1 

# Draft **I nformation**  **C ollection**  **R equest**  **Supporting Statement**  **P ART**  

## A **OF THE** 

## S **UPPORTING** 

## S**TATEMENT** 

## N **ATIONAL** 

## R **EFRIGERANT** 

## R **ECYCLING AND** 

## E **MISSIONS** 

## R **EDUCTION** 

## P **ROGRAM** 

# 1) **Identification o** **f t**  **he Information Collection Title and Number of the Information Collection**  **a)** This information collection request ( ICR ) is titled “ National Refrigerant Recycling and Emissions Reduction Program”, EPA ICR Number: 1626.13 , Office of Management and Budget ( OMB ) Control Number: 2060 -0256 . 

## Characterization/Abstract **b)** Section 608 of the Clean Air Act (CAA), also known as the National Recycling and Emission Reduction Program (the Program), directs the E nvironmental Protection Agency (EPA) to issue regulations governing the use of ozone - depleting substances (ODS), including chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs), during the maintenance, service, repair, or disposal of air conditioning and refrigeration appliances . The regula tions require persons servicing refrigeration and air - conditioning appliances to observe certain service practices that reduce emissions of ozone depleting refrigerants. The regulations also establish certification programs for technicians, recovery/recycl ing equipmen t, and off-site refrigerant reclaimers. In addition, EPA requires that ozone - d epleting refrigerants contained in appliances be removed prior to disposal of the appliances and that all refrigeration and air - conditioning appliances be provided wi th a servicing aperture that facilitates recovery of the refrigerant. T he Agency requires that substantial refrigerant leaks in appliances be repa ired when they are discovered. These regulations significantly reduce emissions of ozone - depleting refrigerant s, and therefore aid U.S. and global efforts to minimize damage to the ozone layer and the environment as a whole. To facilitate comp liance with and enforcement of S ection 608 regulations, EPA requires reporting and recordkeeping from technicians; technic ian certification programs; equipment testing organizations; refrigerant wholesalers and purchasers; refrigerant reclaimers; refrigeration and air - conditioning appliance owners; and other establishments that perform refrigerant removal, service, or disposa l. OMB previously approved t his collection under ICR Number 1626. 12 . Specific reporting and recordkeeping requirements were initially published May 14, 1993 ( 58 FR 28660 ) and codified at 40 CFR part 82, subpart F (§82.150 et seq. ). Collection of this information was approved through December 31, 2017 .2

EPA is proposing to update the existing requirements under the Program as well as extend them to cover appliances containing hydrofluorocarbons ( HFCs ) and other non - exempt substitute refrigerants. EPA is proposing regulatory changes that affect the reporting and recordkeeping requirements , including: establish ing recordkeeping requirements for the disposal of appliances containing 5 to 50 pounds of refrigerant ; requiring documented leak inspections of certain refrigeration and air conditioning appliance s; requir ing testing and use of self-sealing valve s on small containers of MVAC refrigerant ; and removing outdated recordkeeping and reporting requirements. New records that would be maint ained as part of the proposal include : invoices for servicing events ; results of verification tests; annual and quarterly leak inspection reports ; refrigerant removal at disposal; and self-sealing valve test results. New reporting requirements would include: lists of refr igerant recovery/recycling equipment ; lists of certified technicians ; and expanded opportunity to request extensions to the appliance repair and the appliance retrofit/retire ment requirements . EPA has estimated that there are 1,050,39 0 annual respondents consisting of representatives from the air- conditioning and refrigeration and small can manufacturing community. The annual cost for respondents for the collection and maintenance of records, as well as reports to EPA, is estimated to total $35, 931,685 . 

# 2) **Need For a**  **nd Use o** **f t**  **he Collection Need/Authority for the Collection**  **a)** This proposed information collection is authorized under Section 60 8(a) of the Clean Air Act . This section directs the Administrator to “promulgate regulations establishing standards and requirements regarding the use and disposal” of ozone - depleting substances and to implement Section 608(c) which contains a statutory prohibition against venting of ODS and substitute refrigerants. EPA requires reporting and recordkeeping t o facili tate compliance with and enforcement of the S ection 608 requirements . In addition, EPA’s authority for this rulemaking is supplemented by Section 114 which authorizes the EPA Administrator to require recordkeeping and reporting in carrying out any provision of the CAA. 

## Practical Utility/Users of the Data **b)** The purpose of the collection request is to facilitate compliance with and enforcement of S ection 608 of the CAA by reducing emissions of cla ss I and class II ozone - depleting refrigerants and their substitutes to the lowest achievable level during the service, maintenance, repair, and disposal of appliances. EPA has used and will continue to use these records and reports to ensure that refrigerant releases are minimized during the recovery, recycling, and reclamation processes. Some recordkeeping requirements are to facilitate information sharing between regulated entities to ensure compliance with S ection 608 requirements. Owners/operators of appliances use the information3

provided by service technicians to ensure their systems are not leaking in violation of the regulations. Refrigerant wholesalers use the data provided by service technicians to ensure they are complying with the refrigerant s ale s restriction. Most of the reporting requested from respondents under this ICR are to seek a benefit such as an extension to repairing or retrofitting an appliance leaking in violation of Section 608 requirements or to voluntarily become an organizatio n to test and certify technicians or to test and certify recovery and recycling equipment. 

# 3) **Non -**  **Duplication, Consultations, a**  **nd Other Collection Criteria**  **Non -**  **Duplication a)**  The specific information requested is not currently collected by any other EPA office or any other government agency . 

## Public Notice Required Prior to ICR Submission to OMB **b)** EPA is proposing changes to the existing recordkeeping and reporting requirements covered by this ICR. EPA is requesting comment on this ICR in that proposed rulemaking. 

## Consultations **c)** The burden calculations for this renewal were developed based on information from EPA’s consultations for the previous ICR . EPA previously consulted two refrigerant reclaimers, a refrigerant wholesaler, and two technician certification progr ams. EPA also consulted the California Air Resource Board (CARB) , Autocare Association, and the Automotive Refrigeration Products Institute (ARPI) for the regulatory changes to Section 608 that are reflected in this ICR . 

## Effects of Less Frequent Collectio **n d)**  The proposed information collection requirements are either one -time, an nual, or occasional submissions . All of these reporting requirements are similar to those that exist for ODS refrigerants but would be new for non - exempt substitute refrigerants . Add itionally, EPA is proposing to remove the (1) one -time certification from technicians that they own certified refrigerant recovery equipment , (2) the annual report from programs certifying recovery and/or recycling equipment concerning the equipment they a pprove , and (3) the requirement for refrigerant recovery/recycling equipment testing organizations to submit information to EPA within 30 days of certification of a new model line of refrigerant recovery/recycling equipment .4

The one -time submissions (e.g., applications for approval of technician certification organizations) and annual submissions (e.g., reclaimer annual reports) are required for EPA to track changes in industry and for long-term management of the Program. Occasional submissions, such as requests for extensions to repair, retrofit, or retirement timelines , allow entities flexibility in meeting regulatory requirements. The removal of this reporting requirement may result in non - compliance or higher costs to t he entity (e.g., cost for expedited shipment of a necessary part). 

