1
INFORMATION
COLLECTION
REQUEST
OMB­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STRATOSPHERIC
OZONE
PROTECTION
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
ICR:
National
Refrigerant
Recycling
and
Emissions
Reduction
Program
EPA
ICR
Number:
1626.08
OMB
Control
Number:
2060­
0256
1(
b)
Short
Characterization/
Abstract
The
Environmental
Protection
Agency
(
EPA)
has
developed
regulations
under
the
Clean
Air
Act
Amendments
of
1990
(
the
Act)
establishing
standards
and
requirements
regarding
the
use
and
disposal
of
class
I
and
class
II
refrigerants
during
the
service,
maintenance,
repair,
or
disposal
of
refrigeration
and
air­
conditioning
equipment.
Section
608(
c)
of
the
Act
states
that
effective
July
1,
1992
it
is
unlawful
for
any
person
in
the
course
of
maintaining,
servicing,
repairing,
or
disposing
of
refrigeration
or
air­
conditioning
equipment
to
knowingly
vent
or
otherwise
knowingly
release
or
dispose
of
any
class
I
or
class
II
substance
used
as
a
refrigerant
in
the
equipment
in
a
manner
which
permits
the
substance
to
enter
the
environment.

During
1993,
EPA
promulgated
regulations
under
section
608
of
the
Act
for
the
recycling
of
ozone­
depleting
refrigerants
recovered
during
the
servicing
and
disposal
of
air­
conditioning
and
refrigeration
equipment.
These
regulations
were
published
on
May
14,
1993
(
58
FR
28660)
and
codified
in
40
CFR
subpart
F
(
§
82.150
et
seq.).

The
regulations
require
persons
servicing
refrigeration
and
air­
conditioning
equipment
to
observe
certain
service
practices
that
reduce
emissions
of
ozone
depleting
refrigerants.
The
regulations
also
establish
certification
programs
for
technicians,
recovery/
recycling
equipment,
and
off­
site
refrigerant
reclaimers.
In
addition,
EPA
requires
that
ozone­
depleting
refrigerants
contained
"
in
bulk"
in
appliances
be
removed
prior
to
disposal
of
the
appliances
and
that
all
refrigeration
and
air­
conditioning
equipment,
except
for
small
appliances
and
room
air
conditioners,
be
provided
with
a
servicing
aperture
that
facilitates
recovery
of
the
refrigerant.
Moreover,
the
Agency
requires
that
substantial
refrigerant
leaks
in
equipment
be
repaired
when
they
are
discovered.
These
regulations
significantly
reduce
emissions
of
ozone­
depleting
refrigerants,
and
therefore
aid
U.
S.
and
global
efforts
to
minimize
damage
to
the
ozone
layer
and
2
the
environment
as
a
whole.

To
facilitate
compliance
with
and
enforcement
of
section
608
requirements,
EPA
requires
reporting
and
record
keeping
requirements
of
technicians;
technician
certification
programs;
equipment
testing
organizations;
refrigerant
wholesalers
and
purchasers;
refrigerant
reclaimers;
refrigeration
and
air­
conditioning
equipment
owners;
and
other
establishments
that
perform
refrigerant
removal,
service,
or
disposal.
The
record
keeping
requirements
and
periodic
submission
of
reports,
to
EPA's
Office
of
Air
and
Radiation,
Office
of
Atmospheric
Programs,
occur
on
an
annual,
biannual,
onetime,
or
occasional
basis
depending
on
the
nature
of
the
reporting
entity
and
the
length
of
time
that
the
entity
has
been
in
service.
Specific
reporting
and
record
keeping
requirements
were
published
in
58
FR
28660
and
codified
under
40
CFR
subpart
F
(
§
82.166).
Record
keeping
requirements
for
affected
entities
consist
of
the
following:

°
programs
certifying
technicians
must
maintain
records
on
each
technician
certified
through
their
programs;
°
purchasers
of
refrigerants
must
maintain
proof
of
technician
certification;
°
wholesalers
of
refrigerants
must
maintain
refrigerant
sales
records;
°
approved
refrigerant
recovery/
recycling
equipment
testing
organizations
must
maintain
records
of
refrigerant
recovery/
recycling
equipment
testing
and
performance
and
refrigerant
recovery/
recycling
equipment
that
meets
EPA
standards;
°
refrigerant
reclaimers
must
maintain
records
on
their
customers
and
the
quantity
of
material
sent
to
them
for
reclamation;
°
disposers
of
refrigeration
and
air­
conditioning
equipment
must
maintain
copies
of
signed
statements
attesting
that
the
refrigerant
has
been
removed
prior
to
final
disposal
of
each
appliance;
°
people
servicing
appliances
normally
containing
50
or
more
pounds
of
refrigerant
must
maintain
service
documents;
and
°
owners
of
appliances
normally
containing
50
or
more
pounds
who
add
their
own
refrigerant
must
keep
records
of
the
amounts
of
refrigerant
purchased
and
added
to
their
appliances.

Periodic
reports
include
the
following:

°
approved
technician
certification
programs
must
submit
biannual
reports
on
their
pass/
fail
rates
and
the
next
year's
testing
schedule;
°
approved
refrigerant
recovery/
recycling
equipment
testing
organizations
must
submit
an
annual
list
of
refrigerant
recovery/
recycling
equipment
that
meet
EPA
standards
and
must
notify
EPA
whenever
a
model
of
refrigerant
recovery/
recycling
equipment
fails
a
threeyear
recertification
test;
°
refrigerant
reclaimers
must
submit
annual
reports
noting
the
mass
of
refrigerant
reclaimed
and
the
mass
of
waste
products
produced;
°
owners
of
industrial
process
refrigeration
(
IPR)
equipment
(
i.
e.,
appliances)
whose
appliances
fail
a
verification
test
and
owners
of
industrial
process
refrigeration
appliances
3
and
federally­
owned
commercial
and
comfort
cooling
appliances
who
wish
to
receive
an
extension
or
exclusion
under
the
leak
repair
amendment
are
subject
to
additional
reporting
and
record
keeping
requirements.
Copies
of
these
reports
are
forwarded
by
the
affected
entities
and
stored
at
EPA
headquarters.

The
previously
Office
of
Management
and
Budget
(
OMB)­
approved
ICR
1626.07
was
approved
in
July
2000,
and
expires
July
31,
2003.
EPA
has
not
promulgated
any
regulation
that
changes
the
recordkeeping
or
reporting
requirements
since
the
previous
ICR
renewal.
Prior
to
submission
of
this
ICR
for
renewal,
EPA
updated
and
verified
a
number
of
the
estimates
of
the
number
of
respondents
based
on
Agency
experience
in
reviewing
submitted
reports
from
respondents,
enforcement
data,
and
Agency
review
of
respondent
applications
for
approval.
EPA
will
continue
to
update
the
estimate
of
wages,
taking
into
account
any
guidance
provided
by
EPA's
Office
of
Environmental
Information
and
OMB.

EPA
has
estimated
that
there
are
345,608
annual
respondents
consisting
of
representatives
from
the
air­
conditioning
and
refrigeration
community,
including
but
not
limited
to
service
repair
shops,
refrigerant
reclaimers,
and
refrigerant
wholesalers.
The
annual
cost
of
collection
and
maintenance
of
records
for
the
respondents
is
estimated
to
total
$
6,973,541.10.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
In
order
to
facilitate
compliance
with
and
enforce
the
section
608
requirements
of
the
Act,
EPA
requires
reporting
and
record
keeping
requirements
of
technicians,
technician
certification
programs,
refrigerant
recovery/
recycling
equipment
testing
organizations,
refrigerant
wholesalers
and
purchasers,
refrigerant
reclaimers,
refrigeration
and
air­
conditioning
equipment
owners,
and
other
establishments
that
perform
refrigerant
removal,
service,
or
disposal.
Specific
reporting
and
record
keeping
requirements
were
published
in
58
FR
28660
and
codified
under
40
CFR
subpart
F
(
§
82.166).

2(
b)
Practical
Utility/
Users
of
the
Data
The
purpose
and
need
of
this
renewed
collection
request
is
to
facilitate
compliance
with
and
enforcement
of
section
608
of
the
Act
by
reducing
emissions
of
class
I
and
class
II
ozonedepleting
refrigerants
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.

This
collection
is
a
renewal
of
the
previously
OMB­
approved
Information
Collection
Request
(
ICR)
Number
1626.07.
The
regulations
implementing
the
above
provisions
were
published
in
58
FR
28660
and
are
codified
at
40
CFR
subpart
F
(
§
82.150
et
seq.).
Collection
of
this
information
was
approved
for
use
through
July
31,
2003.
4
EPA
requires
reporting
and
record
keeping
requirements
of
technicians,
technician
certification
programs,
refrigerant
recovery/
recycling
equipment
testing
organizations,
refrigerant
wholesalers
and
purchasers,
refrigerant
reclaimers,
refrigeration
and
air­
conditioning
equipment
owners,
and
other
establishments
that
perform
refrigerant
removal,
service,
or
disposal.
The
recordkeeping
requirements
and
periodic
submission
of
reports
are
made
directly
to
EPA's
Office
of
Air
and
Radiation.

3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
duplication
The
specific
information
requested
by
this
notice
is
not
currently
collected
by
any
other
EPA
office
or
any
other
government
agency
with
the
exception
of
some
chlorofluorocarbons
(
CFCs)
listed
under
the
Resource
Conservation
and
Recovery
Act
(
RCRA).
However,
since
RCRA
concerns
itself
with
disposal
of
wastes
and
the
recycling
rule
specifically
requires
that
refrigerants
be
recovered
rather
than
disposed,
any
information
currently
collected
under
RCRA
would
not
be
considered
a
duplication
of
effort.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
1995
Paperwork
Reduction
Act
(
PRA),
EPA
sought
public
comments
for
a
60­
day
period
prior
to
submitting
the
ICR
renewal
package
to
OMB.
These
comments,
which
are
used
partly
to
determine
realistic
burden
estimates
for
respondents,
must
be
considered
when
completing
the
Supporting
Statement
that
is
submitted
to
OMB.

