USTs).

Do you recall if your company received the emails?

YES → Great. In the message we asked whether you were an appropriate representative from [AGENCY] to respond to the survey, which requests information about UST compliance testing data collected by your company.If that’s the case we would appreciate it if you could contact us about the survey within the next week. If an alternative respondent is more appropriate could you please provide their name and contact information?

NO → [VERIFY ADDRESS] We will resend the email now. In the email message we ask whether you are an appropriate representative from [COMPANY] to respond to the survey, which requests information about UST compliance testing data. If that’s the case we would appreciate it if you could review the emails and let us know a good time to coordinate your assistance with the survey. If an alternative respondent to decide if [COMPANY] can participate is more appropriate to respond, please reply to the message with their name and contact information.

If you have any questions about the survey, please feel free to contact me at [contact@[CONTRACTOR].com] or [xxx-xx-xxxx].

Thank you for your time.

[SCHEDULE CALLBACK DAY/TIME IF NECESSARY]