## General Guidelines **e)** The reporting and recordkeeping requirements do not violate the regulations established by OMB at 5 CFR part 1320.5(d)(2) . 

## Confidentiality **f)** EPA informs respondents that they may assert claims of business confidentiality for any of the information they submit. Information claimed confidential will be treated in accordance with the procedures for handling information claimed as confidential under 40 CFR Part 2, Subpart B, a nd will be disclosed only if EPA determines that the information is not entitled to confidential treatment. If no claim of confidentiality is asserted when the information is received by EPA, it may be made available to the public without further notice to the respondents (40 CFR 2.203). The handling and confidentiality of the reporting requirements for assuring computer data security , preventing disclosure, proper storage, and proper disposal follow EPA's confidentiality reg ulations (40 CFR 2.201 et seq .). 

## Sensitive Questions **g)** None of the reporting or recordkeeping requirements contain sensitive questions. 

# 4) **Respondents a nd Information Requested**  **Respondents / North American Industry Classification System a)**  **(NAICS) Codes** Table 1 list s the NAICS codes potentially affected by the information requirements covered under this ICR . These cate gories generally include owners/operators of industrial process refrigeration, commercial refrigeration, and comfort cooling appliances ; plumbing, heating, and air- conditioning contractors; refrigerant wholesalers; manufacturers and distributors of small cans of automotive refrigerant; refrigerant reclaimers; disposers and recyclers of appliances; and testing and certifying organizations. These listings are not all - inclusive but are consistent with the types of organizations potentially impacted by this I CR .5

**Table 1**  **: NAICS Codes of Potentially Affected Respondents**

**Industry Category NAICS Codes**  **NAICS Code Definition** Agriculture and Crop Support Services 115 Support Activities for Agriculture and Forestry Arts, Entertainment, and Recreation 71 Arts, Entertainment, and Recreation Beverage and Ice Manufacturing 312 Beverage Manufacturing Durable Goods Wholesalers and Dealers 423 Merchant Wholesalers - Durable Goods 441 Motor Vehicle and Parts Dealers Educational Services 611 Educational Services Food M anufacturing 311 Food M anufacturing General Merchandise Stores 452 General Merchandise Stores 453998 All Other Miscellaneous Store Retailers (except

Tobacco Stores) Grocery and Specialty Food Stores 4451 Grocery Stores 4452 Specialty Food Stores 72231 Food Service Contractors Hospitals 622 Hospitals Non -durable Goods Wholesalers and Dealers 424 Merchant Wholesalers – Non - durable Goods Non -food Manufacturing 322 Paper Manufacturing 323 Printing and Related Support Activities 324 Petroleum Manufacturing 325 Chemical Manufacturing 3254 Pharmaceutical Manufacturing 326 Plastics and Rubber Manufacturing 332 Metals Manufacturing 333 Machinery Manufacturing 334 Computer and Electronic Product Manufacturing 336 Transportation Equipment Manufacturing 3391 Medical Equipment and Supplies Manufacturing6 **Industry Category NAICS Codes**  **NAICS Code Definition** 339999 Miscellaneous Manufacturing Office Buildings 511 Publishing Industries (except Internet) 512 Motion Picture and Video Industries 515 Broadcasting 517 Telecommunications 518 Data Processing, Hosting, and Related Services 519 Libraries and Archives 522 Credit Intermediation and Related Activities 524 Insurance Carriers 531 Real Estate 541 Professional, Scientific, and Technical Services 551 Management of Companies and Enterprises 561 Administrative and Support Services 712 Museums, Historical Sites, and Similar Institutions 721 Accommodation 813 Religious, Grantmaking, Civic, Professional, and

Similar Organizations Other Warehousing, Storage, and Transportation 48 Transportation and Warehousing 4931 Warehousing and Storage Refrigerated Warehousing and Storage 49312 Refrigerated Warehousing and Storage Research and Development 5417 Research and Development Utilities 211 Oil and Gas E xtraction 221 Utilities Warehouse Clubs and Supercenters 452910 Warehouse Clubs and Supercenters Reclaimers 325120 Industrial Gas Manufacturing 423930 Recyclable Material Merchant Wholesalers 562920 Materials Recovery Facilities 562212 Solid Waste Landfill 424690 Other Chemical and Allied Products Merchant7 **Industry Category NAICS Codes**  **NAICS Code Definition** Wholesalers Refrigerant Wholesalers 325120 Industrial Gas Manufacturing 424690 Other Chemical and Allied Products Merchant

Wholesalers 42 Wholesale Trade Service Technicians 238220 Plumbing, Heating, and Air-conditioning Contractors Disposal Establishments 562920 Materials Recovery Facilities 562212 Solid Waste Landfill 423990 Other Miscellaneous Durable Goods Merchant

Wholesalers Service Establishments 811310 Commercial Industrial Machinery and Equipment (not Automotive and Electronic) Repair and Maintenance 811412 Appliance Repair and Maintenance Small Can Manufacturers 441310 Automotive Parts and Accessories Stores 325120 Industrial Gas Manufacturing Certifying Organizations 541380 Environmental Test Laboratories and Services 

## Information Requested **b)** A ll records pursuant to this ICR must be available onsite at the respondents' place of business for a minimum of three years. Entities may submit reports electronically to 608reports@epa.gov or by mail to: Section 608 Program Manager; Stratospheric Protection Division; Mail Code: 6205T; U.S. Environmental Protection Agency; 1200 Pennsylva nia Avenue, NW; Washington, DC 20460. 

### 1. **Refrigerant Recovery/Recycling Equipment Testing Organizations**  The data items required by organizations that test and certify refrigera nt recovery/recycling equipment are specified in 40 CFR 82.16 0(a ) , (b), and (e). i) Data Items

 Application for approval by EPA to certify refrigerant recovery/recycling equipment (as applicable). Information includes:8



###  List refrigerant recovery/recycling equipment present at the organization that will be used for testing; 

###  Verification of expertise in refrigerant recovery/recycling equipment testing and the technical experience of the organization's personnel; 

###  Verification of the organization’s knowledge of the standards and recordkeeping and reporting requirements in 40 CFR Part 82, S ubp art F; and 

###  Description of the organization’s program for verifying the performance of certified recycling and recovery equipment manufactured over the long term, specifying whether retests of equipment or inspections of equipment at manufa cturing facilitie s will be used; 

###  Verification that the organization has no conflict of interest and receives no direct or indirect financial benefit from the outcome of certification testing; and 

###  Agreement to allow EPA access to records and personnel to verify the informa tion contained in the application .  Records of refrigerant recovery/recycling eq uipment testing and performance .  Annual list of certified refrigerant recovery/recycling equipment .  Notice of when a model of refrigerant recovery/recycling equipment fails a three -year recertification test. ii) Respondent Activities  Prepare and submit an application for refrigerant recovery/recycling equipment testing approval .  Retain records of recovery/recycling equipment testing and performance and refrigerant recovery/recycling equipment that meets EPA standards .  Notify EPA within 30 days of retesting or inspection if equipment previously certified fails the periodic re -test required by the regulation .  P ublish online a list of all certified equipment that includes the name of the manufacturer and the name or serial number of the model line and update the list annually. 