The
announcement
of
a
public
comment
period
for
this
renewal
ICR
was
published
in
the
Federal
Register
on
March
10,
2003
(
68
FR
11389).
EPA
sought
public
comments,
pursuant
to
5
CFR
1320.8(
d),
on
the
previous
burden
estimates
being
sought
by
the
Agency.
EPA
received
no
comments.
A
copy
of
the
FR
notice
has
been
included
in
the
ICR
package
that
EPA
submitted
to
OMB.

3(
c)
Consultations
In
developing
the
regulations
(
40
CFR
82,
subpart
F)
that
led
to
the
Stratospheric
Ozone
Refrigerant
Recycling;
Final
Rule
(
60
FR
28660,
dated
May
14,
1993),
EPA
established
an
advisory
committee
for
issues
relating
to
stratospheric
ozone.
The
Stratospheric
Ozone
Protection
Advisory
Committee
(
STOPAC)
membership
included
representatives
from
affected
industries,
environmental
interest
groups,
and
academics
in
related
fields.
Within
STOPAC,
subcommittees
were
formed
to
look
at
the
more
detailed
issues.
The
subcommittees
on
recycling,
equipment
certification,
reclaimer
certification,
and
technician
certification
and
training
met
and
discussed
all
aspects
of
the
proposed
regulations
for
section
608
of
the
Act.
The
names
and
5
contact
information
for
members
of
the
STOPAC
are
provided
in
Appendix
1
to
this
Supporting
Statement.

For
the
leak
repair
provisions
for
industrial
process
refrigeration
provisions,
EPA
met
several
times
with
numerous
members
of
the
Chemical
Manufacturers
of
America
(
CMA)
in
negotiating
a
settlement
agreement
and
developing
the
proposed
amendments.
A
listing
of
acknowledgments
for
the
preparation
of
the
Compliance
Guidance
for
Industrial
Process
Refrigeration
Leak
Repair
Regulations
Under
Section
608
of
the
Clean
Air
Act
is
provided
in
Appendix
2
to
this
Supporting
Statement.

EPA
also
received
comments
regarding
the
record
keeping
and
reporting
requirements
during
the
public
comment
period
for
the
original
rulemaking
of
1993.
The
negotiating
group
agreed
to
the
provisions
with
the
realization
that
in
order
to
receive
an
extension
or
exclusion,
certain
information
needed
to
be
submitted
to
EPA
to
allow
for
a
determination.
EPA
responded
to
all
comments
regarding
the
recordkeeping
and
reporting
provisions
in
the
final
rule.
Most
commenters
agreed
with
the
negotiating
group.
Two
commenters
disagreed.
EPA
also
had
several
meetings
with
the
U.
S.
Department
of
Energy's
Office
of
Environmental
Guidance
to
discuss
the
unique
problems
that
the
Agency
experienced
with
meeting
leak
repair
deadlines
for
commercial
and
comfort­
cooling
equipment.

3(
d)
Effects
of
Less
Frequent
Collection
The
information
requirements
in
the
final
rule
are
either
onetime,
annual,
semiannual,
or
occasional
submissions
depending
on
the
nature
of
the
reporting
entity
and
the
length
of
time
that
the
entity
has
been
in
service.

Onetime
submissions
cannot
be
submitted
less
frequently
by
definition.
These
include
the
following:

°
Application
for
approval
of
refrigerant
recovery/
recycling
equipment
testing
organizations;
°
Testing
organization
notification
of
newly
certified
or
decertified
recovery
devices;
°
Application
for
approval
of
technician
certification
organizations;
°
Recovery
device
acquisition
certification
(
by
service
and
disposal
establishments);
°
Refrigerant
reclaimer
certification;
°
Owners
of
industrial
process
refrigeration
equipment
who
need
more
than
30
days
to
complete
repairs
or
more
than
one
year
to
retrofit
or
replace
equipment
must
submit
documentation
to
EPA
explaining
their
need
for
additional
time.

The
information
that
is
required
to
be
submitted
annually
is
detailed
below.
Collecting
this
information
less
than
annually
would
hinder
EPA
enforcement
efforts.
6
°
Testing
organization
notification
of
all
previously
certified
recovery
devices;
°
Approved
technician
certification
organizations
must
submit
a
biannual
activity
report
that
includes
the
pass/
fail
rate
and
testing
schedule
for
the
next
six
months;
and
°
Reclaimer
reports
on
the
quantities
of
used
refrigerant
received
and
processed.

3(
e)
General
Guidelines
Section
608(
a)(
3)
of
the
Act
requires
maximization
of
the
recapture
and
recycling
of
class
I
and
class
II
ozone­
depleting
refrigerants.
Enforcement
of
these
provisions
of
the
Act
is
insured
by
requiring
annual
reports
of
refrigerant
recovery/
recycling
equipment
test
organizations
and
refrigerant
reclaimers.

Biannual
activity
reports
are
required
of
programs
certifying
technicians.
These
activity
reports
allow
EPA
to
determine
the
relative
progress
and
success
of
these
programs.
This
is
imperative
since
each
of
these
programs
acts
as
a
third
party
certifier
on
behalf
of
EPA.
The
reports
also
allow
opportunities
for
feedback
from
the
programs
concerning
test
questions
and
question
bank
modifications.

There
are
instances
under
which
EPA
is
requesting
information
within
30
days.
Newly
approved
refrigerant
recovery/
recycling
equipment
testing
organizations
shall
submit
a
list
of
all
certified
refrigerant
recovery/
recycling
equipment
to
EPA
within
30
days
of
the
organization's
approval
by
EPA.
In
order
to
ensure
the
maximization
of
recapture
and
recycling
of
class
I
and
class
II
ozone­
depleting
refrigerants
as
mandated
by
section
608(
a)(
3)(
B)
of
the
Act,
EPA
has
established
a
30­
day
reporting
deadline
for
approved
refrigerant
recovery/
recycling
equipment
testing
organizations
when
a
new
model
line
of
recycling/
recovery
equipment
has
been
certified
or
when
retests
of
refrigerant
recovery/
recycling
equipment
show
that
a
previously
certified
model
line
fails
to
meet
EPA
requirements.
A
deadline
of
greater
than
30
days
might
allow
refrigerant
recovery/
recycling
equipment
that
is
faulty
or
below
standard
into
commerce.
Once
substandard
refrigerant
recovery/
recycling
equipment
is
in
circulation
the
chances
of
a
recall
are
unlikely
and
the
opportunity
for
refrigerant
venting
from
substandard
equipment
will
increase.

In
order
to
reduce
the
emissions
of
class
I
and
class
II
ozone­
depleting
refrigerants
to
the
lowest
achievable
amount,
EPA
is
requesting
continued
collection
of
information
concerning
the
following
leak
repair
reporting
and
recordkeeping
requirements,
in
accordance
with
40
CFR
82.156:

°
Owners/
operators
of
commercial
and
comfort
cooling
appliances
and
owners
of
IPR
who
decide
to
retrofit/
retire
appliances
instead
of
repairing
them
must
maintain
a
retrofit/
retire
plan
at
their
place
of
business.


Those
taking
the
retrofit/
retire
option
have
three
paths
to
choose
from
to
determine
the
total
time
allowed
to
complete
the
retrofit/
retirement
of
their
equipment.
The
three
paths
are
determined
by:
(
1)
If
the
appliance
is
custom
built,
7
the
owners
or
operators
may
apply
to
EPA
for
an
extension
to
the
leak
repair
time
frames
due
to
a
lack
of
parts
availability
(
i.
e.,
more
than
30
weeks
needed
for
parts
to
become
available)
or
(
2)
other
regulations
require
delays
or
a
suitable
replacement
refrigerant
with
a
lower
ozone­
depleting
potential
is
not
available
or
(
3)
more
than
two
years
are
needed
for
the
retrofit/
retirement.
For
(
1)
and
(
2),
the
owner/
operator
must
submit
an
extension
request
in
the
form
of
a
report
to
EPA
within
six
months
after
the
end
of
the
30­
day
period
initiated
by
the
original
determination
that
their
appliance
leaked
above
35%.
They
must
also
maintain
records
adequate
to
determine
that
the
appliance
is
custom
built
and
that
parts
are
not
available.
Owners/
operators
can
seek
further
extensions
by
submitting
an
additional
extension
request
within
30­
days
of
discovering
the
need
for
more
time.
For
(
3),
the
owner/
operator
determines
that
an
additional
year
is
required
in
addition
to
the
original
year
granted
under
(
1),
the
owner/
operator
can
submit
a
request
in
the
form
of
a
report
for
additional
time
to
complete
the
retrofit/
retirement.

°
Owners/
operators
who
take
the
leak
repair
option
may
seek
an
exemption
to
the
30­
day
repair
option
by
submitting
a
report
to
EPA
within
30
days
of
determination,
but
only
if
they
site
availability
of
parts
as
the
reason
for
the
request.


Upon
a
failed
follow­
up
verification
test
for
IPR
or
under
some
circumstances
owners/
operators
of
federally
owned
comfort
cooling
and
commercial
appliances,
the
owner
or
operator
is
required
to
report
to
EPA
that
the
verification
test
failed
and
develop
a
retrofit/
retirement
plan
within
30­
days.
The
plan
is
maintained
onsite,
and
the
original
plan
must
be
readily
available
to
EPA
upon
request.


