1 United States Environmental Protection Agency IN FORMAT ION COLLECTI ON REQUEST (ICR) Part A of the Supporting Statement 1. ID ENTIFICATION OF THE INFORMATION COLLECTION 1(a) Title: Registration of Fuels and F uel Additives:

Requirements for Manufacturers EPA I CR Number 0 309.1 3 , 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, s ubparts 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 introduc tion 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 deve lopment of health

- effects data is covered b y 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, Of

fice 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 cop y, with most entered into a computer data base. There are approximately 5 0 0 fuel manu facturers, 1,00 0 additive manufacturers, 7 0 0 registered fuels, and 7,2 00 registered additives. These numbers change dail y. The annual cost to industry is estimated at $ 2.2 million. The annual cost to the government is estimated at $ 450,0 00. This p rogram 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 re gistration program for gasoline detergent additives. The reporting and recordkeeping requirements unique to this certification program are covered b y a separate information collection. In addition, per 30 CFR 75.1901(c), onl y 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 COLLECTION2

2(a) Need/Authority for the C ollection 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 b road 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 19 77 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 b y 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 b y the Department of Health, Education, and Welfare in 1970, and transferred to the EPA sho rtly thereafter. They

ultimately

re sided 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 ox ygenates and a manganese additive for gasoline have un dergo ne such alternative testing. Follow

- up studies, if required, would occur under Tier 3. (The reporting and recordkeeping requirements of these tiers are covered b y 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 sul f ur 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 o f 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 cataly tic converters an d 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.3

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 c ontent. 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, an d 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 b y 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 , th e 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 “s ubstantially 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 un leaded gasoline has been defined via interpretive rule. Elemental composition is restricted to carbon, hydrogen, oxygen, nitrogen, and sul f ur. On a number of occasions additive manufacturers have attempted to register additives for unleaded gasoline whic h did not meet these requirements. Thus, the registration program has been instrumental in enforcing requirements that were established independentl y of the registration regulations at 40 CFR 79. The fuel/additive data base has proven extremely useful i n the anal ys is of other fuels issues. For example, the data have been used to assess the development and use of gasoline detergent additives. 3. NONDUPLICATION, CONSUL TATIONS, AND OTHER COLLECTION CRI TERIA 3(a) Nonduplication To our knowledge, this i s 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 for4

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 w as published in the Federal Register (75 FR 5581, February 3, 2010) requesting public comment on th e 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 wi th 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 Annu al 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

- 1 3A)

- 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 Refin ing 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 hours5

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 info rmation provided. The quarterl y 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 quarterl y 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 prod uction, 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 f or this program is governed b y 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 publicl y 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 G eneral 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 b y a multi

- sensor alar m sy stem with 24

- hour monitoring. Access is via a keyfob sy stem for authorized personnel only . Paper files are secured in combination lock, fireproof cabinets with each cabinet requiring its own unique sequence to be unlocked.6

Data processing is perfo rmed 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 anal ys is. EPA personnel work c losely 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) Respond ents/NAI CS Codes The fuel and fuel additive manufacturers are related to the following major group North American Industry

Classification Sy stem (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) In formation Requested (i) Data Items The following definitions at 40 CFR 79.2 are important to the under standing 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 mi xture 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 b y volume of the resultant additive(s)/fuel mixture is not thereb y considered a fuel manufacturer.7

(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, o ther 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 sy stem) 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 3. Company

identi fication number (issued b y EPA) 4. Address 5. Ty

pe 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 anal ytical 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 p roducts, and effects of additive emissio n products on emission controls 10. Anticipated sales, in percent, by Petroleum Admin istration for Defense Districts 11. Yes/no response on if fuel is derived only from conventional petroleum, heavy oil deposits, co al , tar sands, and/or oil sands 12. If appl yi ng for a small business provision, annual sales revenue for the past three ye ars and identification of any parent company 13. If not applicable for a small business provision, identification o f membership in a tes ting group 14. Indication of which portio ns 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 advertisi n g to imply government approval 17. Signature, date, printed name, title, phone number, fax number, and e

