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9/6 /12 IN FORMAT ION COLLECTI ON REQUEST (ICR) ENVIRONMENTAL PROTECTION AGENCY STRATOSPHERI C OZONE PROTECTION SUPPORTING STATEMENT PART A 1. Id entification of the In formation Collection **a) Title:**  Reporting and Recordkeeping Requirements of the HCFC Allowance Sy stem OMB Number: 2060 - 0498 EPA I CR Number: 2014.0 4 **b) Short Characterization:**  The international treaty The Montreal Protocol on Substances that Deplete the Ozone Layer (Protocol) and Title VI of the Clean Air Act Amendments (CAAA) established limits on total U.S. production, import, and export of class I and class II controlled ozone depleting substances (commonl y referred to as “controlled substances) . Under the commitments agreed to under the Protocol, the United States was obligated to cease production and import of class I controlled substances (e.g., chlorofluorocarbons or CFCs) with exemptions for essential uses, critical uses, previously- used material, and material that is transformed, destro yed, or exported to developing countries. The Protocol also establishes limits and reduction schedules leading to the eventual phaseout of class II controlled substances (i.e., hydrochlorofluorocarbons or HCFCs). The U.S. is obligated to limit HCFC consumption (defined b y the Protocol as production plus imports, minus exports). The schedule call ed for a 35 percent reduction on January 1, 2004, followed b y a 7 5 percent reduction on January 1, 2010, a 9 0 percent reduction on January 1, 2015, a 99.5 percent reduction on January 1, 2020, and a total phaseout on January 1, 2030. The U.S. Environmental Protection Agency (EPA) is responsible for administering the phaseout. The U.S. comfortabl y met the 35 perc ent and 75 percent reduction of the cap , and is on schedule to meet the 90 percent reduction for January 1, 201 5 . To ensure U.S. compliance with these limits and restrictions, EPA established an allowance s ys tem to control U.S. production and import of HC FCs by granting control measures referred to as baseline and calendar- ye ar allowances . Baseline allowances are based on the historical activity

of individual companies. Calendar- ye ar allowances grant companies the ability to produce and/or import a limited quantity of HCFCs in a given year and are reflected as aPage 2 of 26

percentage of baseline allowances. There are two ty pes of baseline and calendar- ye ar allowances: consumption and production allowances. Since each allowance is equal to 1 kilogram of HCFC, EPA is able to monitor the quantity of HCFCs being produced, imported and exported. Transfers of production and consumption allowances among producers and importers are allowed and are tracked by EPA . The above - described limits and restrictions are monitored by EPA through the recordkeeping and reporting requirements established in the regulations in 40 CFR part 82, subpart A. To submit required information, regulated entities c an download reporting forms from EPA’s web site (http://www.epa.gov/ozone/record.index.html), complete them, and send them to EPA electronically , via mail , courier, or fax. Almost all of the large regulated companies use the EPA reporting forms. Upon receipt of the reports, the data is entered into the ODS Tracking S ys tem . The ODS Tracking S ys tem is a secure database that m aintains the data submitted to EPA and helps the agency : (1) maintain oversight over total production and consumption of controlled substances; (2) monitor compliance with limits and restrictions on production, imports, and trades and specific exemptions from the phaseout for individual U.S. companies; (3) enforce against illegal imports ; and (4) assess, and report on, compliance with the U.S. phasedown caps established under the Montreal Protocol. EPA has implemented an electronic reporting s ys tem through the agency ’s Central Data Exchange (CDX) that allows regulated entities to prepare and submit data electronically . Coupled with the widespread use of the standardized forms, electronic reporting has improved data quality

and made the reporting process efficient for both reporting companies and EPA. Most reports that are submitted to the agency are done so electronicall y. Pursuant to regulations in 40 CFR part 2, subpart B, reporting businesses are entitled to assert a business confidentiality claim co vering any

part of the submitted business information as defined in 40 CFR 2.201(c). EPA’s practice is to manage the reported information as confidential business information. Based on our records, the information collection requirements affect 49 respond ents. We estimate the total average annual industry burden and cost as 1, 6 01 hours and $ 16 1 , 79 3 . **Terms of Clearance** When O MB approv ed the IC R in 200 3 , i t encouraged EPA to develop a database that allows for direct electronic reporting. EPA has establish ed an electronic reporting s ys tem that is widely used by companies . No Terms of Clearance were issued when OMB last approved the ICR.Page 3 of 26

2. Need For, and Use Of, the Collection **a) Authority for the Collection**  This information collection is authorized under section 603(b) of the Clean Air Act Amendments and is necessary to meet information collection obligations under Article 7 of the Montreal Protocol. Excerpts from these documents are as follows. **CAA A**  **603(b) Production, import, and export level reports**  On a quarterl y basis, each person who produced, imported, or exported a class I or class II controlled substance shall file a report with the Administrator setting for th the amount of the substance that such person produced, imported, and exported during the preceding reporting period. Each report shall be signed and attested b y a responsible officer. No report shall be required from a person after April of the calendar year after such person permanently ceases production, importation, and exportation of the substance and so notifie d the Administrator in writing. **Article 7 of the Montreal Protocol on Substances that Dep lete the Ozone Layer:**  **Reporting of data** 1. Each Party shall provide to the Secretariat, within three months of becoming a Party, statistical data on its production, imports and exports of each of the controlled substances in Annex A for the year 1986, or the best possible estimates of such data where actual data are not available. 2. Each Party shall provide to the Secretariat statistical data on its production, imports and exports of each of the controlled substances

- In Annex B and Groups I and II of Annex C for the year 1989;

- In Annex E, for the year 1991, or the best possible estimates of such data where actual data are not available, not later than three months after the date when the provisions set out in the Protocol with regard to the substances in Annexes B, C and E respectivel y enter into force for that Party. 3. Each Party shall provide to the Secretariat statistical data on its annual production (as defined in paragraph 5 of Article 1) of each of the controlled substances listed in Annexes A, B, C and E and, separatel y, for each substance :

- Amounts used for feedstocks,

- Amounts destroyed by

technologies approved by the Parties, and

- Imports from and exports to Parties and non - Parties respectivel y , f or the ye ar during which provisions concerning the substances in Annexes A, B, C and E respectivel y entered into force for that Party and for each ye ar thereafter. Each Party shall provide to the Secretariat statistical data on the annual amount of the controlled substance listed in Annex E used for quarantine and pre - shipment applications. Data shall be forwarded not later than nine months after the end of the ye ar to which the data relate.Page 4 of 26