Once
retrofit/
retirement
is
required
as
a
result
of
failed
verification,
the
owner/
operator
of
IPR
or
under
some
circumstances
owners/
operators
of
federally
owned
comfort
cooling
and
commercial
appliances
may
seek
relief
from
the
retrofit/
retirement
plan
by
following
one
of
two
options
for
second
repair
efforts,
in
accordance
with
40
CFR
82.156(
i)(
6),
(
i)(
3)(
ii),
and
(
i)(
3)(
iii).
1.
Report
to
EPA
within
30
days
of
successful
verification
that
second
repair
attempts
held.
This
report
results
from
the
repairs
of
the
same
leaks
subject
to
the
first
repair
efforts
within
30
days
of
the
original
failed
follow­
up
verification
test.
2.
Report
to
EPA
within
30
days
that
the
obligation
to
retrofit/
replace
is
relieved.
This
report
results
from
an
inclusion
in
the
original
notification
to
EPA
of
the
parameters
used
to
establish
that
a
leak
rate
is
less
than
35%.
Such
notification
allows
the
owner/
operator
180
days
from
the
original
failed
verification
to
determine
the
leak
rate
using
the
approved
parameters.

The
requirements
of
this
collection
do
not
exceed
any
other
guidelines.

3(
f)
Confidentiality
8
The
information
collected
under
this
ICR
renewal
is
used
to
facilitate
compliance
with
and
enforcement
of
section
608
of
the
Clean
Air
Act
as
amended
in
1990.
The
record
keeping
requirements
and
periodic
submission
of
reports
are
not
shared
with
parties
outside
of
the
Federal
government.
The
handling
and
confidentiality
of
the
reporting
requirements
for
assuring
computer
data
security;
preventing
disclosure,
proper
storage,
and
proper
disposal
follow
EPA's
confidentiality
regulations
(
40
CFR
2.201
et
seq.)

3(
g)
Sensitive
Questions
This
ICR
renewal
does
not
ask
questions
of
a
sensitive
nature.
The
required
recordkeeping
and
reporting
requirements
do
not
ask
any
questions
concerning
sexuality,
religious
beliefs,
or
other
matters,
usually
considered
private.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
/
North
American
Industry
Classification
System
(
NAICS)
Codes
The
following
is
a
list
of
NAICS
codes
affected
by
the
manifest
information
requirements
covered
under
this
ICR:

NAICS
Category
81131
Commercial
Industrial
Machinery
and
Equipment
(
not
Automotive
and
Electronic)
Repair
and
Maintenance
811412
Appliance
Repair
and
Maintenance
42193
Recyclable
Material
Wholesalers
(
Metal
scrap
and
waste)

541380
Environmental
Test
Laboratories
/
Services
443111
Household
Appliance
Stores
23511
Plumbing,
Heating,
Air
Conditioning
Contractors
42111
Automobile
and
Other
Motor
Vehicle
Wholesalers
42112
Motor
Vehicle
Suppliers
and
New
Parts
Wholesalers
44131
Automotive
Parts
and
Accessories
Stores
4(
b)
Information
Requested
9
(
i)
Data
items
­
including
recordkeeping
and
reporting
requirements
All
records
pursuant
to
this
ICR
must
be
kept
onsite
at
the
respondents'
place
of
business
for
a
minimum
of
three
years.
Records
are
required
in
accordance
with
40
CFR
§
82.166.
Reports
are
submitted
from
the
respondents
to
EPA
headquarters
in
a
written
or
electronic
media
format.

Recordkeeping
1.
Certified
technicians
must
maintain
a
copy
of
their
certification.
2.
Programs
certifying
technicians
must
display
at
their
place
of
business
a
copy
of
a
letter
stating
EPA
approval
as
required
in
40
CFR
82,
subpart
F,
appendix
D
section
(
g).
3.
Programs
certifying
technicians
must
maintain
records
which
include
the
names
and
addresses
of
all
individuals
taking
the
test,
the
scores
of
all
certifications
tests
administered
and
the
dates
and
locations
of
all
testing
administered
as
detailed
in
40
CFR
82,
subpart
F,
appendix
D
section
(
g).
4.
Persons
who
sell
or
distribute
any
class
I
or
class
II
substance
for
use
as
a
refrigerant
must
retain
invoices
that
indicate
the
name
of
the
purchaser,
the
date
of
sale,
and
the
quantity
of
refrigerant
purchased.
5.
Refrigerant
wholesalers
are
required
to
keep
on
file
evidence
that
at
least
one
technician
of
the
purchaser
is
properly
certified,
and
may
only
sell
refrigerant
to
the
purchaser
or
his
authorized
representative.
6.
Purchasers
of
any
class
I
or
class
II
ozone­
depleting
refrigerants
who
employ
certified
technicians
must
provide
written
proof
of
the
certification
to
the
wholesaler
who
sells
them
refrigerant.
7.
Approved
refrigerant
recovery/
recycling
equipment
testing
organizations
must
maintain
records
of
refrigerant
recovery/
recycling
equipment
testing
and
performance
and
a
list
of
refrigerant
recovery/
recycling
equipment
that
meets
EPA
requirements.
8.
Reclaimers
must
maintain
records
on
a
transactional
basis
of
the
names
and
addresses
of
persons
sending
them
material
for
reclamation
and
the
quantity
of
the
material
(
the
combined
mass
of
refrigerant
and
contaminants)
sent
to
them
for
reclamation.
9.
Reclaimers
must
maintain
records
of
the
quantity
of
material
sent
to
them
for
reclamation,
the
mass
of
refrigerant
reclaimed,
and
the
mass
of
waste
products.
10.
Persons
disposing
of
small
appliances,
motor
vehicle
air
conditioners
(
MVACs),
and
MVAC­
like
appliances
must
maintain
copies
of
signed
statements
on­
site
at
their
place
of
business
verifying
that
the
refrigerant
has
been
previously
evacuated
from
the
appliance
or
shipment
of
appliances.
11.
Persons
servicing
appliances
normally
containing
50
or
more
pounds
of
refrigerant
must
provide
the
owner/
operator
of
such
appliances
with
an
invoice
or
other
documentation,
which
indicates
the
amount
of
refrigerant
added
to
the
appliance.
12.
The
owners/
operators
of
appliances
containing
50
or
more
pounds
of
refrigerant
must
keep
servicing
records
documenting
the
date
and
type
of
service,
as
well
as
the
quantity
of
refrigerant
added.
13.
The
owners/
operators
of
appliances
containing
50
or
more
pounds
of
refrigerant
must
10
keep
records
of
refrigerant
purchased
and
added
to
such
appliances
in
cases
where
owners
add
their
own
refrigerant.

Reporting
1.
Approved
refrigerant
recovery/
recycling
equipment
testing
organizations
shall
submit
a
list
of
all
certified
refrigerant
recovery/
recycling
equipment
to
EPA
within
30
days
of
the
organization's
approval
by
EPA
and
annually
at
the
end
of
each
calendar
year
thereafter.
2.
Approved
refrigerant
recovery/
recycling
equipment
testing
organizations
shall
submit
to
EPA
within
30
days
of
the
certification
of
a
new
model
line
of
refrigerant
recovery/
recycling
equipment
the
name
of
the
manufacturer
and
the
name
and/
or
serial
number
of
the
model
line.
3.
Approved
refrigerant
recovery/
recycling
equipment
testing
organizations
shall
notify
EPA
if
retests
of
refrigerant
recovery/
recycling
equipment
or
inspections
of
manufacturing
facilities
conducted
pursuant
to
sec.
82.158(
j)
show
that
a
previously
certified
model
line
fails
to
meet
EPA
requirements.
Such
notification
must
be
received
within
thirty
days
of
the
retest
or
inspection.
4.
Reclaimers
must
report
the
quantity
of
material
sent
to
them
for
reclamation,
the
mass
of
refrigerant
reclaimed,
and
the
mass
of
waste
products.
Reclaimers
must
report
this
information
to
EPA
annually
within
30
days
of
the
end
of
the
calendar
year.
5.
EPA
must
receive
an
activity
report
from
all
approved
certifying
programs
by
every
January
30
and
June
30
which
includes
the
pass/
fail
rates
and
testing
schedules
as
detailed
in
40
CFR
82
subpart
F,
appendix
D
section
(
g).
6.
40
CFR
§
82.166
(
n)
requires
that
persons
requesting
extensions
or
exclusions
from
the
leak
repair
requirements
must
submit
in
writing
the
reasons
for
the
request.

(
ii)
Respondent
Activities
Refrigerant
Recovery/
Recycling
Equipment
Certification
­
Independent
testing
of
refrigerant
recovery/
recycling
equipment
is
required
to
ensure
that
the
refrigerant
recovery/
recycling
equipment
is
capable
of
meeting
the
standards
described
in
40
CFR
section
82.158
and
appendices
B
and
C
of
the
regulations.
To
ensure
reliability
and
objectivity
of
the
refrigerant
recovery/
recycling
equipment
certification
programs
are
required
to
submit
an
application
to
EPA.

Applications
for
refrigerant
recovery/
recycling
equipment
testing
approval
must
include
written
information
verifying
the
following:
(
l)
the
list
of
refrigerant
recovery/
recycling
equipment
present
at
the
organization
that
will
be
used
for
testing
refrigerant
recovery/
recycling
equipment;
(
2)
expertise
in
refrigerant
recovery/
recycling
equipment
testing
and
the
technical
experience
of
the
organization's
personnel;
(
3)
thorough
knowledge
of
the
standards
as
they
appear
in
40
CFR
section
82.158
and
appendices
B
and
C
of
the
regulation;
and
(
4)
a
program
for
verifying
the
performance
of
certified
refrigerant
recovery/
recycling
equipment
over
the
long
term.
11
The
refrigerant
recovery/
recycling
equipment
testing
organization
must
certify
that
it
has
no
conflict
of
interest,
and
that
it
receives
no
direct
or
indirect
financial
benefit
from
the
outcome
of
certification
testing.
The
organization
must
agree
to
allow
the
Administrator
access
to
records
and
personnel
to
verify
the
information
contained
in
the
application.