- mail address of signer8

Note that in item 16 above , the manufacturer is required to notify EPA in writing if certain information, listed in the regulatio ns, were to change. This usuall y involves updating the list of additives being used and is accomplished with a brief letter. This will be referred to later in this I CR as a “fuel notification update.” For the purpose of registration, the following is required to be submitted by each manufacturer of a designat ed 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

identi fication number (issued b y EPA) 3. Address 4. Method o f 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. Chemi cal composition of the additive 8. Che mical structure of the additive 9. To the extent known, impurities at greater 0.1% by weight 10. To the extent known, information on anal ytical techniques that can be used to detect the additive in fuel 11. To the extent known to the manufa cturer, 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 emis sion products, and effects on emission controls; 12. Yes/no response on if the additive is a relable of a currentl y registered additive 13. Estimated annual production during the third year of production 14. Estimated market distribution f or the third year of production 15. Yes/no response on if the additive is derived onl y from conventional petroleum, heav y oil deposits, co al, tar sands, and/or oil sands 16. If appl yi ng for a small business provision, annual sales revenue for the past three ye ars and identification of any parent company 17. Yes/no response on if the additive is an aerosol, and if so, if app lying for the aerosol provision 18. If not applicable for a small business or aerosol provision, identification o f membership in a testing group 19. Indication of which portio ns 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, EPA would be notified in writing if certain information, listed in the regulations, were to change. This is accomplished by a brie f letter, and involves minor9

issues such as an additional name under which the additive will be sold. This will be referred to later in this I CR as an “additive notification update.” Additive manufacturers are also required to report annually the follow ing information for each regis tered 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 Addi tive Manufactur er Annual Report, Attachment 7). 1. Company

name an d company

identification number 2. Report year 3. Ty

pe of report (original or resubmission) 4. Impurities, if greater than 0.1% by weight, to the extent known 5. Any

information known to th e manufacturer and not previously reported on mechanisms of action, reactions with fuels, emissio n products, or emission effects 6. Production (volume or weight) f or the ye ar for the additive(s) 7. Indication of which portio ns 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 merel y relabeling a registered additive or blend of registered additives are not required to submit an annual report, since the information would be covered b y 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 i dentification number 2. Address 3. Fuel identification number 4. Report year 5 Quarterl y production volume 6. Quarter 7. Brand name of the fuel 8. Range of concentration during the quarter for each additive previous ly 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)

.10

1. Company name and identification number 2. Address 3. Fuel identification number 4. Report ye ar 5. Brand names(s) 6. Fuel properties, to the e xtent known by the manufacturer 7. If not previousl y reported, infor mation known by

the manufacturer on mechanisms of action, reactions between additives and fuels, emission products, and emission effect s 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 fo llowing 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. Revi ew the information 4. Enter info rmation onto the forms and sign 5. If indicated on the forms that additional information is attached, cop y such information 6. Transmit the information
5. THE INFORMATION COLLECTED

-- AGENCY ACTIVITIES, COLLECTION METHODOLO GY, 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 regis tered 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 wi th the regulations and discuss how the problem can be resolved; 5. Store the information in hard cop y; 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. Admin ister 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

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 infor mation is confidential, the data are handled exclusively on a ph ys ically

and electronicall y isolated IBM/PC

- based local area network using Novell NetWare as an operating s ys tem and running FOXPRO database software as the database platform. Data are input and reports generated on workstations located entirel y 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 cop y. The network is no t connected to the Agency ’s LAN backbone and has no modem connections. The facility is protected b y an advanced security sy stem 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 ox ygenates or small amounts of additives to fuels from the definition of a fuel manufacturer. For manufacturers who merel y relabel additives, which are usuall y small bu sinesses, 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 Ag ency if the information provided for registration change s . 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 registration12

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, onl y have to be reported if they reside in the company files. No searching beyond company files is required. There are no recordkeeping req uirements. 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 Employ ment 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 D oubling for company overhead and employing a 2 % annual inflation factor to bring the rates to the ye ar 20 1 0, and, for convenience, rounding up to the nearest dollar, gives the follow rate s that will be used in this I CR. Total Employer Cost Manag erial $ 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. Itis assumed that for each hour of activity

the mix will be about 0.05 hour managerial, 0.0 5 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 I CR. The burden estimates for each activity are the same as for the previous ICR. That is, a fuel m anufacturer 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 to13

complete. The fuel annual and fuel quarterl y reports each require 3 hours on average to complete. Cost per Report Fuel Manufacturer Notification

- 8 hours @ $ 110 = $ 88 0 Fuel Notification Update

- 1 hour @ $ 110 = $ 110 Fuel Additive Manufacturer Notifi cation

- 8 hours @ $ 11 0 = $ 88 0 Additive Notification Update

- 1 hour @ $ 11 0 = $ 11 0 Additive Manufacturer Annual Report

- 1 hour @ $ 11 0 = $ 11 0 Fuel Manufacturer Quarterly Report
- 3 hours @ $ 11 0 = $ 33 0 Fuel Manufacturer Annual Report

- 3 hours @ $ 11 0 = $ 33 0 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 ye ar. A part time Senior Environmental Employee (SEE) is employed at $1 4 ,000 per ye ar 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), $1 20 K x 1.6=$1 92 K GS