3 . Each Party shall provide to the Secretariat separate statistical data of its annual imports and exports of each of the controlled substances listed in Group II of Annex A and Group Iof Annex C that have been recycled. 4. For Parties operating under the provisions of paragraph 8 (a) of Article 2, the requirements in p aragraphs 1, 2, 3 and 3 bis of this Article in respect of statistical data on imports and exports shall be satisfied if the regional economic integration organization concerned provides data on imports and exports between the organization and States that are not members of that organization. **b) Practical Utility/Users of the Data**  The reporting and recordkeeping requirements for class II controlled substances enable EPA to: 1) Ensure compliance with the restrictions on production, import and export of controlled substances ; 2) A llow exempted production and import for certain uses and the tracking of that production and import; 3) Address f

ederal concerns regarding the illegal import of controlled substances; 4) Satisfy U.S. obligations under the Montreal Protocol to report data annually to the Ozone Secretariat, as listed in Article 7 of the Protocol; 5) Fulfill statutory

obligations under Section 603(b) of the CAAA for reporting and monitoring; and 6) Provide information to report to Congress on the production, use and consumption of class II controlled substances as required in Section 603(d) of the CAAA. The information reported to EPA is entered into an ele ctronic tracking s ys tem to ensure companies do not exceed their allowances and to guarantee the U.S. does not violate it s obligations under the Protocol. Thus, the information is used for compliance monitoring for individual companies and for monitoring U. S. compliance with the obligations under the Protocol. EPA and Customs and Border Protection (CBP) are concerned about fraudulent imports of controlled substances that are mislabeled as used, recycled , or reclaimed. To this end, EPA established a petition process to provide information for controlling the import of these materials and act as a deterrent to potential fraud. Under 40 CFR 82.24(c)(3), companies that wish to import used, recycled or reclaimed controlled substances must provide detailed information about the previous use and intended use of the material. As a specific example of the use of the data, EPA works closel y with CBP to combat the import of controlled substances that are illegall y imported into the United States. EPA provides CBP with information identifying controlled substances that are prohibited and/or restricted from being imported, and requests that CBP contact EPA if there are questions regarding the leg ality of a shipment. When a shipment arrives at the border containing a controlled substance that is prohibited, CBP either contact s EPA to request additional guidance or take s enforcement action .Page 5 of 26

The smuggling and distribution of ozone - depleting substan ces are being investigated through a multi - agency

initiative known as Operation Catch - 22. Operation Catch - 22 has included the successful conviction of nearl y a doz en individuals and corporations at every level of the refrigerant gas smuggling and distribution chain. For example, Carlos A. Garcia pled guilty in April 2012 to a charge of knowingl y receiving, buying, selling and facilitating the transportation, concealment, and sale of approximately

13,600 kilograms of the ozone - depleting substance HCFC - 22. HCFC - 22 is a widely used refrigerant for residential heat pump and air- conditioning s ys tems. Garcia’s employer, Mar - Cone Appliance Parts Co. (Marcone), was convicted and sentenced for their role in the illicit conduct and ordered to pay a $500,0 00 criminal fine, a $400,000 community service pay ment, and was ordered to forfeit to the United States $190,534.70 in illegal proceeds. 3 . Nonduplication, Consultations, and Other Collection Criteria **a) Nonduplication**  None of the information requested from respondents under this I CR is available from other sources because it is proprietary information submitted solely in response to CAAA 603(b). **b) Public Notice Required Prior to ICR Submission to OMB**  In compliance with the Paperwork Reduction Act of 1995, EPA issued a public notice in the Federal Register on

______________ . ______ comments were received. **c) Consultations**  The recordkeeping and reporting requirements were established in the original HCFC allowance s ys tem rule promulgated January 21, 2003 (68 FR 2820). Prior to that rule, in 1998, EPA conducted two stakeholder meetings for members of the industry about the HCFC allowance s ys tem. In preparation for the 2010 reduction in HCFC production and con sumption, EPA anal yz ed the future servicing needs for HCFC equipment and refined that anal ys is using stakeholder input from meetings held on September 29, 2006 and June 16, 2008. EPA’s report, The U.S. Phaseout of HCFCs: Projected Servicing Needs in the U.S. AirConditioning and Refrigeration Sector ("the Servicing Tail Report") , assessed the demand for HCFCs in 2010 and beyond. The first version of the Servicing Tail Report was released in November 2005 and announced via a Federal Register Notice of Data Availability (NODA) on November 4, 2005 (70 FR 67172). Comments received on the NODA were considered and a second version was released in September 2006. This version was distributed at a September 29, 2006 stakeholder meeting, where the results were summ arized and information on regulations under consideration was provided. Many of the assumptions made to model the demand for HCFC - 22 were presented to the Air- Conditioning, Heating and Refrigeration Institute (AHRI) in April 2007, and based on feedback rec eived, the assumptions were revised. A presentation on the results of the anal ys is was given January 30, 2007 at the winter meeting of the American Society of Heating, Refrigerating, and Air- Conditioning Engineers (ASHRAE). Comments provided onPage 6 of 26

the second version were considered and a third version was released in June 2008. Another stakeholder meeting was held June 16, 2008 where the results of the anal ys is were presented and additional information regarding regulations under development was provided. A summary of the June 16, 2008 stakeholder meeting is in the docket EPA - HQ - OAR - 2009 - 0496. The final version of the report concentrates on the most widely used HCFC (HCFC - 22) in the sector where it is most used (refrigeration and air- conditioning). This infor mation was used in preparing the proposed, and then final "200 9 Allocation Rule," (73 FR 78680 and 74 FR 66412). This rule provided production and consumption allowances for HCFC - 22 and other HCFCs for the years 2010 through 2014. However, the baselines an d calendar year allowances for HCFC - 22 and HCFC - 142b were vacated b y the U.S. Court of Appeals for the District of Columbia Circuit (Court) decision in Arkema v. EPA (618 F.3d 1, D.C. Cir. 2010) . In response to the Court’s partial vacatur of the 200 9 Alloc ation Rule, EPA published an interim final rule issuing HCFC - 22 and HCFC - 142b production and consumption allowances for 2011. Following that interim final rule, EPA proposed and finalized /will finalize HCFC - 22 and HCFC - 142b baselines and calendar year allo wances for 2012 - 2014 (77 FR 237 and 77 FR XXXX). In the proposed rule, EPA took comment on an updated anal ys is of the HCFC - 22 market and proposed to decrease the amount of allowed HCFC - 22 consumption in 2012 - 2014. **d) Effects of Less Frequent**  **Collection** Less frequent collection of data would compromise EPA’s ability to fulfill the statutory requirement under section 603 of the CAAA to monitor production, import and export levels. Less frequent collection of information would hinder EPA's ability to identify

a violation of the regulation s . Our quarterly reporting requirements provide EPA the ability to resolve in a timel y manner discrepancies in the data reported to us. Less frequent reporting c ould put the United States in a non - compliance status under the Protocol. Q uarterl y reporting allows EPA the necessary time to take actions if production, import or export activities begin to exceed Protocol limits or the limits set in Section 605 of Title VI in the CAAA . **e) General Gui**  **delines** In formation collection performed under this clearance will follow all of OMB’s General Guidelines regarding federal data collection. **f) Confidentiality**  EPA informs respondents that they may assert claims of business confidentiality for any of the information they

submit. In formation claimed confidential is treated in accordance with the procedures for handling information claimed as confidential under 40 CFR Part 2, Subpart B , and 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).Page 7 of 26

**g) Sensitive Questions**  This section is not applicable because this ICR does not involve matters of a sensitive nature. 4. The Respondents and the Information Requested **a) Respondents/NAICS Codes**  Table 1 list the NAICS code associated with producers, importers, exporters, transformers, and destro yers of HCFCs affected b y the reporting and recordkeeping requirements covered under this ICR.