Organizations
testing
refrigerant
recovery/
recycling
equipment
must
notify
EPA
of
newly
certified
refrigerant
recovery/
recycling
equipment,
or
if
equipment
previously
certified
fails
the
periodic
re­
test
required
by
the
regulation.
Each
such
organization
must
also
send
an
annual
report
to
EPA
naming
all
refrigerant
recovery/
recycling
equipment
that
it
has
certified
to
date.

Reclaimers
­
Reclaimers
are
required
to
submit
to
EPA
a
statement
containing
the
following
(
in
accordance
with
40
CFR
section
82.164):
(
1)
the
name
and
address
of
the
reclaimer;
(
2)
the
list
of
equipment
that
will
be
used
to
reprocess
and
to
analyze
reclaimed
refrigerant;
(
3)
a
certification
that
the
refrigerant
will
be
returned
to
at
least
the
standard
of
purity
set
forth
in
(
Air­
Conditioning
&
Refrigeration
Institute)
ARI
Standard
700,
"
Specifications
for
Fluorocarbon
Refrigerants";
(
4)
a
certification
that
the
purity
of
the
refrigerant
will
be
verified
using
the
methods
set
forth
in
ARI
Standard
700;
(
5)
a
certification
that
no
more
than
1.5
percent
of
the
refrigerant
will
be
released
during
the
reclamation
process;
(
6)
a
certification
that
the
wastes
from
the
reclamation
process
will
be
disposed
of
in
accordance
with
applicable
laws
and
regulations;
and
(
7)
a
certification
that
the
information
provided
is
true
and
correct.
A
responsible
officer
of
the
reclamation
company
must
sign
the
statement.

Reclaimers
must
also
submit
to
EPA
annual
reports
detailing
the
total
amount
of
used
refrigerant
sent
for
reclamation
and
the
total
amount
of
refrigerant
and
waste
products
recovered
(
40
CFR
section
82.166(
h)).

Service
and
Disposal
Establishments
­
Persons
maintaining,
servicing,
repairing,
or
disposing
of
air­
conditioning
or
refrigeration
equipment
must
submit
to
EPA
a
statement
which
includes
the
following
(
40
CFR
section
82.162(
a)):
(
1)
a
certification
that
such
person
has
acquired
certified
refrigerant
recovery/
recycling
equipment
and
is
complying
with
the
requirements
of
the
rule;
(
2)
the
name
and
address
of
the
purchaser
of
the
refrigerant
recovery/
recycling
equipment;
(
3)
the
number
of
trucks
operated
by
the
establishment;
(
4)
the
name
and
address
of
the
establishment
where
the
refrigerant
recovery/
recycling
equipment
is
or
will
be
located;
and
(
5)
the
manufacturer's
name,
the
date
of
manufacture,
and
the
model
and
serial
number
of
the
refrigerant
recovery/
recycling
equipment.
The
owner
of
the
refrigerant
recovery/
recycling
equipment
or
another
responsible
officer
must
sign
the
statement
certifying
that
the
information
given
is
true
and
correct.

Disposers
are
also
required
to
maintain
a
copy
of
a
signed
statement
(
reference
OMB
form
#
2060­
0256,
The
United
States
Environmental
Protection
Agency
Refrigerant
Recovery
or
Recycling
Device
Acquisition
Certification
Form)
for
each
piece
of
disposed
equipment,
thus
demonstrating
that
all
of
the
remaining
refrigerant
was
recovered
from
the
equipment
before
final
disposal
(
40
CFR
sections
82.156(
f)(
2)
and
82.166(
i)).
12
Technician
Certification
Programs
­
Persons
seeking
approval
of
technician
certification
programs
are
required
to
submit
verification
of
the
following
(
40
CFR
section
82.161(
c)
and
appendix
D):
(
1)
ability
to
produce
multiple
versions
of
examinations
for
each
test
site;
(
2)
sufficient
internal
capacity
to
process
the
scoring
and
the
accompanying
documentation;
and
(
3)
ability
to
ensure
the
confidentiality
and
security
of
test
questions
and
answers.
Testing
organizations
have
to
be
able
to
provide
proctors
for
examinations
and
have
to
verify
the
identity
of
technicians
by
examining
photo
identification.
Technician
certification
programs
are
required
to
submit
reports
to
EPA
every
six
months
that
include
information
on
the
pass/
fail
rate
and
testing
schedules.

Submissions
for
approval
of
technician
certification
programs
that
have
already
tested
and
certified
technicians
are
required
to
include
(
1)
verification
that
the
program
meets
all
of
the
standards
set
forth
in
the
rule,
or
(
2)
verification
that
the
program
meets
all
of
the
standards
set
forth
in
the
rule
except
for
a
few,
in
which
case
the
program
must
submit
verification
that
appropriate
supplementary
materials
will
be
provided
upon
EPA's
approval
to
all
persons
previously
certified
under
the
program
(
40
CFR
section
82.161(
g)).

Technicians
­
Technicians
are
required
to
pass
a
certification
test
and
to
keep
a
wallet­
sized
certification
card
(
40
CFR
section
82.166(
1)).

Owners
of
Industrial
Process
Refrigeration
­
section
82.166(
n)
requires
that
the
following
information
listed
in
(
1)
­
(
8)
must
be
submitted
by
persons
requesting
extensions
or
exclusions
from
leak
repair.
These
requirements
(
40
CFR
82.156)
are
only
applicable
in
instances
where
owners/
operators
of
appliances
leaking
above
the
specified
trigger
leak
rates
for
the
specific
type
of
appliance
that
they
own
(
e.
g.,
federally
owned
commercial
refrigeration
appliance).

(
1)
identification
of
the
facility;
(
2)
the
leak
rate;
(
3)
the
method
used
to
determine
the
leak
rate
and
full
charge;
(
4)
the
date
a
leak
rate
of
greater
than
the
allowable
annual
leak
rate
was
discovered;
(
5)
the
location
of
leaks(
s)
to
the
extent
determined
to
date;
(
6)
any
repair
work
that
has
been
completed
thus
far
and
the
date
that
work
was
completed;
(
7)
the
reasons
why
more
than
30
days
are
needed
to
complete
the
work;
(
8)
an
estimate
of
when
repair
work
will
be
completed;
(
9)
a
plan
to
fix
other
outstanding
leaks
for
which
repairs
are
planned
but
not
yet
completed
to
achieve
a
rate
below
the
applicable
allowable
leak
rate;
and
(
10)
identification
of
the
facility
and
date
the
original
information
regarding
additional
time
beyond
the
initial
30
was
filed,
and
notification
of
the
determination
that
the
leak
rate
no
longer
exceeds
the
allowable
annual
leak
rate.

For
instances
where
the
owners
or
operators
intend
to
establish
that
the
appliance's
annual
leak
rate
does
not
exceed
the
applicable
allowable
annual
leak
rate
in
accordance
with
§
82.156(
i)(
3)(
v),
the
owner
or
operator
is
required
to
include
item
(
9).
Item
(
10)
must
be
included
within
30
days
of
determining
that
the
leak
rate
does
exceed
the
applicable
allowable
13
annual
leak
rate.
In
those
cases,
items
(
9)
and
(
10)
may
replace
items
(
7)
and
(
8).

The
dates
and
types
of
verification
tests
performed
and
test
results
must
be
submitted
to
EPA
within
30
days
of
conducting
each
test.

§
82.
166(
o)
requires
that
the
following
items
are
required
for
those
persons
wishing
an
extension
of
the
retrofit/
retirement
requirements:

(
1)
the
identification
of
the
industrial
process
facility;
(
2)
the
leak
rate;
(
3)
the
method
used
to
determine
the
leak
rate
and
full
charge;
(
4)
the
date
a
leak
rate
of
35
percent
or
greater
was
discovered;
(
5)
the
location
of
leaks(
s)
to
the
extent
determined
to
date;
(
6)
any
repair
work
that
has
been
completed
thus
far
and
the
date
that
work
was
completed;
(
7)
a
plan
to
complete
the
retrofit
or
replacement
of
the
system;
(
8)
the
reasons
why
more
than
one
year
is
necessary
to
retrofit
or
replace
the
system;
(
9)
the
date
of
notification
to
EPA;
(
10)
an
estimate
of
when
retrofit
or
replacement
work
will
be
completed;
(
11)
if
time
changes
for
original
estimates
result
in
moving
the
date
of
completion
forward,
documentation
of
the
reason
for
these
changes;
(
12)
and
the
date
of
notification
to
EPA
regarding
a
change
in
the
estimate
of
when
the
work
will
be
completed.

Items
(
11)
and
(
12)
are
required
to
be
submitted
only
when
such
changes
result
in
moving
the
date
of
completion
forward,
and
will
be
submitted
within
30
days
of
occurring.

The
same
records
that
are
required
to
be
submitted
(
above)
by
those
requesting
extension
of
compliance
deadlines
for
leak
repair,
must
also
be
maintained
on­
site,
according
to
§
82.
166(
n):

(
1)
identification
of
the
facility;
(
2)
the
leak
rate;
(
3)
the
method
used
to
determine
the
leak
rate
and
full
charge;
(
4)
the
date
a
leak
rate
of
greater
than
the
allowable
annual
leak
rate
was
discovered;
(
5)
the
location
of
leaks(
s)
to
the
extent
determined
to
date;
(
6)
any
repair
work
that
has
been
completed
thus
far
and
the
date
that
work
was
completed;
(
7)
the
reasons
why
more
than
30
days
are
needed
to
complete
the
work;
(
8)
an
estimate
of
when
repair
work
will
be
completed;
(
9)
a
plan
to
fix
other
outstanding
leaks
for
which
repairs
are
planned
but
not
yet
completed
to
achieve
a
rate
below
the
applicable
allowable
leak
rate;
and
(
10)
identification
of
the
facility
and
date
the
original
information
regarding
additional
14
time
beyond
the
initial
30
days
was
filed,
and
notification
of
the
determination
that
the
leak
rate
no
longer
exceeds
the
allowable
annual
leak
rate.