### 2. **Reclaimers** The data items required by reclaimers are specified in 40 CFR 82.164(d). i) Data Items  Application for reclaimer certification by EPA, including a certification that the reclaimer will: 

###  Reclaim refrigerant to all the specifications in A ppendix A of S ubpart F that are applicable to that refrigerant;9



###  Verify that each batch of refrigerant reclaimed meets these specifications using the analytical method ology prescribed in A ppendix A; 

###  Release no more than 1.5 percent of the refrigerant during the reclamation process; 

###  Dispose of wastes from the reclamation process in accordance with all applicable laws and regulations; and 

###  Main tain records and submit repo rts.  Records of the analysis conducted to verify that reclaimed refrigerant meets the necessary specifications .  Records on the quantity of material sent for reclamation, the amount reclaimed, waste products from the reclamation process, and custom er and sa les records.  Annual reports noting the total annual quantity of material (the combined mass of refrigerant and contaminants) by refrigerant type sent to them for reclamation , the mass of refrigerant reclaimed by refrigerant type, and the mass of waste products produced. ii) Respondent Activities

 Prepare a one -time application to certify that they will meet the requirements of 40 CFR 82.164.  Maintain records of analyse s conducted to verify that reclaimed refrigerant meets the nece ssary specifications.  M aintain records of the names and addresses of persons sending material for reclamation and the quantity of the material (the combined mass of refrigerant and contaminants) by refrigerant type sent to them for reclamation.  Prepare and s ubmit to EPA annual reports detailing the quantity of each refrigerant sent for reclamation (the combined mass of refrigerant and contaminants) , the mass of each refrigerant reclaimed, and the mass of waste products .  N otify EPA within 30 days of a change in business management, location, or contact information . 

### 3. **Refrigerant Wholesalers** The data items required by refrigerant wholesalers are specified in 40 CFR 82.154( c ) (3) . i) Data Item

 Refrigerant sales records that indicate the name of the purchaser, the date of sale, the quantity, and that the purchaser is a certified technician (as applicable). ii) Respondent Activities  Retain i nvoices from refrigerant sales.10



### 4. **Technician Certification Programs** The data items required by technician certification programs are specified in 40 CFR 82.161(b) . i) Data Items  Application for technician certification approval by EPA. Application will verify: 

###  A bility to produce multiple versions of examinations for each test site; 

###  S ufficient internal capacity to process the scoring and the acco mpanying documentation; and 

###  A bility to ensure the confidentiality and security of test questions and answers.  Records of the names and addresses of all individuals taking the tests, the scores of all certification tests administered, and the dates and locations of all testing administered. These records must be retained indefinitely.  List of technician certified through the program , including: 

###  First name, middle initial, and last name of the technician; 

###  Technician’s city of residence when taking the test; 

###  Type(s) of certification received; and 

###  Date each certification was completed.  Biannual (2x/year) reports on pass/fail rates and the next year’s testing schedule. ii) Respondent Activities  Prepare and submit applicat ion for technician certification.  Maintain records of testing events, scores of certification tests, and th e dates and locations of tests.  Maintain and publish online lists of technic ians certified through programs after January 1, 2017 .  Prepare and submit reports to EPA every six months on the pass/fail rate and testing schedules.  Prepare and send certification cards to technicians who pass the exam .  Organizations that stop certifying technicians must transfer their records to another certifying program or EPA. Organizations that receive those records must inform EPA within 30 days. 

### 5. **Disposal Establishments** The data items required by disposal establishments are specified in 40 CFR 82.155(c) . i) Data Item11

 Copies of signed statements attesting that refrigerant has been recovered prior to the disposal of each appliance or copies of a contract from a supplier of multiple appliances that refrigerant will be recovered prior to delivery at the disposal establishme nt . ii) Respondent Activities  Retain copies of signed statements for each piece of disposed appliance with the name and address of the person who recovered the refrigerant and the date the refrigerant was recovered. 

### 6. **Technicians** The data items required by technicians are specified in 40 CFR 82.161 (a)(4) . i) Data Items  Proof of technician certification.  Leak inspection records.  Service invoi ces to owners/operators.  R ecords for the disposal of field - installed appliances with charge s between 5 and 50 pounds which include: the company name, location of equipment, date of recovery, the quantity and types of refrigerant recovered, and the quantity and type s of refrigerant ultimately transferred for reclamation or destruction . ii ) Respondent Activities  Complete a certification test .  Maintain a copy of certification at the ir place of business.  When servicing appliances containing 50 or more pounds of refrigerant : p repare service invoices with information on the identity and location of the appliance, the date and type of service performed, the quantity and type of refrigerant added, the full charge of the system, and t he leak rate. The technician must p rovide such service invoices to owners/operators with each servicing event.  Prepare the appropriate records when disposing of field - installed appliances with charge s between 5 and 50 pounds . 

### 7. **Owners/Operators of Appliances with Charge Sizes of 50 or More P** **ounds** The data items required by owners/operators of appliances containing 50 or more pounds of refrigerant are specified in 40 CFR 82.157( l ) and ( m ) . i) Data Items12

 S ervice invoices with information on the identity and location of the appliance, the date and type of service performed, the name of the person performing the service, the quantity and type of refrigeran t added, the full charge of the system, and the leak rate. Typically these are provided by the technician with each servicing event.  Records on either: 

###  Quarterly leak inspections for appliances with 500 or more pounds or refrigerant and/or annual leak insp ections for appliances with 50 to 500 pounds of refrigerant; or 

###  Installation of an automatic leak detection system and annual inspections and recalibrations.  Records of verification tests on repairs conducted when the leak rate is exceeded.  Requests for extension s to the 30- day repair timeline or the one -year retrofit/retire timeline (as applicable). Submissions include the following information : 

###  D ate of notification to EPA; 

###  I dentification of the appliance ; 

###  Name of the owner or operator; 

###  Leak rate; 

###  M ethod used to determine the leak rate and full charge; 

###  D ate a leak rate above the applicable allowable rate was discovered; 

###  Location of leaks(s) to the extent determined to date; 

###  A ny repair work that has been finished thus far, including the date that work was finished; 

###  P lan to finish the retrofit or retirement of the system (as applicable) ; 

###  R easons why more than one year is necessary to retrofit or retire the system (as applicable) ; and 

###  E stimate of when retrofit or retirement work will be finished (as applicable) .  Plans to retire/replace or retrofit appliances (as applicable). Plans must include: 

###  Identification and location of the appliance; 

###  Type and full charge of the refrigerant used in the appliance; 

###  Type and full charge of the refrigerant to whic h the appliance will be converted, if retrofitted; 

###  Itemized procedure for converting the appliance to a different refrigerant, including changes required for compatibility with the new substitute, if retrofitted; 