**Table 1: NAICS Codes Associated with the ICR Category**  **NAICS Code**  **Examples of Regulated Entities** Industrial Gas Manufacturing 325120 Chlorofluorocarbon gas manufacturing and import **b) Information Requested**  EPA monitors the sy stem of production allowances and consumption allowances for the production and import of class II controlled substances through quarterl y and annual reports. Producers, importers, exporters and others identified in §82.16, §82.18, §82.20, §82.23, and §82.24 must maintain records for three years and also report information to EPA, as follows : (i) Data Items **Producers ( §82.24**  **(b) )**   The following information must be reported:

 The quantity

of production of each class II controlled substance used in processes resulting in their transformation by the producer and the quantity intended for transformation b y a second party;

 The quantity

of production of each class II controlled substance used in processes resulting in their destruction by the producer and the quantity intended for destruction by a second party;

 The expended allowances for each class II controlled substance;

 The producer's total of expended and unexp ended production allowances, consumption allowances, export production allowances, and Article 5 allowances at the end of that quarter;

 The quantity

of class II controlled substances sold or transferred during the quarter to a person other than the producer for use in processes resulting in their transformation or eventual destruction;Page 8 of 26  A list of the amounts and names of class II controlled substances, exported by the producer to a Party to the Protocol, that will be transformed or destro ye d and therefore we re not produced expending production or consumption allowances;

 For transformation in the U.S. or by a person of another Party, one cop y of a transformation verification from the transformer for a specific class II controlled substance and a list of additi onal quantities shipped to that same transformer for the quarter;

 For destruction in the U.S. or by a person of another Party, one cop y of a destruction verification for a particular destro ye r, destro ying the same class II controlled substance, and a list of additional quantities shipped to that same destro ye r for the quarter;

 A list of U.S. purchasers of class II controlled substances that exported to a Party to the Protocol in cases when export production allowances were expended during production;

 A list of U.S. purchasers of class II controlled substances that exported to Article 5 countries in cases when Article 5 allowances were expended during production; and

 A list of HCFC 141b - exemption allowance holders from whom orders were received and the quanti ty

of HCFC - 141b requested and produced.  The following records must be retained :

 Dated records of the quantity of each class II controlled substance produced at each facility ; produced and/or sold for use in processes that result in their transformation and/or destruction; produced with export production allowances or Article 5 allowances;

 Copies of invoices or receipts documenting sale of class II controlled substances for use in processes that result in their transformation and/or destruction;

 Dated re cords of the quantity of each class II controlled substance used at each facility as feedstocks or destroyed in the manufacture of a class II controlled substance or in the manufacture of any other substance, and any cl ass II controlled substance introduce d into the production process of the same class II controlled substance at each facility ;

 Dated records of the quantity of raw materials and feedstock chemicals used at each facility for the production of class II substances;

 Dated records of the shipment s of each class II controlled substance produced at each plant;

 Records of the quantity of class II controlled substances, the date received, and names and addresses of the source of used materials containing class II controlled substances which are recycl ed or reclaimed at each plant;

 Records of the date, the class II controlled substance, and the estimated quantity of any spill or release of a class II controlled substance that equals or exceeds 100 pounds;

 Transformation verification in the case of trans formation, or destruction verification, in the case of destruction, showing that the purchaser or recipient of a class II controlled substance, in the U.S. or in another country that is a Party, certifies the intent to either transform or destro y the class II controlled substance, or sell the classPage 9 of 26 II controlled substance for transformation or destruction in cases when allowances were not expended;

 Written verifications from a U.S. purchaser that the class II controlled substance was exported to a Party

in cases where export production allowances and/or Article 5 allowances were expended to produce the class II substance; and

 Written verifications from a U.S. purchaser that HCFC - 141b was manufactured for the express purpose of meeting HCFC - 141b exemption nee ds, in cases where HCFC 141b exemption allowances were expended to produce the HCFC - 141b. **Importers ( §82.24**  **(c) )**   The following information must be reported:

 Summaries of the required records for the previous quarter (as described below) ;

 The total quantity

imported of each class II controlled substance for that quarter;

 The commodity

code for the class II controlled substances imported;

 The quantity

of those class II controlled substances imported that are used class II controlled substances;

 The qu antity

of class II controlled substances imported for that quarter and totaled by chemical for the control period to date;

 The importer's total sum of expended and unexpended consumption allowances b y chemical as of the end of that quarter;

 The quantity

of class II controlled substances imported for use in processes resulting in their transformation or destruction;

 The quantity

of class II controlled substances sold or transferred during that quarter to each person for use in processes resulting in their transformation or eventual destruction;

 Transformation verifications showing that the purchaser or recipient of imported class II controlled substances intends to transform those substances or destruction verifications showing that the purchaser or recipient intends to destroy the class II controlled substances; and

 A list of the HCFC 141b - exemption allowance holders from whom orders were received and the quantity of HCFC - 141b requested and imported.  The following records must be retained :

 The quantity

of e ach class II substance imported, either alone or in mixtures, and the percentage of each mixture containing a class II substance;

 The quantity

of those class II controlled substances imported that are used and the information provided with the petition;

 Th e quantity

of class II controlled substances other than transhipments or used substances imported for use in processes resulting in their transformation or destruction;

 The quantity

of class II controlled substances other than transhipments or used substan ces imported and sold for use in processes that result in their destruction or transformation;Page 10 of 26  For each quantity of class II controlled substance imported: the date imported; the port of entry ; the country

from which the class II controlled substances were imported; the commodity

code for the class II controlled substances shipped; the importer number for the shipment; a cop y of the bill of lading; import invoices; quantity of imports of used class II controlled substances; and the U.S. Customs Summary Entry form;

 Dated records of the sale or transfer of class II controlled substances for use in processes resulting in their transformation or destruction;

 Copies of verification of transformation or destruction; and

 Written verification from a U.S. purchaser that HCFC - 141b was imported to meet HCFC - 141b exemption needs, in cases where HCFC - 141b exemption allowances were expended to import the HCFC - 141b.  The following information must be submitted in a petition for importing used Class II substances:

- The name and quantity of the used class II controlled substance to be imported;

- The name and address of the importer, the importer ID number, the contact person, and the phone and fax numbers;

- The name, address, contact person, (including phon e number and email ) of all previous source facilities from which the used class II controlled substance was recovered;

- A detailed description of the previous use of the class II controlled substance at each source facility

and a best estimate o f when the specific controlled substance was put into the equipment at each source facility , and, when possible, documents indicating the date the material was put into the equipment;

- A list of the name, make and model number of the equipment from which th e material was recovered at each source facility ;

- The name, address, contact person, (including phone number and email) of the exporter and of all persons to whom the material was transferred or sold after it was recovered from the source facility;