Where
the
owners
or
operators
intend
to
establish
that
the
appliance's
annual
leak
rate
does
not
exceed
the
applicable
allowable
annual
leak
rate
in
accordance
with
§
82.156(
i)(
3)(
v),
the
owner
or
operator
is
required
to
include
item
(
9).
Item
(
10)
must
be
included
within
30
days
of
determining
that
the
leak
rate
does
exceed
the
applicable
allowable
annual
leak
rate.
In
those
cases,
items
(
9)
and
(
10)
may
replace
items
(
7)
and
(
8)
above.

The
same
records
that
are
required
to
be
submitted,
above,
by
those
requesting
extension
of
compliance
deadlines
for
retrofitting,
must
also
be
maintained
on­
site,
according
to
§
82.
166(
o):

(
1)
the
identification
of
the
industrial
process
facility;
(
2)
the
leak
rate;
(
3)
the
method
used
to
determine
the
leak
rate
and
full
charge;
(
4)
the
date
a
leak
rate
of
35
percent
or
greater
was
discovered;
(
5)
the
location
of
leaks(
s)
to
the
extent
determined
to
date;
(
6)
any
repair
work
that
has
been
completed
thus
far
and
the
date
that
work
was
completed;
(
7)
a
plan
to
complete
the
retrofit
or
replacement
of
the
system;
(
8)
the
reasons
why
more
than
one
year
is
necessary
to
retrofit
to
replace
the
system;
(
9)
the
date
of
notification
to
EPA;
(
10)
an
estimate
of
when
retrofit
or
replacement
work
will
be
completed;
(
11)
if
time
changes
for
original
estimates
result
in
moving
the
date
of
completion
forward,
documentation
of
the
reason
for
these
changes;
and
(
12)
the
date
of
notification
to
EPA
regarding
a
change
in
the
estimate
of
when
the
work
will
be
completed.
Items
(
11)
and
(
12)
are
required
to
be
submitted
only
when
such
changes
result
in
moving
the
date
of
completion
forward,
and
will
be
submitted
within
30
days
of
occurring.

40
CFR
82.
166(
p)(
1)
permits
persons
who
wish
to
exclude
purged
refrigerants
that
are
destroyed
from
annual
leak
rate
calculations;
however,
the
persons
must
maintain
records
on­
site
to
support
the
amount
of
refrigerant
claimed
as
sent
for
destruction.
Records
shall
be
based
on
a
monitoring
strategy
that
provides
reliable
data
to
demonstrate
that
the
amount
of
refrigerant
sent
for
destruction
corresponds
with
the
amount
of
refrigerant
purged.
Records
shall
include:

(
1)
flow
rate;
(
2)
quantity
or
concentration
of
the
refrigerant
in
the
vent
stream;
and
(
3)
periods
of
purge
flow.

40
CFR
82.
166(
q)
permits
persons
to
calculate
the
full
charge
of
an
affected
appliance
by
establishing
a
range
based
on
the
best
available
data
and
the
normal
operating
characteristics
and
15
conditions
for
the
appliance.
The
mid­
point
of
the
range
will
serve
as
the
full
charge,
and
where
records
are
maintained
they
shall
include:

(
1)
the
identification
of
the
owner
or
operator
of
the
appliance;
(
2)
the
location
of
the
appliance;
(
3)
the
original
range
for
the
full
charge
of
the
appliance,
its
midpoint,
and
how
the
range
was
determined;
(
4)
any
and
all
revisions
of
the
full
charge
range
and
how
they
were
determined;
and
(
5)
the
dates
such
revisions
occurred.

5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Agency
activities
associated
with
the
review
of
the
reports
and
record
keeping
requirements
for
the
National
Recycling
Program
consist
of
reviewing
the
following:

°
Applications
from
independent
refrigerant
recovery/
recycling
equipment
testing
labs
that
wish
to
certify
recovery/
recycling
equipment;
°
Lists
of
certified
refrigerant
recovery/
recycling
equipment
submitted
annually
by
testing
organizations;
°
Notices
of
new
refrigerant
recovery/
recycling
equipment
certification
and
of
decertification
of
previously
certified
refrigerant
recovery/
recycling
equipment;
°
Applications
for
service
establishment
certification;
°
Applications
for
disposer
certification;
°
Applications
for
reclaimer
certification;
°
Annual
reports
from
reclaimers
on
their
activities;
°
Applications
for
approval
to
conduct
technician
certification
programs;
°
Reports
submitted
by
approved
technician­
certification
programs;
and
°
Submissions
from
owners
of
industrial
process
refrigeration
equipment.

5(
b)
Collection
Methodology
and
Management
EPA
has
not
developed
required
reporting
forms
or
applications,
although
it
has
developed
a
sample
form
intended
to
facilitate
certification
by
owners
of
recovery/
recycling
equipment
(
reference
the
enclosed
OMB
form
#
2060­
0256,
The
United
States
Environmental
Protection
Agency
Refrigerant
Recovery
or
Recycling
Device
Acquisition
Certification
Form).
Entities
are
encouraged
to
submit
the
required
information
in
a
format
compatible
with
their
existing
record
keeping
practices.
The
information
submitted
by
each
member
of
the
regulated
community
will
be
stored
at
EPA
headquarters
for
review
and
reference.

EPA
has
determined
that
periodic
on­
site
inspection
is
the
most
effective
method
to
16
ensure
compliance
with
section
608.
The
records
should
be
kept
at
the
location
where
service
or
disposal
of
equipment
involving
refrigerant
is
performed
or
refrigerant
is
sold,
distributed,
or
reclaimed.

5(
c)
Small
Entity
Flexibility
The
regulations
permit
technicians
who
work
on
small
appliances
to
become
certified
through
passage
of
a
take­
home
test
rather
than
a
proctored
test.
This
provision
was
implemented
in
recognition
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
(
MVACs)
when
they
are
disposed
of
are
not
required
to
be
certified
at
all
and
are
not
required
to
use
certified
refrigerant
recovery/
recycling
equipment.

Several
of
the
record
keeping
and
reporting
requirements
of
the
rule
are
intended
to
permit
entities
greater
flexibility
in
complying
with
the
regulation.
Final
persons
in
the
disposal
process
for
small
appliances
and
MVACs
may
elect
not
to
perform
refrigerant
recovery
themselves
so
long
as
they
obtain
a
signed
statement
from
persons
upstream
in
the
disposal
process
that
the
refrigerant
has
been
removed
already.
Thus,
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.
Thus,
the
plan
permits
the
owner
greater
flexibility
in
reducing
refrigerant
emissions.
Owners
of
industrial
process
refrigeration
equipment
may
take
longer
than
30
days
to
complete
repairs
or
longer
than
one
year
to
retrofit
or
replace
equipment
so
long
as
they
submit
documentation
to
EPA
explaining
their
need
for
additional
time.
Again,
the
reporting
permits
the
owner
greater
flexibility
in
compliance.

5(
d)
Collection
Schedule
EPA
requires
maintenance
of
the
following
records
for
a
minimum
of
three
(
3)
years.

°
Organizations
operating
refrigerant
recovery/
recycling
equipment
certification
programs
must
complete
a
onetime
application
for
approval
from
EPA.
The
approved
refrigerant
recovery/
recycling
equipment
testing
organizations
must
report
when
new
equipment
passes
the
certification
test,
when
previously
certified
equipment
fails
retesting
or
inspection,
and
provide
an
annual
report
of
the
equipment
that
the
organization
has
certified.
°
Service
establishments
must
complete
a
one­
time
certification
requirement
to
EPA.
°
Establishments
that
recover
refrigerant
from
appliances,
machines,
or
other
goods
at
disposal
must
complete
a
onetime
registration
requirement.
°
Reclaimers
must
complete
a
onetime
certification
and
approved
reclaimers
must
report
annually
on
their
reclamation
activities.
17
°
Organizations
seeking
approval
to
conduct
technician
certification
programs
must
complete
a
onetime
application
for
approval
from
EPA
to
do
so,
and
after
approval
are
required
to
submit
a
semiannual
report
to
EPA.
°
Owners
of
industrial
process
refrigeration
equipment
must
submit
a
onetime
request
if
they
wish
to
obtain
an
extension
or
exclusion
described
above.
It
is
collected
so
that
EPA
may
determine
whether
an
extension
or
exclusion
should
be
granted.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
This
section
provides
burden
tables
that
provide
the
numerical
basis
for
the
annual
burden
and
cost
of
this
ICR
renewal
by
detailing
the
following:

°
EPA's
rationale
in
preparing
respondent
burden
and
cost
tables;
°
estimating
respondent
and
Agency
burden
(
hours
to
complete
required
activities);
°
estimating
respondent
and
Agency
labor
costs
and
costs
of
capital
associated
with
the
those
activities;
°
developing
universe
estimates;
and
°
calculating
burden
and
cost
totals.

The
collection
activities
defined
in
Sections
4
and
5
are
referenced
to
develop
the
aforementioned
estimates.
The
activities
for
which
EPA
has
estimated
burden
and
cost
correspond
directly
with
the
activities
listed
in
Sections
4
and
5.

6(
a)
Estimating
Respondent
Burden
Estimates
of
respondent
burden
and
cost
for
the
rule
are
presented
below.
All
hour
estimates
are
based
on
EPA's
experience
implementing
this
program
and
on
EPA's
best
professional
judgement.
The
overall
reporting
and
record
keeping
burden
for
the
rule
has
dropped
significantly
since
the
original
ICR
was
developed,
because
much
of
the
burden
calculated
in
the
original
ICR
was
associated
with
the
start­
up
of
the
program,
which
is
now
complete.
Thus,
all
burden
hours
and
costs
presented
here
are
annual.
None
of
the
reporting
or
record
keeping
requirements
is
expected
to
have
associated
capital
costs.