- 13 Chemical Engineer (CE), $ 100 K x 1.6=$1 60 K GS

- 13 Program Anal ys t (PA), $ 100 K x 1.6=$1 60 K GS

- 13 Computer Specialist (CS), $ 100 K x 1.6=$1 60 K Worksheet 9: Annual Agency Burden in Full Time Equivalents (FTE’s) activity EE CE PA CS respond to inquiries 0.1/$1 92 00 0.1/$1 600 0 0 0 mail info by

contractor review data 0.1/$1 92 00 0.2/$ 320 00 0 0 contact manu. 0 0.1/$1 600 0 0 0 store info by

contractor14

enter data by

contractor and Senior Environmental Employee issue letters by

contractor contract ad. 0.1/$1 92 00 0 0.2/$ 320 00 0 security 0 0 0.1/$1 60 00 0 record cbi division clerical support maintain computer by

contractor 0.05/$ 80 00 program oversight 0.2/$3 84 00 0.1/$1 60 00 0 0 totals 0.5/$ 96 000 0.5/$ 80 000 0.3/$ 4 80 00 0.05/$ 80 00 total 1.35 FTE/$ 2 3 2, 0 00
Total Annual Cost to the Government Contract $ 174 ,000 Part time SEE $ 1 4 ,000 Lease $ 25,000 Security $ 5,000 FTE’s $ 2 3 2, 0 00 Total $ 450,0 00 Thus, the annual estimated cost to the government is $ 450,0 00. 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 7 0 0 registered fuels (up from 50 0 in the previous ICR) and 7,2 00 registered additives (up from 5,800 the previous I CR). Of the additives, about 3,0 00 are relabels, so only 7,2 00

- 3,0 00 = 4 ,2 00 additi ves will require annual reports. Data for 200 9 indicate that EPA is receiving approximate ly 75 new fuel notifications ( down from 10 0), 2 0 0 fuel notification updates (down from 25 0), 500 new additive notifications (unchanged), and 2 00 additive notification updates ( down from 3 00) annually

. Worksheet 10: Annual Industry Burden Form Number H ours/Cost Total Hours/Cost Additive Notification 500 8.0/$ 88 0 4000/$ 44 0 ,000 Additive Update 2 00 1.0/$ 11 0 2 00/$ 2 2 ,0 0015

Additive Annual 4 2 00 1.0/$ 11 0 4 2 00/$ 462 ,0 00 Fuel Notification 75 8.0/$ 88 0 6 00 /$ 6 6 ,00 0 Fuel Update 2 0 0 1.0/$ 11 0 2 0 0/$ 2 2 ,000 Fuel Annual 7 0 0 3.0/$ 33 0 21 0 0/$ 231 ,0 00 Fuel Quarterl y 2 8 0 0 3.0/$ 33 0 84 00 /$ 924 ,0 00 Totals 8,675 1 9,700 /$ 2,167 ,000 Thus, the net burden to industry is 1 9,70 0 hours and $ 2,167 ,000 , plus 8,675 submissions x $ 5 .00 each for co pying and postage, or $ 43,375 +$ 2,167 ,00 0=$ 2,210,375 . (The net burden for the previous ICR was $1, 411,75 0.) The burden is gauged per form. Some manufacturers have hundreds of products, some have onl y one or two. Per section 6(c), the annual burden to th e government is 2808 hours and $ 450,0 0 0. It is recommended that the above costs be increased 2 % annuall y for inflation. 6(f) Reasons for Change in Burden The net burden has increased due to an inc rease 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 4 000 4000 0 additive update 3 00 2 00

- 100 adjustment additive annual 4 3 00 4 2 00

- 100 adjustment fuel notification 80 0 6 00

- 20 0 adjustment fuel annual 1 5 0 0 21 00 + 60 0 adjustment fuel quarterl y 60 00 84 00 + 24 00 adjustment fuel16

update 25 0 2 0 0

- 5 0 adjustment totals 1 7,15 0 1 9,70 0 +2 ,55 0 6(g) Burden S tatements 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 b y persons to generat e, 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 s ys tems for the purposes of collecting, validating, and verifyi ng information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of info rmation; 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 di splay s 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 I CR under Docket ID No. EPA

- HQ

- OAR

- 200 6

- 0 894 , which is available for public viewing at the Office of A ir 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 holiday s. 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 vie w 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 s ys tem, follow the on

- line instructions . Also, you can send comments to th e 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

- 200 6

- 0 894 and OMB control number 2060

- 0150 in any c orrespondence. 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 th at 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

- 1217

Attachment 2

- Instructions for EPA Form 3520

- 12 Attachment 3

- EPA Form 3520

- 13 Attac hment 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 Attachm ent 10

- EPA Form 3520

- 12A Attachment 11

- Instructions for EPA Form 3520

- 12A