- The U.S. port of entry

for the import, the expected date of shipment and the vessel transporting the chemical. If at the time of submitting a petition the importer does not know the U.S. port of entry , the expected date of shipment and the vessel transp orting the chemical, and the importer receives a non - objection notice for the individual shipment in the petition, the importer is required to notify the Administrator of this information prior to the actual U.S. Customs entry of the individual shipment;

- A description of the intended use of the used class II controlled substance, and, when possible, the name, address, contact person, phone number and email of the ultimate purchaser in the United States;

- The name, address, contact person, phone number and email of the U.S. reclamation facility , where applicable;

- If someone at the source facility recovered the class II controlled substance from the equipment, the name and phone and email of that person;

- If the imported class II controlled substance was reclaimed in a foreign Party , the name, address, contact person, phone number and email of any or all foreign reclamation facility(ies) responsible for reclaiming the cited shipment;Page 11 of 26

- An export license from the appropriate government agency in the country

of export and, if recovered in another country , the export license from the appropriate government agency

in that country ;

- If the imported used class II controlled substance is intended to be sold as a refrigerant in the U .S., the name and address of the U.S. reclaimer who will bring the material to the standard required under subpart F of this part, if not already reclaimed to those specifications; and

- A certification of accuracy of the information submitted in the petitio n.  A person receiving an objection notice from the Administrator may re -petition within ten working day s after receipt, only if the Administrator indicated “insufficient information” as the basis for the objection notice for the original petition.  A pers on receiving a non - objection notice from the Administrator for a petition to import used class II controlled substances must maintain the following records:

- A cop y of the petition submitted, the EPA non - objection notice, the bill of lading for the import, and U.S. Customs entry documents for the import that must include one of the commodity

codes Appendix K to this subpart.  The following records must be retained b y persons that trans - s hip class II controlled substances:

 Records that indicate that the cla ss II controlled substance shipment originated in a foreign country , is destined for another foreign country , and will not enter interstate commerce within the United States.  Any importer who brings a container with a heel must indicate on its bill of lading or invoice that the class II controlled substance in the container is a heel.  The following information on a container with a heel must be reported quarterly :

 The quantity

of the heel brought into the U.S.;

 Certification that the residual quantity in each shipment is no more than 10 percent of the volume of the container; and that the residual quantity in each shipment will either: (A) Remain in the container and be included in a future shipment; (B) be recovered and transformed; (C) be recovered and destroyed; or (D) be recovered for a non emissive use.  Any importer who brings a container with a heel into the U.S. must report on the final disposition of each shipment within 45 day s of the end of the control period. **Exporters (**  **§82.24 (d)**  **)**  The foll owing information must be reported:

 The names and addresses of the exporter and the recipient of the exports;

 The exporter's Employer Identification Number;

 The ty pe and quantity of each class II controlled substance exported and what percentage, if any of the class II controlled substance is used;Page 12 of 26  The date on which, and the port from which, the class II controlled substances were exported from the U.S. or its territories;

 The country

to which the class II controlled substances were exported;

 The quantity e xported to each Article 5 country ;

 The commodity

code for the class II controlled substances shipped;

 For persons reporting transformation or destruction, the invoice or sales agreement containing language similar to the transformation verifications that the purchaser or recipient of imported class II controlled substances intends to transform those substances, or destruction verifications showing that the purchaser or recipient intends to destroy the class II controlled substances;  In cases of export using export production allowances (in addition to applicable exporting requirements listed above), the following information must be reported:

 The Employer Identification Number on the Shipper's Export Declaration Form or Employer Identification Number of the shipping agent shown on the U.S. Customs Form 7525;

 The exporting vessel on which the class II controlled substances were shipped; and

 The quantity

exported to each Party.  In cases of export using Article 5 allowances (in addition to applicable exporting requirements above), the following information must be reported:

 The Employer Identification Number on the Shipper's Export Declaration Form or Employer Identification Number of the shipping agent shown on the U.S. Customs Form 7525; and

 The exporting ves sel on which the class II controlled substances were shipped.  In cases of export of used class II controlled substances, the bill of lading or invoice must indicate that the class II controlled substance is used, as defined in §82.3. **Transformers and Destroyers (**  **§82.24 (e)**  **)**  The following records must be retained:

 Copies of the invoices or receipts documenting the sale or transfer of the class II controlled substances to the person;

 Records identifying the producer or importer of the cl ass II controlled substances received b y the person;

 Dated records of inventories of class II controlled substances at each plant on the first day of each quarter;

 Dated records of the quantity of each class II controlled substance transformed or destroyed ;

 A cop y of the person's transformation verification in the case where class II controlled substances were purchased or transferred for transformation purposes;

 Dated records of the names, commercial use, and quantities of the resulting chemical(s) when th e class II controlled substances are transformed;

 Dated records of shipments to purchasers of the resulting chemical(s) when the class II controlled substances are transformed.Page 13 of 26  A cop y of the person's destruction verification in the case where class II controlled substances were purchased or transferred for destruction purposes;  The following information on transformation and destruction must be reported:

 The names and quantities of the class II controlled substances transformed;

 The names and quantities of the class II controlled substances destro ye d;  In cases of purchasing class II controlled substances for purposes of transformation, purchasers must provide the producer or importer with a transformation verification, containing the following information:

 Id entity

and address of the person intending to transform the class II controlled substances;

 The quantity

of class II controlled substances intended for transformation;

 Id entity

of shipments by

purchase order number(s), purcha ser account number(s), by location(s), or other means of identification;

 Period of time over which the person intends to transform the class II controlled substances; and

 Signature of the verifying person.  The following information on destruction must be reported:

 A one - time report stating the destruction unit's destruction efficiency , the methods used to record the volume destro yed and those methodologies used to determine destruction efficiency , and the name of other relevant federal or state regulations that may apply to the destruction process.

 Any changes to this information must be reflected in a revision to be submitted to EPA within 60 days of the change(s).  In cases of purchasing class II controlled substances for purposes of destruction that were originall y produced without expending allowances, purchasers must provide the producer or importer from whom it purchased or received the class II controlled substance a destruction verification containing the following information:

 Id entity

and address of the person intending to destroy class II controlled substances;

 In formation about whether those class II controlled substances will be completely destroyed, or less than completely destro ye d, in which case the destruction efficiency at which such substances will be destroyed must be included;

 Period of time over which the person intends to destroy class II controlled substances; and

 Signature of the verifying person. **HCFC -**  **141b Exemption Petitioners (**  **§82.16 (h)**  **)**  A person petitioning for an HCF C - 141b exemption must submit the following:

 Name and address of the HCFC - 141b formulator, U.S. government entity or non governmental space vehicle entity ;

 Name of contact person, phone number, fax number and e - mail address;Page 14 of 26  Quantity

of HCFC - 141b needed for each relevant calendar year, supported by documentation about past use for at least the previous three ye ars;

 Quantities of HCFC - 141b, if any , contained in s ystems that were sold to other sy stems houses for at least the previous three ye ars;