###  Plan for the disposition of recovered refrigerant; 

###  Plan for the disposition of the appliance, if retired; and 

###  One -year schedule for completion of the appliance retrofit or retirement.13

 Records on mothballed appliances, including the date when a system that is leaking in excess of the leak rate is mothballed and the date when refrigerant is later added back into the system .  Records on purged or destroyed refrigerant, including information o n flow rate, q uantity or concentration of the refrigerant in the vent steam; and p eriods of purge flow. ii) Respondent Activities  Retain service invoices containing the information described above.  Retain documentation from leak inspections or on leak detection systems.  Retain documentation on verification tests for repairs when the leak rate is exceeded .  Notify EPA when seeking an extension of time to complete repairs.  Prepare and maintain a plan to retire/replace or retrofit leaking appliances (as applicable).  Prepare and submit to EPA requests for extensions to the 30- day repair timeline or the one -year retrofit/retire timeline (as applicable) .  Maintain a copy of requests for extensions to the 30- day repair timeline or the one -year retrofit/retire timeline .  Maintain records on mothballed appliances .  Notify EPA when excluding purged refrigerants that are destroyed from annual leak rate calculations.  Maintain records on purged or destroyed refrigerant . 

### 8. **Small Can Manufacturers** The data items for small can manufacturers are specified in 40 CFR 82.154(c)(2) . i) Data Item  Log forms of results from self-sealing valve testing . ii) Respondent Activities  Conduct tests on self-sealing valves on products.  Prepare and retain records of results from self-sealing valve tests.14



# 5) **Information Collected -**  **Agency Activ ities, Collection**  **Methodology, a nd Information Management**  **A gency**  **Activities a)**  EPA activities associated with the review of the reports and recordkeeping requirements for the Program consist of reviewing the following:

 Extension requests from owners/operators of commercial refrigeration, comfort cooling, and industr ial process refrigeration appliances .  Applications to become an independent refrigerant recovery/recycling equipment certifying organization ;  Applications to become a certified refrigerant reclaimer;  Annual reports from reclaimers on their activities;  Certification notices by refrigerant reclaimers that change ownership or enter the market;  Applications to become a technician certification program ;  Reports submitted by approved technician certification programs; and 

## Collection Methodology and Manageme **nt b)**  EPA has not developed reporting or application forms, although it has a sample form to facilitate recordkeeping by small can manufacturers ( insert reference to form ). Entities are encouraged to submit the required information in a n electronic format to 608reports@epa.gov . The information submitted by each member of the regulated community will be stored at EPA headquarters for review and reference. 

## Small Entity Flexibility **c)** Several of the recordkeeping and report ing requirements of the rule are intended to permit entities greater flexibility in complying with the regulation. Technicians who work on small appliances may take a take - home test rather than a proctored test. This provision was implemented in recogniti on of the facts that (1) entities servicing small appliances are often small businesses, (2) many of these entities only rarely perform service on the refrigerant circuit of small appliances, and (3) the quantity of refrigerant in small appliances is less than five pounds. For similar reasons, individuals who recover refrigerant from small appliances and motor vehicle air conditioners when they are disposed of are not required to be certified and are not required to use certified refrigerant recovery/recycl ing equipment.15

Final persons in the disposal process for small appliances and MVACs may elect not to recover refrigerant themselves so long as they obtain a signed statement from persons upstream in the disposal process that the refrigerant has been remov ed already. The signed statement permits the final disposer to delegate responsibility for refrigerant removal. Owners of appliances that leak above a certain level may elect to retrofit or replace their appliances rather than repair them so long as they develop a retrofit or retirement plan. Owners /operators may take longer than 30 days to complete repairs or longer than one year to retrofit or replace appliances so long as they submit documentation to EPA explaining t heir need for additional time. 

## Colle **ction Schedule d)**  Information collection is required as of ( date ). EPA requires maintenance of records for a minimum of three years. The following information is required on a specific collection schedule :  Approved equipment testing organizations must notify EPA if a previously certified model line fails to meet EPA requirements within 30 days of the failed retest or inspection.  On a transactional basis, reclaimers must maintain records of the quantity of ea ch refrigerant sent to them for reclamation (the combined mass of refrigerant and contaminants), the mass of each refrigerant reclaimed, and the mass of waste products. Reclaimers must report th e aggregated information by refrigerant type to EPA within 30 days of the end of the calendar year.  Effective January 1, 2018, programs certifying technicians, excluding federally - run programs, must create and maintain a publicly -searchable database of technicians they have certified. The database must include all technicians certified after January 1, 2017.  If a refrigerant reclaimer change s ownership, the new owner must certify with EPA within 30 days of the change of ownership.  Owners/operators must prepare a retrofit or retirement plan within 3 0 days of: 

###  D iscove ring a leak greater than the applicable threshold leak rate; 

###  M aking good faith efforts to repair leak s but before finishin g a follow- up verification test; or 

###  After a failed follow - up verification test.  Owners/operators choosing to request an extension to t he retrofit/retirement timeline must do so within seven months of discovering that the leak rate exceeded the applicable leak rate .  Owners/operators who exclude purged refrigerants that are destroyed from annual leak rate calculations must submit informat ion to EPA within 60 days of the first time the exclusion is used by the facility where the appliance is located .16



# 6) **Estimating t he Burden**  **and Cost of t he Collection**  This section provides burden tables that provide the numerical basis for the annual burden and cost of this ICR by detailing the following:

 EPA’s rationale in preparing respondent burden and cost tables;  Estimated respondent and Agency burden (hours to complete required activities);  Estimated respondent and Agency labor costs and capital costs associated with the those activities;  Universe of estimates; and  Calculated burden and cost totals. The collection activities in Sections 4 and 5 are referenced to develop the se estimates. The activities for which EPA estimated burden and cost correspond directly with the activiti es listed in Sections 4 and 5. 

## Estimating Respondent Burden **a)** Estimates of respondent burden and cost for the Program are presented below. All hour estimates are based on EPA' s experience implementing this P rogram a nd on EPA’ s best professional judgment. The overall reporting and recordkeeping burden as a result of the proposed rule is higher compared to previous ICRs because 1) the universe of reporters has expanded to include owners/operators and technicians who service equipment containing HFC- and other non - exempt substitute refrigerant containing appliances and 2) new requirements to document the disposal of mid -sized comfort cooling and commercial refrigeration appliances. There are also new requirements related to leak inspec tion, disposal, and self-sealing valves. All burden hours and costs presented here are annual. 

## Estimating Respondent Costs **b)** EPA has estimated the total cost per respondent required to complete each activity. The total cost for each respondent activity is comprised of the following:

 Labor Cost (for legal, managerial, technical, clerical, and other employees).  Operating and Maintenance (O&M) Cost (for labor and equipment needed over time as well as for the purchase of services). None of the reporting or rec ordkeeping requirements is expected to have associated capital costs. 