6(
b)
Estimating
Respondent
Costs
Based
upon
the
burden
hours,
EPA
has
estimated
the
labor
cost
per
respondent
and
the
capital
costs
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);
°
Capital/
Start­
up
Cost
(
for
equipment,
machinery,
and
construction);
and
°
Operating
and
Maintenance
(
O&
M)
Cost
(
for
labor
and
equipment
needed
over
time
as
18
well
as
for
the
purchase
of
services).

(
i)
Estimating
Labor
Costs
EPA
has
consulted
the
original
ICR
to
obtain
the
appropriate
baseline
labor
rates
for
each
labor
category.
The
labor
rates
reflect
the
total
cost
to
employ
an
individual
and
include
estimates
of
salaries
and
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
median
hourly
earnings
of
$
15.76
for
heating,
air­
conditioning,
and
refrigeration
mechanics
and
installers
given
in
the
Bureau
of
Labor
Statistics
website:
www.
bls.
gov/
oco/
oco1008.
htm.
EPA
then
multiplied
this
number
by
110%
for
overhead
($
15.76
x
1.10
=
$
17.34).
The
resulting
cost
of
$
33.10
($
15.76
+
$
17.34)
is
the
average
hourly
administrative
cost
of
labor
plus
overhead
for
a
private
firm.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
According
to
the
1995
PRA,
burden
is
the
"
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency."
Any
activity
that
is
not
usual
and
customary
is
considered
a
burden.
This
ICR
renewal
includes
the
time
needed
to
review
instructions,
maintaining
records,
completing
paperwork,
gathering
information,
and
reporting
information.
The
Agency
has
also
included
costs
associated
with
the
information
collection
activities,
such
as
capital
costs
and
operations
and
maintenance
(
O&
M)
costs.

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.
Capital
used
for
the
routine
and
usual
functioning
of
a
company,
or
for
a
technical
requirement
for
which
there
is
no
reporting
or
keeping
of
information,
have
not
been
included
as
an
ICR
capital
or
O&
M
cost.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
There
are
two
types
of
non­
labor
related
costs
­­
capital/
start­
up
costs
and
operating
and
maintenance
(
O&
M)
costs.
One­
time
capital/
start­
up
costs
usually
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
usually
incurred
at
the
beginning
of
an
information
collection
period
and
are
usually
incurred
only
once.
In
addition
to
the
actual
acquisition
of
start­
up
capital,
one­
time
activities
associated
with
the
production
of
capital
have
also
been
evaluated.
The
Agency
has
considered
capital/
start­
up
costs
and
O&
M
costs
in
determining
that
there
are
no
non­
labor
related
costs
associated
with
this
ICR
renewal.

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
19
amount
of
cost
associated
with
O&
M
or
purchasing
services."
The
reporting
costs
associated
with
this
ICR
renewal
have
been
included,
and
include
costs
for
file
storage,
photocopying,
and
postage.

(
iv)
Annualizing
Capital
Costs
Annualized
costs
represent
the
amount
of
an
annuity
that
would
have
to
be
paid
over
a
specific
period
of
time
that
makes
an
individual
indifferent
between
paying
either
the
stream
of
payments
or
the
up­
front
costs
in
one
lump­
sum.
This
renewal
ICR
does
not
include
capital
costs,
since
they
were
none
associated
with
the
original
ICR.
There
has
not
been
any
rulemaking
associated
with
this
ICR
renewal
that
would
have
an
associated
capital
cost.

1.
Refrigerant
Recovery/
Recycling
Equipment
Testing
Organizations
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Costs
Submit
to
EPA
annual
list
of
all
refrigerant
recovery/
recycling
equipment
previously
certified
2.0
$
66.20
Notify
EPA
of
certification
of
new
models
5.0
$
165.50
Maintain
records
of
refrigerant
recovery/
recycling
equipment
tested
and
its
performance
0.0
$
0.00
Notify
EPA
of
refrigerant
recovery/
recycling
equipment
failing
retests
or
inspections
2.0
$
66.20
Subtotal
9.0
$
297.90
Two
refrigerant
recovery/
recycling
equipment
testing
and
certifying
organizations
approved
by
EPA
are
estimated
to
spend
two
hours
each
year
preparing
and
submitting
a
list
of
all
refrigerant
recovery/
recycling
equipment
previously
certified.
An
additional
five
hours
per
year
is
estimated
to
be
spent
by
each
firm
informing
EPA
of
new
models
that
are
tested
and
meet
the
certification
requirements.
This
estimate
corresponds
to
10
models
tested
and
certified
each
year
per
firm
and
a
½
hour
reporting
burden.
Two
hours
per
year
are
estimated
to
be
spent
by
each
firm
informing
EPA
of
refrigerant
recovery/
recycling
equipment
that
has
failed
retests
or
inspections.
This
estimate
corresponds
to
four
models
per
year
that
fail
per
firm
and
a
one
half
hour
reporting
burden.
No
additional
time
is
required
to
maintain
records
of
the
tests
as
these
20
would
be
maintained
as
a
part
of
normal
business
practices.
The
$
33.10
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.

Based
on
EPA's
experience
over
the
past
six
years,
it
is
not
anticipated
that
additional
entities
will
apply
to
become
approved
refrigerant
recovery/
recycling
equipment
testing
organizations.

2.
Certification
by
Service
Establishments
that
Change
Ownership
or
Enter
the
Market
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Costs
Compile
information,
complete
certification
requirements
1.0
$
33.10
Maintain
proof
of
employee
certification
0.5
$
16.55
Subtotal
1.5
$
49.65
The
estimated
burden
of
one
and
one­
half
hours
is
for
each
service
establishment
to
collect
information,
certify
to
EPA
that
it
is
capable
of
and
will
follow
requirements
of
the
rule,
and
maintain
adequate
documentation
of
employee
certification.
EPA
assumes
that
it
takes
each
service
establishment
one
hour
to
complete
the
certification
form
and
submit
it
to
the
appropriate
EPA
regional
office
for
the
state
in
which
they
reside.
EPA
also
assumes
that
each
service
establishment
one­
half
hour
to
obtain
and
file
copies
of
their
technician's
certification
cards
onsite
at
their
place
of
business.

3.
Certification
by
Disposal
Establishments
that
Change
Ownership
or
Enter
the
Market
Annual
Respondent
Burden
21
Collection
Activities
Burden
Hours
Annual
Costs
Compile
information,
complete
certification
requirements
1.0
$
33.10
Subtotal
1.0
$
33.10
The
estimated
burden
of
one
(
1)
hour
is
for
each
disposal
establishment
to
collect
information
and
certify
to
EPA
that
it
is
capable
of
and
will
follow
requirements
of
the
Recycling
Rule.
The
$
33.10
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
of
a
private
firm.

4.
Maintenance
of
copies
of
signed
statements
by
disposal
establishments
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Costs
Maintain
copies
of
signed
statements
verifying
evacuation
of
refrigerant
9
$
297.90
Subtotal
9
$
297.90
The
industry
burden
is
the
costs
for
collecting
and
maintaining
copies
of
signed
statements
verifying
that
refrigerant
has
been
removed
from
appliances
before
they
are
accepted
for
disposal.
An
estimated
two
(
2)
minutes
per
day
are
spent
completing
and
filing
the
statements.
The
$
33.10
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.

5.
Certification
by
Refrigerant
Reclaimers
that
Change
Ownership
or
Enter
the
Market
Annual
Respondent
Burden
22
Collection
Activities
Burden
Hours
Annual
Costs
Completing
certification
and
submitting
it
to
EPA
Headquarters
5.0
$
165.50
Subtotal
5.0
$
165.50
EPA
assumes
that
it
takes
an
average
of
five
(
5)
hours
for
each
of
these
organizations
to
prepare
their
certification
packages.
The
$
33.10
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.

6.
Reclaimer
Reporting
and
Record
Keeping
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Costs
Completing
certification
and
submitting
it
to
EPA
Headquarters
5.0
$
165.50
Maintain
usual
business
records
of
refrigerant
sales
transactions
0.0
$
0.00
Subtotal
5.0
$
165.50
Reclaimers
must
maintain
records
on
quantity
of
refrigerant
received,
quantity
reclaimed,
and
mass
of
waste
products
generated,
and
report
yearly
totals
to
EPA.
Compiling
this
information,
preparing
it
for
EPA,
and
submitting
it
to
EPA
is
estimated
to
take
five
hours
per
year.
Reclaimers
must
also
maintain
records
of
refrigerant
sales
transactions;
it
is
assumed
that
no
additional
time
is
spent
maintaining
these
records
since
they
are
kept
as
part
of
usual
business
practice.
The
$
33.10
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.

7.
Refrigerant
Wholesalers
Annual
Respondent
Burden
23
Collection
Activities
Burden
Hours
Annual
Costs
Maintain
usual
business
records
of
refrigerant
sales
transactions
0.0
$
0.00
Verifying
purchasers'
certification
8.0
$
264.80
Subtotal
8.0
$
264.80
The
first
two
requirements
are
compatible
with
current
wholesale
transaction
record
keeping
practices
and
therefore
present
no
additional
burden.
It
is
assumed
that
each
wholesaler
must
spend
approximately
eight
hours
verifying,
acquiring,
and/
or
maintaining
records
of
technician
certification
in
order
to
ensure
that
they
sell
refrigerant
only
to
firms
that
employ
certified
technicians.
The
$
33.10
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.

8.
Technician
Certification
Programs
Applying
for
Approval
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Cost
Collection
Activities
Burden
Hours
Annual
Costs
Compiling
information
to
become
approved
and
submitting
it
to
EPA
Headquarters
30.0
$
993.00
Subtotal
30.0
$
993.00
The
$
33.10
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.