 Description of the markets and applications served by the use of HCFC - 141b or sy stems based on HCFC - 141b;

 Technical description of processes in which HCFC - 141b is being used;

 Technical description of the specific conditions under which the product will be applied;

 Technical description of why alternatives and substitutes are not sufficient to eliminate the use of HCFC - 141b;

 Amount of stockpiled HCFC - 141b (on - hand, taken title to, or available from a supplier) along with a detailed anal ys is showing why stockpiled, re covered or recycled quantities are deemed to be unavailable, or technically or commercially

infeasible for use (for example, taking into consideration undue costs for storage and transportation);

 An estimate of the number of control periods over which such an exemption would be necessary ;

 A detailed description of continuing investigations into and progress on possible alternatives and substitutes;

 A list of alternatives considered, purchased or sampled, including dates and copies of receipts for verificati on;

 A summary

of the petitioner's in - house development program including summaries of all relevant test results and their significance to subsequent decision - making and technology

selection. Full supporting test data must be available on request including alternative tested and date on which it was tested;

 A clear statement of the preferred technical option(s) being pursued at the time of the petition and the reasoning for this selection;

 A summary

of product test results conducted on the preferred technical option(s) by accredited organizations in order to determine whether products meet applicable codes. Relevant test reports and certifications must be made available on request; and

 A description of the further development testing to be carried out over th e number of control periods identified. **Persons allocated HCFC -**  **141b Exemption Allowances (**  **§82.24 (g)**  **)**  Semi - annual report containing the following information:

 Total quantity

HCFC - 141b received during the 6 month period; and

 The identity

of the supplier of HCFC - 141b on a shipment - by- shipment basis during the 6 month period.  The following records must be retained :

 Records of letters to producers and importers conferring unexpended HCFC - 141b exemption allowances for the specified control period in the notice;

 Orders for the production or import of HCFC - 141b under those letters; andPage 15 of 26  Written verifications that the HCFC - 141b was produced or imported for the express purpose of meeting HCFC - 141b exemption needs and that the quantity will not be resold. **Requ est for Additional Class II Consumption Allowances**  **( §82.20)**   The following information must be submitted in a request for additional consumption allowances:

 The identities and addresses of the exporter and the recipient of the exports;

 The exporter's Emplo ye r Identification Number;

 The names and telephone numbers of contact persons for the exporter and the recipient;

 The quantity

and ty pe of class II controlled substances reported;

 The source of the class II controlled substances and the date purchased;

 The date on which, and the port from which, the class II controlled substances were exported from the U.S. or its territories;

 The country

to which the class II controlled substances were exported;

 A cop y of the bill of lading and the invoice indicating th e net quantity of class II controlled substances shipped and documenting the sale of the class II controlled substances to the purchaser;

 The commodity

codes of the class II controlled substances reported; and

 A written statement from the producer that the class II controlled substances were produced with expended allowances.  Persons requesting a trade from a Party to increase or decrease its production allowances, export production allowances, or Article 5 allowances, for a specified control period, must submit the following information to EPA:

 A signed document from the principal diplomatic representative in that nation's embassy in the U.S. stating that the appropriate authority within that nation will establish or revise production limits for the nation to reflect the trade :

 A true cop y of the document that sets forth the following:  The identity

and address of the person;  The identity

of the Party;  The names and telephone numbers of contact persons for the person and for the Party ;  The chemical ty

pe and quantity

of production being traded;  Documentation that the Party possesses the necessary

quantity of unexpended production rights;  The control period(s) to which the trade applies; and  For increased production intended for export to the Party from whom the allowances would be received, a signed statement of intent to export to the Party .  A person requesting a trade to a Party to increase or decrease its production allowances, export production allowances, or Article 5 allowances, f or a specified control period, must submit a request to EPA that sets forth the following information:Page 16 of 26  The identity

and address of the person;

 The identity

of the Party;

 The names and telephone numbers of contact persons for the person and for the Party;

 The chemical ty

pe and quantity

of allowable production being traded; and

 The control period(s) to which the trade applies. **Domestic Transfers of Allowances for class II controlled substances (**  **§82.23)**  A person must submit the following information for inter- company transfers:

 The identities and addresses of the transferor and the transferee;

 The name and telephone numbers of contact persons for the transferor and the transferee;

 The ty pe of allowances being transferred, including the names of the class II controlled substances for which allowances are to be transferred;

 The quantity

of allowances being transferred;

 The control period(s) for which the allowances are being transferred;

 The quantity

of unexpended allowances of the typ e and for the control p eriod being transferred that the transferor holds under authority of this subpart on the date the claim is submitted to EPA; and

 For trades of consumption allowances, production allowances, export production allowances, or Article 5 allowances, the quantity of the 0.1 percent offset applied to the unweighted quantity traded that will be deducted from the transferor's allowance balance.  A person must submit the following information for inter-pollutant transfers:

 The identity

and address of the transferor;

 The name and telephone number of a contact person for the transferor;

 The ty pe of allowances being converted, including the names of the class II controlled substances for which allowances are to be converted;

 The quantity

and ty pe of allowances to be conv erted;

 The quantity

of allowances to be subtracted from the transferor's unexpended allowances for the first class II controlled substance, to be equal to 100.1 percent of the quantity

of allowances converted;

 The quantity

of allowances to be added to the transferee's unexpended allowances for the second class II controlled substance, to be equal to the quantity of allowances for the first class II controlled substance being converted multiplied by the quotient of the ozone depletion potential of the first class II controlled substance divided by the ozone depletion potential of the second class II controlled substance;

 The control period(s) for which the allowances are being converted; and

 The quantity

of unexpended allowances of the typ e and for the contro l period being converted that the transferor holds under authority of this subpart as of the date the claim is submitted to EPA.Page 17 of 26

 A person receiving a notice from the Administrator disallowing an inter- company or inter-pollutant transfer may file a notice of appeal, with supporting reasons, with the Administrator within 10 working day s after receipt of notification. (ii) Respondent Activities  Producers must submit quarterl y reports and keep records.  Importers must:

- Submit quarterly

reports and keep records

- For imports of used controlled substances, submit information in a petition and re petition and keep records of petitions ;

- Indicate specified information of an import of heels on bill of lading; and

- Report quarterl y on a co ntainer with heels and include the final disposition of each shipment of a container with heels in the report submitted within 45 days of the end of the control period.  Exporters must submit quarterl y reports and ensure bill of lading or invoice indicates that the class II controlled substance is used, as applicable.  Transformers and destroyers must:

- Submit annual reports within each control period within 45 day s of the end of such control period, and keep records, if applicable;

- Submit a transformation v erification (transformers only) to the producer or importer, if applicable;

- Submit a one - time destruction efficiency report to EPA (destro yers onl y), as applicable; and

- Submit a destruction verification (destro ye rs onl y) to the producer or importer, as app licable.  Persons wanting to petition for an HCFC - 141b exemption allowance must submit a petition.  Persons allocated HCFC - 141b exemption allowances must s ubmit a report semi - annuall y and keep records.  Persons requesting additional consumption allowances mu st s ubmit a report on a transactional basis.  Persons requesting international transfers of allowances must submit information requirements on a transactional basis.  Persons wanting to domestically transfer allowances of class II controlled substances must:

 Submit a report for inter- company transfers and/or inter-pollutant transfers on a transactional basis, as required by §82.23(a) and §82.23(b), respectivel y; and

 File a notice of appeal, as applicable.  Persons wanting to increase or decrease production allowances, export production allowances, or Article 5 allowances, for a specified control period through trades with another Party to the Protocol must submit a request on a trade from a Party and a trade to a Party , on a transactional basis, as applicabl e. All records and reports must comply with requirements for class II controlled ODS in Subpart A of the regulations. Reports and records associated with the reports listed above mustPage 18 of 26

be kept for three ye ars. All amounts must be reported in kilograms. The recordkeeping requirements pertain to original documents that are held by companies in the normal course of conducting business such as Customs entry forms, accounts of daily

production runs, sales invoices, and bills of lading. In formation from these rec ordkeeping documents is summarized in reports. Recordkeeping requirements are designed to aid EPA in compliance monitoring, site inspec tion, and enforcement actions. 5. The Information Collected : Agency Activities, Collection Methodology , and Information Management **a) Agency Activities**   Notify

producers/importers/exporters of baseline allowances;  Modify the ODS Tracking S ys tem to incorporate revisions to the regulations ;  Revise guidance document s to describe reporting requirements;  Enter and store information submitted from companies in the ODS Tracking S ys tem;  Respond to companies submitting tracked/monitored information, such as requests for transfers;  Review petitions to import used HCFCs;  Review petitions requesting HCFC - 141b exemption s ;  Review information and conduct compliance monitoring activities related to restrictions on production, import, export, transformation and destruction of HCFCs for individual companies;  Inspect records maintained by producers, importers, exporters, transformers, and destroyers of HCFCs;  Review information in the tracking s ys tem to ensure U.S. is not exceeding consumption and production caps agreed to as a Party to the Protocol;  Review information in the ODS Tracking S ys tem to ensure exempted production and imports do not exceed limits in Section 605 of Title VIof the CAAA;  Compile reports mandated by U.S. obligations under the Protocol and Title VI of the CAAA, including Reports to Congress. **b) Collection Methodology and Management**  EPA provides forms for regulat ed entities to use to report the required information. They are available on the EPA’s Stratospheric Ozone web site at : http://www.epa.gov/ozone/record/index.html. Inaddition, online instruction documents are available for class I, class II, and methylbromide reporting forms, entitled, “W hat reporting forms should I complete?” and “Helpful Hints for Completing EPA’s Reporting Forms” to assist participants in completing the forms. Reporting forms can be sent to EPA electronicall y, b y mail , private courier, or fax. Although the use of the forms is voluntary , almost all respondents use them. EPA has implemented an electronic reporting s ys tem, which transmits the bulk of the reports EPA receives.Page 19 of 26

**c) Small Entity Flexibility**  Much of this information collection is required b y statute. Any additional information required is collected in response to Congressional requests for reports and U.S. reporting obligations under the Protocol. The EPA database manager activel y works with small entities to resolve reporting issues. **d) Collection Schedule**  The collection schedule is as follows:  Producers, importers, and exporters report to EPA quarterl y (45 day s after the end of each quarter).  Persons that transform and/or destroy class II controlled substances report to EPA annually (45 day s after the end of the control period).  Persons petitioning for HCFC - 141b exemption allowances ; transferring consumption allowances to another company or to another chemical ; requesting additional consumption allowances ; requesting international transfer of allowances ; requesting a trade from or to a Party t o increase or decrease production allowances ; exporting production allowances or Article 5 allowances ; or importing used class II controlled substances (i.e., petition) must submit reports to EPA on a transactional basis.  Entities holding HCFC - 141b exemption allowances report to EPA semi - annually (30 days after the end of the second and fourth quarters) . 6 . Estimating the B urden and Cost of Collection **a) Estimating Respondent Burden**  The basis of the anal ys is is the identification of the principal steps involved in complying with EPA recordkeeping and reporting requirements and the estimated burden associated with each step . The burden is estimated by identifying the number of times the step will be undertaken and the number of hours required to complete each step. The burden estimates presented in this section are based on the quarterl y, semiannual, annual, or other (per transaction) reporting requirements ; EPA’s experience wi th reporting under both the CFC and HCFC allowance sy stems in the past ; and dialogue with industry representatives. It i s estimated that the burden to respondents submitting paper reports is approximately 4.5 hours per report prepared. This assumption i s based on previous consultations with industry representatives conducted for the preparation of ICR 1432.25 and I CR 1432.29 (OMB Control Number 2060 - 0170) , as discussed in section 3c of th is I CR. Four hours are allotted for data compilation and 0.5 hours for report preparation. The burden to respondents submitting petitions is estimated at eight hours per petition prepared. Additional hours are assumed because petitions must be prepared individually depending on the respondent’s request , and no standard petition form exis ts.Page 20 of 26

The process of preparing electronic submittals is s assumed to take approximately 4 hours per report prepared . This assumption, similar to that for paper reporting, was based on the consultations with industry conducted for the preparation of ICR 1432. 29 . This indicated that the majority

of respondents maintain their data in an electronic format and manuall y transcribe their data to the paper forms. However, because the option of electronic reporting will eliminate the transcription step (i.e., report preparation) as required using the paper forms, the estimated reporting time is reduced from 4.5 hours to 4 hours. Inaddition, it i s assumed that eight hours would be spent during the first year of electronic reporting for the respondents to become familiar with the electronic reporting process, organize their files and data appropriatel y, and prepare a template to store their data in the correct format for submission through the agency ’s CDX and eventual import into the ODS Tracking System . (Any additional burden associated with submitting data through CDX, such as registration, is accounted f or in ICR 2002.04, “Cross - Media Electronic Reporting and Recordkeeping Rule,” OMB Control Number 2025 - 0003.) The eight hours are annualized over the three years of this ICR, resulting in an additional annual burden to an electronic reporter of 2.7 hours ( i.e., 8 hours /3 ye ars = 2. 7 hours ) . For respondents that must submit quarterly , this translates to a total annual burden of 18.7 hours (i.e., 4 hours/report x 4 reports/year + 2.7 hours/year = 18.7 hours). Since the last I CR, for respondents that have es tablished electronic reporting procedures , this I CR differentiates between burden for respondents that have established electronic reporting and burden for new respondents that may

begin to report electronicall y (with annualized start - up costs of 2.7 hour s removed for the established respondent burden) . **b) Estimating Respondent Cost**  To determine respondent costs, an average hourly wage rate of $ 47 . 73 per hour , the hourly wage rate for professional and related persons, was derived from the Bureau of Labor Statistics Employer Cost and Employee Compensation, Table 2 (“civilian workers, by occupational and industry group”), March 2012 . A 110 percent increase was added to reflect the estimated additional costs for overhead and fringe, which increased th e wage rate to $ 100.23 per hour. Burden hours, as described above, were multiplied by the labor rate to determine respondent costs. Operations and Maintenance (O&M) costs, including photocop ying, packaging, and postage, were estimated for all resp ondents submitting paper reports. These costs were estimated at $ 5 .00 per report. Start - up costs for report submittal were estimated to be $0 because no new recordkeeping or reporting requirements have be en added since the previous ICR , and it was assume d that onl y those respondents with the necessary computer equipment to report electronically would choose this option . **c) Estimating Agency Burden and Cost**  This analysis identifies the steps involved in implementing and operating the system. The costs associated with each step have been estimated by identifying the number of times the step will be undertaken, the number of hours required to complete each step, and the total dollar cost.Page 21 of 26