## i. **Estimating Labor Costs** The labor costs reflect the total cost to employ an individual and include estimates of salaries and17

overhead costs. EPA estimates the average annual respondent hourly cost (labor plus overhead) for all affected entities below. In deriving these costs, EPA used the media n hourly rate of $21.46 for heating, air-conditioning, and refrigeration mechanics and installers 1 and a median hourly rate of $13.74 for weighers, measurers, checkers, and samplers 2 from the Bureau of Labor Statistics. EPA then multiplied these numbers by 110% for overhead. The resulting costs of $45.07 (for heating, air

-conditioning, and refrigeration mechanics and installers) and $28.85 (for weighers, measurers, checkers, and samplers) are the average hourly administrative cost of labor plus overhead for private firms. The cost for weighers, measurers, checkers, and samplers is applicable only to small can manufacturers. 

## ii. **Estimating Capital and Operations and Maintenance Costs** According to the 1995 PRA, burden is the “total time, effort, or financial resources exp ended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. ” Any activity that is not usual and customary is considered a burden. As part of the submission to OMB, EPA has estimated all costs for respondents to comply with required Agency activities that are not incurred by persons in their normal course of activities. This ICR estimate includes the time needed to review instructions, maintain records, complete paperwork, gather information, an d rep ort information. There are two typ es of non - labor costs – capita l/start
- up costs and O&M costs. One -time capital/start
up costs include any produced physical good needed to provide the necessary information. Start- up capital must be purchased for the specific purpose of satisfying EPA’s reporting or recordkeeping requirements. Capital goods include computers, machinery, or equipment. Start- up capital costs are incurred at the beginning of an information collection period and are incurred only once. In addition to the acquisition of start- up capital, one -time activities associated with the production of capital have also been evaluated. EPA has considered capital/start
- up costs and O&M costs in determining that there are no non - labor related costs assoc iated with this ICR. O&M costs are those costs associated with a paperwork requirement incurred continuously over the life of the ICR. They are defined by the PRA as “the recurring dollar amount of cost associated with O&M or purchasing services. ” The fo llowing tables summarize the annual respondent burden and cost by respondent type and reporting and recordkeeping requirement.

1 Bureau of Labor Statistics, U.S. Department of Labor, Occupational Employment and Wages, May 2014, Heating, Air-conditioning, and Refrigeration Mechanics and Installers, on the Internet at http://www.bls.gov/oes/current/oes499021.htm (visited July 13, 2015 ). 2 Bureau of Labor Statistics, U.S. Department of Labor, Occupational Employment and Wages, May 2014, Weighers, Measurers, Checkers, and Samplers, Recordkeeping, on the Internet at http://www.bls.gov/oes/current/oes435111.htm (visited July 30, 2015).18



### 1. **Refrigerant Recovery/Recycling Equipment Testing Organization Annual Respondent Burden**  **Collection Activities Burden Hours**  **Labor Costs/Entity**  Publish list of all certified equipment that includes the name of the manufacturer and the name or serial number of the model line online 0.08 $3.76 Maintain records of refrigerant recovery/recycling equipment tested and its performance 0.125 $5.63 Each of the two refrigerant recovery/recycling equipment testing and certifying organizations approved by EPA are estimated to spend 5 minutes each year publishing a list of all certified equipment online . Each refrigerant recovery/recycling equipment testing and certifying organizations are also expected to spend 1/8 hour maintain ing records of the tests as a part of normal business practices. 

### 2. **Refrigerant Reclaimers Annual Respondent Burden** 

**Collection Activities Burden Hours**  **Labor Costs/Entity**  Annual activity report 9.4 $422.23 Reclaim er recordkeeping 11.7 $527.79 Maintain records that analysis conducted to verify that reclaimed refrigerant meets the necessary specifications 4.3 $ 195.29 Certification by refrigerant reclaimers that c hange ownership or e nter the m arket 5.0 $225.33 R eclaimers must maintain records and report annually on the quantity of material sent to them for reclamation, the amount reclaimed, waste products from the reclamation process, and customer and sales records. Compiling this information, preparing it for EPA, and submitting it to EPA is estimated to take approximately 9.4 hours per year for ODS, HFC, and other non - exempt substitute refrigerants. 3 Reclaimers must maintain records of refrigerant sales transactions. EPA estimates that each reclaimer will spend approximately 14 minutes per recordkeeping event with a total of 50 events per year. 4

3 In the previous ICR, the burden for preparing the annual activity report was 5.0 hours for ODS appliances only. The recordkee ping burden was scaled to include appliances containing HFCs and other non -exempt refrigerants based on the inventory of equipment. 4 In the previous ICR, the burden for maintaining records was 0.125 hours for ODS appliances only. The recordkeeping burden was scaled to include appliances containing HFCs and other non -exempt refrigerants based19

Therefore, each reclaimer will spend 11.7 hours maintain ing records annually. Reclaimers must also maintain records of analyses conducted to verify that reclaimed refrigerant meets the necessary specifications. EPA estimates that each reclaimer will spend approximately 1 minute per day maintaining records . The refore, each reclaimer will spend approximately 4.3 hours maintaining records annually. Based on experience from previous years, EPA estimates that four reclaimers will submit one -time applications for certification. Each submission is estimated to take 5 hours. 

### 3. **Refrigerant Wholesalers Annual Respondent Burden**  **Collection Activities Burden Hours**  **Labor Costs/Entity** Recordkeeping for refrigerant sales, including maintenance of technician certification cards from purchasers employing at least one certified technician 1.55 $69.67 EPA estimates that each refrigerant wholesaler must spend approximately four minutes maintaining invoices that indicate the name of the purchaser, the date of sale, the quantity, and verification that the purchaser is a certified technician (as applicable). 5 EPA estima tes that each refrigerant wholesaler performs 25 recordkeeping actions per year, or 1.55 annual burden hours. 

### 4. **Technician Certification Programs Annual Respondent Burden**  **Collection Activities Burden Hours**  **Labor Costs/Entity** Technician certification programs applying for approval 5.0 $225.33 Maintain list/database of technicians certified 0.17 $7.51 Biannual reporting by existing certification programs 2.0 $90.13 Recordkeeping by existing certification programs 5.0 $225.33 EPA estimates that it will take five hours for new organizations to compile the necessary information to apply for the certification program approval. on the inventory of equipment. 5 In the previous ICR, the burden for maintaining records was 0.125 hours for ODS appliances only. The recordkeeping burden was scaled to include appliances containing HFCs and other non -exempt refrigerants based on the inventory of equipment.20

Technician certification programs are required to publish online a list or database documenting who they have certified and what type of certification each individual received. Each of the testing organizations are also required to submit biannual reports summarizing the numbers of previously certified individuals, individuals taking the tests, scores of all certification tests, and the dates and locations of all tests administered. EPA estimates that technician certification programs spend five minutes publishing online lists and one hour completing each report. EPA expects programs to publish lists and comp lete reports twice a year. EPA estimates that each technician certification program spends five hours annually maintaining records on each technician certified through their programs. 