9.
Record
keeping
by
Existing
Technician
Certification
Programs
Annual
Respondent
Burden
24
Collection
Activities
Burden
Hours
Annual
Cost
Collection
Activities
Burden
Hours
Annual
Costs
Maintain
records
of
certified
technicians,
individuals
taking
the
tests,
test
scores,
locations,
and
dates
of
tests
0.0
$
0.00
Submit
biannual
reports
to
EPA
16.0
$
529.60
Subtotal
16.0
$
529.60
Ninety­
seven
(
97)
testing
organizations
are
estimated
to
spend
sixteen
hours
each
year
per
firm
submitting
statistical
information
on
their
tests
(
eight
hours
for
each
six­
month
report).
It
is
estimated
that
no
additional
time
is
spent
maintaining
records
of
certified
individuals,
individuals
taking
the
tests,
scores
of
all
certification
tests
as
well
as
the
dates
and
locations
of
all
tests
administered,
as
these
would
be
kept
as
a
part
of
the
normal
business
practices.
The
$
33.10
per
hour
estimate
of
labor
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.

10.
Technicians
Acquiring
Certification
and
Maintaining
Certification
Cards
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Cost
Collection
Activities
Burden
Hours
Annual
Costs
Register
and
take
certification
test
3.0
$
99.30
Maintain
certification
card
0.02
$
0.66
Subtotal
3.02
$
99.96
It
is
estimated
that
approximately
10
percent
of
the
300,000­
strong
technician
labor
force
turns
over
each
year,
necessitating
certification.
Three
hours
are
needed
to
register
for
and
take
the
test
of
approximately
100
questions.
All
300,000
technicians
are
assumed
to
take
one
minute
maintaining
their
certification
card
each
year.
25
11.
Owners
of
Refrigeration
and
Air­
Conditioning
Equipment
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Costs
Keep
normal
business
records
of
the
quantity
of
refrigerant
used
during
service
procedures
0.0
$
0.00
Subtotal
0.0
$
0.00
EPA
assumes
that
owners/
operators
of
industrial
process
refrigeration,
comfort
cooling,
and
commercial
refrigeration
equipment
(
i.
e.,
appliances)
with
charge
sizes
greater
than
50
lbs
will
maintain
service
records
indicating
what
was
done
to
their
equipment,
whether
performed
by
in­
house
service
personnel
or
contracted
out,
will
be
maintained
as
a
part
of
normal
operating
procedures.

12.
Leak
Repair
Requirements
for
Owners
of
Industrial
Process
Refrigeration
and
Commercial
and
Comfort
Cooling
Equipment
(
Appliances)

Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Costs
Prepare
requests
for
30­
day
extensions
(
IPR
and
in
limited
instances
federally
owned
equipment)
5.0
$
165.50
Prepare
requests
for
retrofit
extensions
(
IPR
and
in
limited
instances
federally
owned
equipment)
8.0
$
264.80
Collection
Activities
Burden
Hours
Annual
Costs
26
Maintain
information
on
purged
and
destroyed
refrigerant
4.0
$
132.40
Maintain
information
on
the
calculation
of
the
full
charge
using
a
range
4.0
$
132.40
Maintain
reports
on
the
results
of
verification
tests
(
IPR
and
in
limited
instances
federally
owned
equipment)
4.0
$
132.40
Maintain
plan
to
retire,
replace,
or
retrofit
equipment
10.0
$
331.00
Subtotal
35.0
$
1,158.50
The
basis
of
the
analysis
is
the
identification
of
the
steps
involved
in
seeking
an
extension
to
or
exclusion
from
the
leak
repair
provisions.
These
costs
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
costs.
Each
hour
of
industry
time
is
valued
at
$
33.10.
This
value
represents
an
average
hourly
rate
of
pay
for
a
private
firm
and
is
based
on
anecdotal
information
gleaned
through
the
operation
of
the
allowance
tracking
system
during
the
past
years.

Industrial
Process
Refrigeration,
Comfort
Cooling,
and
Commercial
Refrigeration
appliances
have
the
option,
and
in
limited
cases
are
mandated,
to
create
and
maintain
plans
to
retire/
retrofit
their
equipment
under
the
leak
repair
requirements
of
40
CFR
82.156.
The
estimated
burden
of
10
hours
is
for
equipment
owners
who
decide
not
to
repair
leaks
and
subsequently
must
develop
and
maintain
a
plan
showing
that
the
equipment
will
be
either
retired,
replaced,
or
retrofitted.
It
is
further
assumed
that
five
percent
of
all
equipment
owners
will
elect
to
proceed
with
such
a
plan
rather
than
repair
leaks.
The
$
33.10
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.

6(
c)
Estimating
Agency
Burden
and
Cost
The
hourly
rate
for
EPA
staff
at
the
GS­
12
Step
1
level
is
$
27.82
per
hour.
This
hourly
basic
rate
is
from
the
GS
salary
schedule
listed
in
the
Federal
Wage
Page
of
the
Office
of
27
Personnel
Management
website:
www.
opm.
gov/
oca.
EPA
then
multiplied
the
hourly
rate
by
the
standard
government
benefits
and
overhead
multiplication
factor
of
1.6.
The
resulting
rate
that
was
used
in
estimating
annual
Agency
burden
and
cost
is
$
44.50
($
27.82
x
1.6).

EPA
has
used
past
experience
and
reporting
data
in
addition
to
estimates
from
the
affected
community
in
determining
the
number
of
respondents
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.

°
Each
year,
EPA
will
review
annual
reports
submitted
by
the
two
testing
organizations
for
completeness
and
to
make
sure
that
EPA's
list
of
certified
refrigerant
recovery/
recycling
equipment
is
complete.
Each
evaluation
will
require
one­
half
(
0.5)
hour,
for
a
total
of
one
hour
per
year.


EPA
will
expend
15
minutes
reviewing
each
of
the
estimated
10
annual
notifications
by
the
each
of
the
two
organizations
that
new
refrigerant
recovery/
recycling
equipment
has
been
tested
and
certified,
spending
a
total
of
five
(
5)
hours
per
year.


In
addition,
EPA
will
expend
15
minutes
reviewing
each
of
the
estimated
four
(
4)
annual
notifications
by
each
of
the
two
organizations
that
previously
certified
refrigerant
recovery/
recycling
equipment
has
failed
retests
or
inspections,
spending
a
total
of
two
(
2)
hours
per
year.

°
EPA
assumes
based
on
previous
data
that
there
are
22,000
to
45,000
service
establishments
in
the
United
States.
EPA
assumes
that
the
number
of
establishments
entering
the
workplace
remains
constant
with
the
number
that
leave
the
workplace.
Five
percent
of
45,000
establishments
(
2,250)
are
assumed
to
change
ownership
annually,
thus
necessitating
recertification.
EPA
personnel
are
assumed
to
spend
15
minutes
reviewing
each
certification
from
2,250
service
establishments.
Thus
requiring
562
hours
per
year
for
review.

°
EPA
estimates
that
each
state
has
on
average
7,500
disposal
establishments.
EPA
assumes
that
the
number
of
establishments
entering
the
workplace
remains
constant
with
the
number
that
leave
the
workplace.
Most
of
these
have
already
fulfilled
this
one­
time
certification
requirement,
but
five
percent
of
these
(
375)
are
assumed
to
change
ownership
annually,
necessitating
recertification.
EPA
Regional
personnel
are
assumed
to
spend
15
minutes
reviewing
each
certification
from
375
disposal
establishments.
Thus
requiring
93.75
hours
per
year
for
review.

°
EPA
currently
has
55
certified
refrigerant
reclaimers
who
must
submit
annual
activity
reports.
Based
on
EPA's
experience,
it
is
assumed
that
four
(
4)
new
refrigerant
reclaimers
per
year
will
submit
one­
time
applications
to
EPA
to
be
certified.
EPA
is
assumed
to
spend
one
(
1)
hour
reviewing
and
approving
each
certification
for
a
total
of
four
(
4)
hours
per
year.
In
addition,
EPA
will
spend
one
(
1)
hour
reviewing
each
of
the
annual
reports
submitted
by
the
55
reclaimers,
for
a
total
of
55
hours
per
year.

°
EPA
will
spend
one
(
1)
hour
each
reviewing
biannual
activity
reports
submitted
by
the
97
28
technician
testing
organizations,
for
a
total
of
194
hours
per
year.
EPA
currently
has
97
certified
technician
certifying
programs.
Each
program
is
required
to
submit
biannual
activity
reports
to
EPA.
Based
on
EPA's
experience
over
the
past
three
years,
the
Agency
expects
to
certify
five
(
5)
new
organizations
per
year.
EPA
expects
to
spend
two
(
2)
hours
reviewing
and
approving
each
application,
for
a
total
of
10
hours
per
year.

°
EPA
estimates
one­
half
(
0.5)
hour
to
review
and
make
a
determination
on
each
of
the
anticipated
eight
(
8)
requests
from
owner/
operator's
of
IPR
equipment
for
an
extension
to
the
30­
day
repair
requirement
for
mandatory
leak
repair.

°
EPA
estimates
one
(
1)
hour
to
review
and
make
a
determination
on
each
of
the
anticipate
two
(
2)
requests
from
owner/
operator's
of
IPR
equipment
for
an
extension
to
the
one­
year
retrofit
requirement
under
the
leak
repair
requirements.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
respondent
universe
as
well
as
the
frequency
of
reporting
is
defined
in
40
CFR
subpart
F,
and
includes
the
number
of
respondents
for
established
refrigerant
recovery/
recycling
equipment
testing
organizations;
averages
for
the
number
of
service
establishments,
disposers,
and
refrigerant
reclaimers
that
enter
the
market
or
change
ownership;
refrigerant
wholesalers;
technician
certification
programs;
technicians
acquiring
certification
and
maintaining
certification
cards;
owners
of
refrigeration
and
air­
conditioning
equipment;
and
owners
of
industrial
process
refrigeration
equipment.