Costs are subdivid ed into agency and contractor costs. The average hourl y rates for EPA technical and managerial staff of $ 36.63 and $ 49.33 , respectivel y, are derived from the 2012 annual base pay

table , which was retrieved from the Office of Personnel Management website. EPA then multiplied hourly rates by the standard government benefits multiplication factor of 1.6 to get hourl y rates of $ 58.61 for technical staff and $ 78.93 for managerial staff. The cost of contractor time and overhead is valued at $ 8 8 .00 per h our, including overhead and fringe. The number of occurrences of each activity is based on the reporting requirements and EPA’s experience with reporting under both the CFC and HCFC allowance s ys tems. **d) Estimating the Respondent Universe and Total Burden**  **and Costs** In this section, EPA estimates the number of respondents under each of the information collection requirements in this I CR. EPA tracks the number of respondents and submittals under the program through the ODS Tracking S ys tem. EPA referred to historical data in the ODS Tracking S ys tem to estimate the annual number of respondents in this IC R, as shown in Table 2 . Because not all submitted reports/petitions/requests are tracked b y the ODS Tracking System, estimates for some of the number of respondents were based on the previous and expected receipt of these forms. **Table 2**  **: Number of Respon dents**  **a Type of Respondent**  **Annual Number of Respondents**  Producer 7 Importerb 3 4 Exporter 1 5 Second - Party Transformers 7 Second - Party Destroyers 7 HCFC - 141b Exemption Allowance Recipients c 0 Otherd 1 7 **Total Respondents**  **49 a** **Numbers in the table are not a dditive.**  The information collection will only affect 49 distinct companies. Several respondents submit multiple report types (e.g., producers can also be exporters). b Includes respondents that petition to import used substances. c Represents petitioners and recipients of HCFC - 141b exemption allowances. dRepresents requests for additional consumption allowances and international/domestic transfer of allowance reports. EPA expects that large companies, which produce the majority of the reports, will s ubmit electronically

to EPA via the CDX, while others will continue to report by paper. G iven that respondents’ annual burden will vary depending on whether they report by paper or electronically , EPA estimated the average annual number of respondents that would report b y paper or electronicall y during the three - ye ar period for each report. In 20 11 , a total of 8 companies submitted a total of 53 importer, exporter , and producer reports electronically . Based on this information in addition to experience with electronic reporting and plans to expand electronic reporting , EPA expects that an average of 70 reports will be submitted electronicall y each ye ar over the next three ye ars. The estimates by report are presented in Table 3. These respondent estimates are used in the burden calculations presented in Table 4.Page 22 of 26

**Table 3**  **. Average Annual Number of Respondents that Report by Paper**  **or**

**Electronically During Three -** **Year Life of ICR Type of Respondent**  **Average Annual Number of Respondents Reporting by Paper**  **Reporting Electronically** Producer 4 3 Importer 26 8 Exporter 10 5 Second - Party Transformers 7 0 Second - Party Destroyers 7 0 HCFC - 141b Exemption Allowance Recipients 0 0 Othera 14 3 a Includes requests for additional consumption allowances and international/domestic transfer of allowance reports. Tables 4 and 5 below show the assumptions used and the calculations made to determine respondent and agency

total burden and costs.Page 23 of 26

**Table 4. Respondent Burden and Costs Estimates**  **Information Collection Activity: Recordkeeping a**  **nd Reporting a**  **Hours and Costs Per Activity Total Hours and Costs**  Hours/ Activity b Number of

Activities/ Year Annualized

Startup Hours Hours/

Year Labor

Costs/Year Annual ized Capital

Startup Costs Annual O&M

Costs Number of

Respondents/ Activity Total Hours/

Year Total Cost/Year **Producer** Submit Quarterly Reports Paper 4.5 4 0.0 18.00 $1,804.1 4 $0.00 $20.00 4 72.0 $7,296.56 Electronic (Established) 4.0 4 0.0 16.00 $1,603 .68 $0.00 $0.00 3 48.0 $4,811.04 Electronic (New) 4.0 4 2.7 18.70 $1,874.3 0 $0.00 $0.00 0 0.0 $0.00 **Importer** Submit Quarterly Reports Paper 4.5 4 0.0 18.0 $1,804.1 4 $0.00 $20.00 26 468.0 $47,427.64 Electronic (Established) 4.0 4 0.0 16.0 $1,603. 68 $0.00 $0.00 8 128.0 $12,829.44 Electronic (New) 4.0 4 2.7 18.7 $1,874.3 0 $0.00 $0.00 0 0.0 $0.00 Petition to Import Used Substance 8.0 6 0.0 48.0 $4,811. 04 $0.00 $30.00 4 192.0 $19,364.16 **Exporter** Submit Quarterly Reports Paper 4.5 4 0.0 18.0 $1,804.1 4 $0.00 $20.00 10 180 .0 $18,241.94 Electronic (Established) 4.0 4 0.0 16.0 $1,603. 68 $0.00 $0.00 5 80.0 $8,018.64 Electronic (New) 4.0 4 2.7 18.7 $1,874.3 0 $0.00 $0.00 0 0.0 $0.00 **Transformers/Destroyers** Submit Second Party Transformation Report 4.5 1 0.0 4.5 $451.0 4 $0.00 $5.00 7 31.5 $3,192.25 Submit Second Party Destruction Report 4.5 1 0.0 4.5 $451.0 4 $0.00 $5.00 7 31.5 $3,192.25 Submit Transformation Verification Report 4.5 1 0.0 4.5 $451.0 4 $0.00 $5.00 7 31.5 $3,192.25 Submit Destruction Efficiency Report 4.5 1 0.0 4.5 $451.0 4 $0.00 $5.00 2 9.0 $912.07 Submit Destruction Verification Report 4.5 1 0.0 4.5 $451.0 4 $0.00 $5.00 7 31.5 $3,192.25 **HCFC -**  **141b Exemption Allowance Recipients** Submit Semi - annual Reports 4.5 2.0 0.0 9.0 $902. 0 7 $0.00 $10.00 0 0 .0 $ 0.00 **Other** Request for Additional Consumption Allowances Paper 4.5 2.0 0.0 9.0 $902.07 $0.00 $ 10 .00 1 9 .0 $912.07 Electronic (Established) 4.0 2.0 0.0 8.0 $801.84 $0.00 $0.00 0 0.0 $0.00 Electronic (New) 4.0 2.0 2.7 10.7 $1,072.46 $0.00 $0.00 3 32 .1 $3,217.38 Submit International Transfer of Allowances Report 4.5 1.0 0.0 4.5 $451.04 $0.00 $5.00 2 9.0 $912.07 Submit Domestic Transfer of Allowances Report 4.5 5.0 0.0 22.5 $2,255.18 $0.00 $25.00 11 247.5 $25,081.93 Petition for HCFC - 141b Exemption Allowances 8.0 1.0 0.0 8.0 $801.84 $0.00 $5.00 0 0.0 $0.00 **Total 107**  **1,600.6 $161,793.14**  a Electronic reporting is only applicable to certain reporting requirements . b Hours per activity were based on consultations with respondents. The similar ICR 1432. 29 used the assumption of 4.5 hours per paper report prepared. Electronic reporting is estimated to require 4 hours per report prepared, with an additional 8 hours during the first year of electronic reporting .Page 24 of 26