### 5. **Disposal Establishments Annual Respondent Burden** 

**Collection Activities Burden Hours**  **Labor Costs/Entity** Maintenance of copies of signed statements of previous refrigerant recovery by disposal establishments 13.0 $585.86 Disposal establishments spend an estimated three minutes per business day (260 events per year) collecting and maintaining copies of signed statements verifying that refrigerant has been removed from appliances before they are accepted for disposal. 

### 6. **Techn icians**  **Annual Respondent Burden -**  **Certification**

**Collection Activities Burden Hours**  **Labor Costs/Entity** Maintain certification cards 0.017 $0.75 Acquire certification cards 0.017 $0.75 EPA estimates that approximately 10 percent of the estimated 300,000 technician labor force turns over each year, necessitating certification. EPA estimates that each technician will spend one minute maintaining a copy of the certification card.

**Annual R espondent Burden**  **- Preparing and Maintaining Records**  **Collection Activities Burden Hours**  **Labor Costs/Entity** Prepare and provide invoices for serviced appliances with charge sizes 50 to 500 lbs. 0.14 $6.35 Prepare and provide invoices for serviced appliances with charge sizes >500 lbs. 0.12 $5.4821

Maintain leak inspection records 0.13 $5.92 Maintain disposal records for appliances with charge sizes of 5

- 50 lbs. 0.41 $18.26 Technicians servicing ODS, HFC, and other non - exempt substitute refrigerant-containing appliances with charge sizes of 50 or more pounds are required to provide records of the following: the identity and location of the appliance, the date and type of service performed, the quantity and type of refrigerant a dded, the full charge of the system, and the leak rate. EPA estimates that appliances containing 50 to 500 pounds of refrigerant will be serviced annually and that appliances with 500 or more pounds will be serviced quarterly. EPA estimates that each techn ician will provide eight invoices a year, spending two minutes preparing and one minute maintaining each record. 6 Technicians disposing of field - installed appliances with charge sizes between 5 and 50 pounds are also required to maintain records on: the quantity and types of refrigerant recovered at disposal; the quantity and type of refrigerant transferred for reclam ation or destruction; the company name; and date. EPA estimates that technicians spend one minute per record and will dispose of an average of 24 pieces of equipment each year. 

### 7. **Owners/Operators Annual Respondent Burden**  **- Reporting** 

**Collection Activities Burden Hours**  **Labor Costs/Entity** Prepare and subm it requests for extension to 30- day repair timeline 0.5 $22.53 Prepare and sub mit requests for extension to 1 -year retrofit/retire timeline 0.5 $22.53 Owners/operators of IPR, comfort cooling, or commercial refrigeration appliances that contain more than 50 lbs. of ODS or HFC refrigerant may apply to EPA for an extension to the leak repair and appliance retrofit/retire timeframe. EPA estimates that each request wil l take 30 minutes to complete. **An nual Respondent Burden**  **- Recordkeeping**  **Collection Activities Burden Hours**  **Labor Costs/Entity** Maintain information on purged/destroyed refrigerant 0.025 $1.13 Develop/maintain plan to retire/replace or retrofit appliances 8.0 $360.53

6 In the previous ICR, EPA had assumed a burden of 1.5 minutes to provide invoices. In this ICR, EPA assumes an additional burden of 0.5 minutes fo r documenting the additional information required.22

Maintain purchase and service records 0.11 $4.91 Maintain leak inspection records 0.073 $3.27 Maintain reports on the results of verification tests for repairs to systems that exceed the leak rate threshold 0.025 $1.13 EPA estimates that owners/ operators of appliances normally containing 50 or more pounds of refrigerant spend 1.5 minutes maintaining information on purged and destroyed refrigerant. Owners/ operators planning to retire/replace or retrofit appliances spend eight hours on developing or maintaining a plan. EPA estimates that one percent of HFC appliances will necessitate a plan. EPA has adjusted the number of expected retirements to account for more extension s to the repair timeline. Owners/operators of ODS, HFC, and other non - exempt substitute refrigerant - containing appliances with charge sizes of 50 or more pounds are required to maintain records of the following for each refrigerant addition: the identity and location of the appliance, the date and type of service performed, the qua ntity and type of refrigerant added, the full charge of the system, and the leak rate. EPA estimates an average annual burden of approximately 6.5 minutes per owner/operator. Owners/operators are required to maintain reports on quarterly and annual inspections and on the results of verification tests and leak inspections any time the leak rate threshold is exceeded. EPA estimates that maintaining leak inspection records require s one minute of burden and that each owner/operator will maintain approximately five records. EPA estimates that 1.5 minutes is required to maintain reports on the results of verification tests any time the leak threshold is exceeded. 

### 8. **Small Can Manufactur ers**  **Annual Respondent Burden -**  **Reporting Collection Activities**  **Burden Hours Labor Costs/Entity**  Maintain records of self-sealing valve test data and log forms for 3 years 0.30 $8.66 Manufacturer of small cans of refrigerant are required to conduct tests to verify that self -sealing valves function and maintain logs of test results. EPA estimates that manufacturers will require 1.5 minutes to document each test result and that tests wil l occur monthly. 

## Estimating the Respondent Universe and Total Burden and **c) Costs**  The respondent universe as well as the frequency of reporting is defined in 40 CFR, Part 82, Subpart F, and includes the number of respondents for established refrigerant recov ery/recycling equipment testing organizations; averages for the number of service establishments, disposers, and refrigerant23

reclaimers that enter the market or change ownership; refrigerant wholesalers; technician certification programs; technicians acqui ring certification and maintaining certification cards; owners of refrigeration and air-conditioning appliances; owners of industrial process refrigeration appliances; and small can manufacturers. EPA used past experience, previously reported data, modelin g, and estimates from the affected community to determine the number of respondents (or the respondent universe). The estimates are based upon EPA's experience in implementing the Program since 1993 and analysis conducted in the Technical Support Document that accompanies this rulemaking. 7 A listing of these entities follows:

 **Refrigerant/Recycling Equipment Testing Organizations:** Testing organizations for refrigerant recovery/recycling equipment have remained at two organizations since inception of the regu lations during May 1993. Based on past experience, EPA does not anticipate that additional entities will apply to become approved refrigerant recovery/recycling equipment testing organizations.  **Refrigerant Reclaimers:** EPA currently has 61 certified refrige rant reclaimers who must submit annual activity reports. Based on EPA's experience, EPA estimates four reclaimers per year will submit one -time applications to EPA to be certified.  **Refrigerant Wholesalers:** EPA believes that the number of establishments th at sell refrigerant has remained the same over the past few years. This ICR assumes that the number of wholesalers has remained at 200,000.  **Technician Certifying Programs:** EPA currently has 88 certified technician certifying programs. Based on EPA's experi ence, EPA estimates five new organizations per year will submit materials to EPA requesting that they be authorized to test and certify technicians.  **Technicians:** EPA assumes that the number of technicians entering the workplace has remained constant wit h those that who have left the workforce. This ICR assumes that the number of technicians has remained constant at 300,000. EPA assumes that 10 percent of the technician labor force turns over each year (i.e., 30,000 technicians), necessitating certificati on.  **Disposal Establishments:** EPA assumes that the number of disposal establishments (7,500) has not c hanged since the previous ICR.  **Owners/Operators: 8** 

7 See Technical Support Document: Analysis of the Economic Impact and Benefits of Proposed Revisions to National Recycling and Emission Reduction Program. August 2015. Available at: [ insert docket locatio n ] 8 All of the following assumptions about the number of owners/operators of comfort cooling, commercial refrigeration, and industrial process refrigeration appliances were developed in the Technical Support Document that accompanies this rulemaking. For more detail on the methodology and modeling approach, please see: Technical Support Document: Analysis of the Economic Impact and Benefits of Proposed Revisions to National Recycling and Emission Reduction Program. August 2015. Available at: [ insert docket loc ation ]24



###  Based on actual submissions to EPA, the Agency estimates that four owners/operators of comfort cooling, commercial refrigeration, and industrial process refrigeration appliances with charge sizes greater than 50 lbs. will choose to exclude the amount of purged and destroyed refrigerant from their leak rate calculations. 

###  EPA allows owners/operators of industrial process refrigeration, comfort cooling, and commercial refrigeration appliances with a charge size of 50 or more pounds to submit a written request for an extension to leak repair requirements. The number of extensions is estimated partly based on th e number of actual extensions filed for ODS industrial process refrigeration appliances in previous years. EPA also accounts for additional requests expected due to fewer comfort cooling and commercial refrigeration appliance retirements and retrofits occu rring associated with the allowing extensions for non -federal ODS comfort cooling and commercial refrigeration appliances and HFC-containing appliances. EPA estimates that 4,556 owners/ operators of ODS and HFC appliances will prepare and submit request fo r extensions each year. 

###  61 owners/operators of appliances with a charge size of 50 or more pounds are expected to prepare and submit requests for extensions to the one year retrofit/retire timeline. This estimate is based on the number of IPR and federally-owned appliances that historically sought extensions. The number of extensions for IPR is scaled up to account for extensions requested for comfort cooling and commercial refrigeration (ODS and HFC appliances ), and IPR (HFC appliances ). 

###  EPA estimates tha t 4,092 owners/operators will develop and maintain the required appliance retire/retrofit report on
-site at their place of business. EPA assumes that fewer retrofits/ retirements will now occur due to the availability of extension requests. 

###  EPA estimates that 542,729 owners/operators of appliances with charge sizes of 50 or more pounds would need to maintain annual or quarterly service invoices. The number of owners/ operators is estimated based on the total number of appliances and the average number of a ppliances per model facility in the Technical Support Document associated with this rule . 

###  EPA estimates that there are 385,322 events that would exceed the leak rate threshold in IPR, comfort cooling, and commercial refrigeration appliances. For the purpos es of this analysis, EPA assumes that the number of leak events is equivalent to the number of owners/operators that would need to keep records on the results of the verification tests when those thresholds are exceeded .  **Small Can Manufacturers:** There are an estimated 10 manufacturers of small cans of refrigerant that need to comply with the self-sealing valve requirements. 9

9 See Technical Support Document: Analysis of the Economic Impact and Benefits of Proposed Revisions to National Recycling and Emission Reduction Program. August 2015. Available at: [ insert docket location ]25

For the entities that may be subject to the proposed regulatory actions, a n estimated 950,500 are small businesses. Additional inform ation on small business impacts can be found in the Technical Support Document. 10 

## Estimating Agency Burden and Cost **d)** The hourly rate for EPA staff at the GS - 13 Step 1 level is $ 35.03 per hour. This hourly basic rate is from the 2015 GS salary schedule listed in the Federal Wage Page of the Office of Personnel Management website http://www.opm.gov/oca . EPA then multiplied the hourly rate by the standard government benefits and overhead multiplicat ion factor of 1.6. The resulting rate that was used in estimating annual Agency burden and cost is $ 56.05 ($ 35.03 × 1.6). EPA has used past experience and reporting data in addition to estimates from the affected community in determining the number of resp ondents for which the Agency would assume the burden of review or response. The following paragraphs describe the amount and degree of burden endured by EPA review of required respondents’ reports.

 **Refrigerant Reclaimers:** EPA currently has 61 certified ref rigerant reclaimers who must submit annual activity reports. EPA will spend one hour reviewing each of the annual reports for a total of 61 hours per year. Based on EPA's experience, it is assumed that four new refrigerant reclaimers per year will submit one -time applic ations to EPA to be certified. EPA spend s one hour reviewing and approving each certification for a total of four hours per year.  **Technician Certifying Programs:** EPA currently has 88 certified technician certifying programs. Each program is required to submit biannual activity reports to EPA. EPA will spend one hour reviewing each biannual activity report, for a total of 176 hours per year. Based on EPA's experience, the Agency expects to certify five new technician certification organizati ons per year. EPA expects to spend two hours reviewing and approving each application, for a total of 10 hours per year.  **Owners/Operators:** EPA estimates that it takes one - half hour to review and make a determination on each of the anticipated 4,556 reque sts from owner/operators of industrial process refrigeration, comfort cooling, and commercial refrigeration appliances for an extension to the 30 - day repair requirement for mandatory leak repair, for a total of 2,278 hours per year. EPA estimates one hour to review and make a determination on anticipated 61 requests from the owner/operator of industrial process refrigeration, comfort cooling, and commercial refrigeration

10 Technical Support Document: Analysis of the Economic Impact and Benefits of Proposed Revisions to National Recycling and Emission Reduction Program. August 2015. Available at: [insert docket location ]26

appliances for an extension to the one -year retrofit requirement under the leak repair requirements, for a total of 61 hours a year.27



## Bottom Line Burden Hours and Cost Tables **e)** The bottom line burden hours and cost tables for respondents and the Agency are summarized below for all a ctivities. 