**Table 5. Agency Burden and Costs Estimates**  **Information Collection Activity Agency Hours and Costs Per Activity**  **Total Hours and Costs** Managerial Technical Contractor Number of Occurrences per Year Labor

Costs/Year Annual ized

Capital Startup Costs Annual O&M

Costs Total

Hours/Year Total

Cost/Year $ 78.93 $ 58.61 $ 88 .00 Notify Submitters of Baseline Allowances 0.5 1 0 24 $2,353.80 $0.00 $0.00 36.0 $2,353.80 Modify Tracking System 10 26 100 1 $11,113.16 $0.00 $0.00 136.0 $11,113.16 Revise Guidance Document 6 8 30 3 $10,747.38 $0.00 $0.00 132.0 $10,747.38 Enter and Store Information in the Tracking System 0 480 0 1 $28,132.80 $0.00 $0.00 480 .0 $28,132.80 Respond to Companies Submitting Transfer Requests 0 1 0 55 $3,223.55 $0.00 $0.00 55.0 $3,223.55 Review Petitions Submitted to Import Used HCFCs 2 4 0 4 $1,569.20 $0.00 $0.00 24.0 $1,569.20 Review Petitions Submitted Requesting HCFC 141b Exemption Allowances 2 4 0 0 $0.00 $0.00 $0.00 0 .0 $0.00 Review Information and Conduct Compliance Monitoring Activities Related to Restrictions 4 12 20 36 $100,045.44 $0.00 $0.00 1,296.0 $100,045.44 Inspect Records Maintained by Submitters 2 32 0 1 $2,033.38 $0.00 $0.00 34.0 $2,033.38 Review Information in Tracking System to Ensure Non - Exceedance of Montreal Protocol Caps 2 8 40 2 $8,293.48 $0.00 $0.00 100.0 $8,293.48 Review Information in Tracking System to Ensure Non - Exceedance of CAAA Limits 2 8 40 1 $4,146.74 $0.00 $0.00 50.0 $4,146.74 Compile Reports Mandated by Montreal Protocol and CAAA 4 20 40 1 $5,007.92 $0.00 $0.00 64.0 $5,007.92 **Total $176,666.85**  **$0.00 $0.00**  **2,271.5 $176,666.85** Page 25 of 26

**e) Bottom Line Burden Hours**  **and Cost Tables**

**(i) Respondent Tally**  As shown in Table 6 , EPA estimates the total annual hour and cost burden to all respondents to average 1, 6 01 hours and $ 16 1 , 79 3 . The bottom - line burden to respondents over three ye ars is estimated to be 4, 803 hours and $ 485 , 3 79

**Table 6**  **. Total Annual Respondent Hour and Cost Burden Total Hours**  **Per Year Total Labor** 

**Cost Per Year Total Capital** 

**Cost Per Year Total O&M** 

**Cost per Year Total Cost Per** 

**Year** 1,601 $160,4 28 $0 $1,365 **$161,79 3**  **(ii) Agency Tally**  As shown in Table 7 , EPA estimates the total annual hour and cost burden to the agency to be 2, 407 hours and $ 1 76 , 667 . The bottom - line burden to the agency over three ye ars is estimated to be 7, 221 hours and $ 5 30,001 .

**Table 7**  **. Total Annual Agency Hour and Cost Burden Total Hours**  **Per Year Total Labor Cost** 

**Per Year Total Capital** 

**Cost Per Year Total O&M** 

**Cost per Year Total Cost Per** 

**Year** 2,407 $176,667 $0 $0 **$176,667 f)**  **Reasons for Change in Burden** The previousl y approved IC R estimated a total annual respondent burden of 1, 860 hours. By comparison, this I CR estimates a total annual burden of 1, 6 01 hours, which is a decrease of 259 hours. This change is largel y attributed to the establishment and expansion of the electronic reporting program. Since most companies that are expected to report electronically over the next three ye ars are already established electronic reporters , the burden associated with electronic reporting is minimal. Inaddition, the number of petitions submitted requesting HCFC 141b exemption allowances has been reduced from eight to zero due to the reduced need for this exemption and elimination of the need to reappl y for petitions once a petition has been approved. Therefore, a total reduc tion in the reporting burden for respondents, as well as the O&M costs during this ICR period is anticipated . The previousl y approved IC R estimated a total annual agency burden of 2,272 hours. This I CR estimates a total annual burden of 2, 4 07 hours, which is an increase of 1 3 5 hours. This change can be attributed to two significant changes in hour estimates: (1) the number of hours required to “ enter and store information into the Tracking System ” and (2) the number of occurrences per ye ar that the agency is required to “respond to companies submitting transfer request . ” The number of hours required to “ enter and store information into the Tracking Sy stem ” is based on the number of paper and electronic reports submitted, with the burden associated with entering an electronic report being lower than the burden associated with entering a paper report. In the previou s ICR, ambitious assumptions were made about the expansion of the electronic reporting program to c ompanies that had not previously reported electronically . Based on activity observed over the past three ye ars, the portion of reports that arePage 26 of 26

anticipated to be submitted electronicall y over the next three years has decreased. As a result, the total hours required to “ enter and store information into the Tracking System ” has increased. In the previous Class II ICR, the number of occurrences per year that the agency is required to “respond to companies submitting transfer request” was based on the number of respondents and not the number of reports submitted . The agency as a result underestimated the frequency of these repo rts. For this ICR, the number was recalculated to take into account the average number of reports submitted by

each respondent per year . Both of these changes contributed to an increase in the total annual burden to the agency . **g) Burden State**  **ment** The annual public reporting and recordkeeping burden for this collection of information is estim ated to average 5 hours per respo nse . Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying 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 information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currentl y 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 Number EPA - HQ - OAR - 2003 - 0039, 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 Avenue, NW., Washington, D.C. 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 D ocket is (202) 566 - 1742. An electronic version of the public 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 docket, and to access those documents i n the public docket that are available electronically . When in the s ys tem, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory

Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA - HQ OAR - 2003 - 0039 and OMB Control Number 2060 - 0498 in any correspondence.