## i) **Respondent Tally** Table 2 and Table 3 summarize total annual respondent burden and cost by respondent type and activity. **Table 2**  **: Total Annual Respondent Reporting Burden and Costs Respondent Type**  **Activity Number of**  **Respondents Number of** 

**Responses per**  **Respondent Burden** 

**Hours per Response**  **Annual**

**Burden Hours**  **Annual**

**Labor Costs** Owners/ Operators of Appliances with Charge Sizes of 50 or More Pounds Prepare and submit requests for extensions to 30-day

repair timeline 4,556 1 0.50 2,278 $102,663 P repare and subm it requests for extensions to 1-yea r retrofit/retire timeline 61 1 0.50 30 $1,366 Refrigerant Reclaimers Reclaimer a nnual activity report 61 1 9.37 572 $25,756

Certification by Refrigerant Reclaimers that Change Ownership or Enter the Market 4 1 5.00 20 $901 Refrigerant Recovery/ Recycling Equipment Testing Organization s Publish online list of all certified equipment 2 1 0.08 0.17 $8 Technician Certification Programs Applying for a pproval 5 1 5.00 25 $1,127

Maintain list/da tabase of technicians certified 88 2 0.08 15 $661 Biannual reporting by existing technician certification programs 2 1.00 176 $7,932 **SUBTOTAL varies**  **varies varies**  **3,116 $140,414** 28

**Table 3**  **: Total Annual Respondent Recordkeeping Burden and Costs Respondent Type**  **Activity Number of**  **Respondents Number of** 

**Responses per**  **Respondent Burden** 

**Hours per Response**  **Annual**

**Burden Hours**  **Annual**

**Labor Costs** Disposal Establishments Maintenance of copies of signed statements of previous

refrigerant recovery by disposal establishments 7,500 260 0.050 97,500 $4,393,935

Owners/ Operators of Appliances with Charge Sizes of 50 or More Pounds Maintain information on purged/destroyed refrigerant 4 1 0.025 0.1 $4

D evelop/ m aintain plan to retire/replace or retrofit equipment, as applicable 4,092 1 8.00 32,738 $1,475,368
M ainta in purchase and service records 542,729 4.35 0.025 59,080 $2,662,486 M ain taining leak inspection records 4.35 0.017 39,386 $1,774,990 Maintain reports on the results of verification tests any time the leak rate threshold is exceeded 385,322 1.00 0.025 9,633 $434,123 Refrigerant Reclaimers Reclaimer Recordkeeping 61 50 0.23 714 $32,195

Maintain records that analysis conducted to verify that reclaimed refrigerant meets the necessary specifications 260 0.017 264 $11,912 Refrigerant Recovery/ Recycling Equipment Testing Organization Maintain records of refrigerant recovery/recycling

equipment tested and its performance 2 1 0.125 0 $11 Refrigerant Wholesalers Recordkeeping for refrigerant sales, including

maintenance of technician certification cards from purchasers employing at least one certified technician 200,000 25 0.062 309,182 $13,933,60629

**Respondent Type Activity**  **Number of Respondents**  **Number of**

**Responses per**  **Respondent Burden** 

**Hours per Response**  **Annual**

**Burden Hours**  **Annual**

**Labor Costs** Small Can Manufacturers Maintain records of self- sealing valve test data and log

forms for 3 years 10 12 0.025 3 $87 Technician Certification Programs Record keeping by existing technician certification

programs 88 1 5.00 440 $19,829

Technicians M aintaining certification cards

300,000 1 0.017 5,010 $225,781

Acquiring certification cards 1 0.017 501 $22,578 Persons servicing CC appliances, and IPR and CR appliances 50 - 500 lbs. provide invoices to appliance owners/operators 4.23 0.033 42,298 $1,906,185 Persons servicing IPR and CR appliances >500 lbs. provide invoices to appliance owners/operators 3.65 0.033 36,475 $1,643,795 Persons servicing appliances maintain leak inspection records 8 0.017 39,386 $1,774,990 Technicians disposing of appliances with 5 - 50 lbs. refrigerant maintaining records on quantity and types of refrigerant recovered at disposal and the quantity and type of refrigerant transferred for reclamation or destruction 24.32 0.017 121,586 $5,479,395
**SUBTOTAL varies**  **varies varies**  **794,198 $35,791,271**  **Table 4**  **: Total Annual Respondent Burden Number of Respondents**  **Number of Responses Hour**  **Burden Labor Costs**  1,050,390 24, 441,490 797, 314 $35, 931,68530



## ii) **The Agency Tally** Table 5 and Table 6 summarize total annual agency burden and cost by and activity. **Table 5**  **: Annual Agency Burden and Cost Activity**  **Number of Respondents**  **Number of**

**Responses per Respondent**  **Burden Hours to**

**Review each Response**  **Total Annual**

**Agency Hours Total Agency** 

**Labor Costs** Reclaimer annual activity report 61 1 1 61 $ 3,419 Certification by refrigerant reclaimers that c hange ownership or e nter the m arket 4 1 1 4 $ 224 Biannual reporting by existing t echnician certification p rograms 88 2 1 176 $ 9,864 Technician c ertification p rograms a pplying for a pproval 5 1 2 10 $ 560 Owners/operators of appliances w/charge sizes of 50 or more lbs prepare & submit requests for extensions to 30 day repair timeline 4,556 1 0.5 2,278 $ 127,681 Owners/operators of appliances w/charge sizes of 50 or more lbs prepare & submit requests for extensions to 1 year retrofit/retire timeline 61 1 1 61 $ 3,398 **SUBTOTAL 4,777**  **varies varies**  **2, 590**  **$ 145,148**  **Table 6**  **: Total Annual Agency Burden Number of Respondents**  **Number of Responses Hour Burden for Review**  **Labor Costs** 4,777 4,86 3 2,59 0 $ 145,14831

Variations in the Annual Bottom Line EPA does not anticipate a significant variation (>25%) in the annual respondent reporting /recordkeeping burden or cost over the c ourse of the clearance period. Likewise, the government burdens and costs are not anticipated to vary significantly. 

## Reasons f**or Change in Burden f)**  EPA has proposed s everal regulatory changes to the refrigerant management requirements under Section 608 of the CAA, s ince the previous renewal of this ICR. To minimize the harm that both ODS and HFC refrigerants have on the environment and to fully implement the prohibition on venting, EPA proposed extending existing requirements under the Program to cover appliances containing HFCs, and revising the ru le components associated with leak repair, as well as recordkeeping and reporting. Further, EPA proposed that manufacturers of small cans of MVAC refrigerant install and test self-sealing valve s to prevent the release of refrigerant to the atmosphere. EPA has also proposed to remove the one -time certification requirement that technicians own recovery equipment and the requirement for refrigerant recovery/recycling e quipment t esting o rganizations to submit annual reports . These regulatory changes have result ed in new requirements for reporting and recordkeeping, as well as removed some previous requirements. The net result is an increase in the time required to submit reports and maintain records in this ICR. EPA has also adjusted costs based on updated labor rates. 

## Burden Statement **g)** The annual public reporting and recordkeeping burden for this collection of information is estimated to range from 11 minutes to 20 hours per year for each respondent. The average reporting and recordkeeping burden for this col lection is 0.03 hours per response . This estimate includes time for preparing and submitting reports and maintaining records on -site at the respondents’ places of business. Burden means the total time, effort, or financial resources expended by persons t o generate, maintain, retain, or disclose or provide informati on 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 othe rwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unles s it displays a curre ntly valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.32

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, a nd 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- OAR2015 -0453 , which is available for online viewing at www.regulations.gov, or in person viewing at the Air and Radiation Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Publi c 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 OAR Docket is (202) 566 - 1742 . An electronic version of the pu blic docket is available at www.regulations.gov . This site can be used to submit or view public comments, access the index listing of the contents of the public doc ket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affai rs, 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- 2015 -0453 and OMB control number 2060-0256 in any correspondence.