EPA
has
used
past
experience
and
reporting
data
in
addition
to
estimates
from
the
affected
community
in
determining
the
number
of
respondents
(
or
the
respondent
universe).
The
estimates
are
based
upon
EPA's
experience
in
implementing
the
rule
since
1993.
A
listing
of
these
entities
follows:

°
Testing
organizations
for
refrigerant
recovery/
recycling
equipment
has
remained
at
two
(
2)
organizations
since
inception
of
the
regulations
during
May
1993.

°
The
preamble
to
the
Recycling
Rule
notes
that
there
are
22,000
to
45,000
service
establishments
in
the
United
States.
Most
of
these
have
already
fulfilled
these
one­
time
requirements,
but
five
percent
of
45,000
establishments
(
2,250)
are
assumed
to
change
ownership
annually,
thus
necessitating
recertification.
EPA
assumes
that
the
number
of
establishments
that
initiate
business
has
remained
constant
with
those
that
have
ceased
operations.

°
EPA
estimates
that
each
state
has
on
average
7,500
disposal
establishments.
Most
of
these
have
already
fulfilled
this
one­
time
requirement,
but
five
percent
of
these
(
375)
are
assumed
to
change
ownership
annually,
necessitating
recertification.

°
EPA
currently
has
55
certified
refrigerant
reclaimers
who
must
submit
annual
activity
29
reports.
Based
on
EPA's
experience,
it
is
assumed
that
four
(
4)
reclaimers
per
year
will
submit
one­
time
applications
to
EPA
to
be
certified.

°
EPA
assumes
that
the
number
of
refrigerant
wholesalers
entering
the
workplace
has
remained
constant
with
those
that
who
have
left
the
workforce.
This
ICR
renewal
assumes
that
the
number
of
wholesalers
has
remained
constant
at
5,000.

°
EPA
currently
has
97
certified
technician
certifying
programs.
Each
program
is
required
to
submit
biannual
activity
reports
to
EPA.
Based
on
EPA's
experience
over
the
past
three
years,
five
(
5)
new
organizations
per
year
are
estimated
to
take
30
hours
each
to
assemble
and
submit
materials
to
EPA
requesting
that
they
be
authorized
to
test
and
certify
technicians.

°
Statements
from
certifying
organizations
have
actually
claimed
that
the
number
of
certified
technicians
entering
the
workplace
is
decreasing.
Therefore,
EPA
assumes
that
there
is
no
longer
a
10%
annual
increase
in
the
number
of
new
technicians
entering
the
workplace.
EPA
assumes
that
the
number
of
technicians
entering
the
workplace
has
remained
constant
with
those
that
who
have
left
the
workforce.
Thus
this
ICR
renewal
assumes
that
the
number
of
technicians
has
remained
constant
at
300,000.

°
Under
limited
circumstances,
EPA
allows
owners/
operators
of
industrial
process
refrigeration
equipment
with
a
charge
size
greater
than
50
lbs
of
an
ozone­
depleting
refrigerant
to
submit
a
written
request
for
an
extension
to
leak
repair
requirements.
The
number
of
occurrences
of
each
of
the
activities
is
based
on
the
estimated
number
of
requests
for
extension
and/
or
exclusion
by
an
estimated
number
of
entities
that
will
likely
choose
to
make
such
a
request.
Based
on
the
volume
of
requests
submitted
to
EPA,
the
Agency
estimates
that
approximately
10
entities
will
take
advantage
of
the
extensions
and
exclusion
each
year.
EPA
estimates
the
breakdown
to
be
for
eight
(
8)
organizations
seeking
extensions
to
the
30­
day
leak
repair
requirement,
and
two
(
2)
owners/
operators
seeking
extensions
to
the
one­
year
retrofit
requirement.

°
EPA
estimates
that
60
owners/
operators
of
comfort
cooling,
commercial
refrigeration,
and
industrial
process
refrigeration
equipment
with
charge
sizes
greater
than
50
lbs
of
an
ozone­
depleting
refrigerant
EPA
estimates
that
will
choose
to
exclude
the
amount
of
purged
and
destroyed
refrigerant
from
their
leak
rate
calculations.
Therefore
only
60
owners/
operators
are
estimated
to
maintain
information
substantiating
the
amount
of
refrigerant
purged
or
destroyed.
EPA
estimates
that
150
owners/
operators
will
maintain
records
showing
how
they
calculated
the
full
charge
of
their
equipment
using
a
range.
EPA
also
estimates
that
100
owners/
operators
will
choose
or
be
forced
to
retrofit
their
equipment,
and
maintain
the
required
retire/
retrofit
report
on­
site
at
their
place
of
business.

°
Owners/
operators
of
refrigeration
and
air­
conditioning
equipment
with
a
charge
greater
than
50
lbs
of
an
ozone­
depleting
refrigerant
are
required
to
maintain
service
records
documenting
the
date
and
type
of
service,
as
well
as
the
quantity
of
refrigerant
added,
in
accordance
with
40
CFR
82.166(
k).
EPA
assumes
that
these
records
are
maintained
as
a
30
part
of
normal
business
procedures.
EPA
also
assumes
that
the
number
or
owners/
operators
entering
the
workplace
remains
constant
(
at
approximately
2,003,850)
with
the
number
of
owners/
operators
whose
organizations
go
out
of
business.

°
Persons
servicing
refrigeration
and
air­
conditioning
equipment
with
a
charge
greater
than
50
lbs
of
an
ozone­
depleting
refrigerant
are
required
to
provide
their
customers
with
an
invoice
indicating
the
amount
of
refrigerant
added
to
the
appliance.
EPA
assumes
that
these
records
are
submitted
as
a
part
of
normal
business
procedures,
and
in
fact
are
required
between
the
two
parties
in
order
to
initiate
payment
for
services
rendered.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
respondents
and
the
Agency
are
summarized
below
for
all
activities.

(
i)
Respondent
Tally
ANNUAL
RESPONDENT
BURDEN
AND
COST
Activity
Number
of
Respondents
Number
of
Activities
Total
Hours
per
Year
Total
Labor
Costs
($)
per
year
Refrigerant
Recovery/
Recycling
Equipment
Testing
Organizations
2
4
18.0
$
595.80
Certification
by
Service
Establishments
that
Change
Ownership
or
Enter
the
Market
2,250
1
3,375.0
$
111,712.50
Certification
by
Disposal
Establishments
that
Change
Ownership
or
Enter
the
Market
375
1
375.0
$
12,412.50
Maintenance
of
copies
of
signed
statements
by
disposal
establishments
7,500
1
67,500.0
$
2,234,250.00
ANNUAL
RESPONDENT
BURDEN
AND
COST
31
Certification
by
Refrigerant
Reclaimers
that
Change
Ownership
or
Enter
the
Market
4
1
20.0
$
662.00
Reclaimer
Reporting
and
Record
Keeping
55
1
275.0
$
9,102.50
Refrigerant
Wholesalers
Recordkeeping
for
Refrigerant
Sales
5,000
1
40,000.0
$
1,324,000.00
Technician
Certification
Programs
Applying
for
Approval
5
1
150.0
$
4,965.00
Record
keeping
by
Existing
Technician
Certification
Programs
97
1
1,552.0
$
51,371.20
Technicians
Acquiring
Certification
and
Maintaining
Certification
Cards
30,000
1
90,000.0
$
2,979,000.00
Technicians
Maintaining
Certification
Cards
300,000
1
6,000.0
$
198,600.00
Leak
Repair
Requirements
for
Owners
of
Industrial
Process
Refrigeration
Equipment
(
Appliances)

Requests
for
30­
day
extension
to
leak
repair
Requests
for
30­
day
extension
to
retrofit
requirement
10
2
56.0
$
1,853.60
ANNUAL
RESPONDENT
BURDEN
AND
COST
32
Leak
Repair
Requirements
for
Owners
of
Industrial
Process
Refrigeration
and
Commercial
and
Comfort
Cooling
Equipment
(
Appliances)

Maintain
information
on
purged/
destroyed
refrigerant
Maintain
information
on
the
calculation
of
the
full
charge
using
a
range)

Maintain
plan
to
retire/
replace
or
retrofit
equipment
310
3
1,360.0
$
45,016.00
TOTALS
345,608
19
210,681.0
$
6,973,541.10
(
ii)
The
Agency
Tally
ANNUAL
AGENCY
BURDEN
AND
COST
Activity
Number
of
Respondents
Number
of
Activities
Total
Hours
per
Year
Total
Labor
Costs
($)
per
year
Review
of
annual
lists
of
certified
recovery/
recycling
equipment
2
1
1.0
$
44.50
Review
of
notifications
of
certified
refrigerant
recovery/
recycling
equipment
that
failed
recertification
tests
2
1
2.0
$
89.00
Review
of
new
refrigerant
recovery/
recycling
equipment
certifications
2
1
5.0
$
222.50
Review
of
certifications
from
owners/
operators
of
recovery/
recycling
equipment
2,250
1
562.5
$
25,031.25
ANNUAL
AGENCY
BURDEN
AND
COST
33
Review
of
certifications
from
disposal
establishments
that
change
ownership
375
1
93.8
$
4,171.88
Review
of
applications
from
organizations
seeking
approval
as
refrigerant
reclaimers
4
1
4.0
$
178.00
Review
of
reclaimer
annual
activity
reports
55
1
55.0
$
2,447.50
Review
of
applications
from
organizations
seeking
approval
as
technician
certification
organizations
5
1
10.0
$
445.00
Review
of
biannual
reports
from
technician
certification
organizations
97
2
194.0
$
8,633.00
Review
of
owner/
operator's
IPR
requests
for
an
extension
to
the
30­
day
repair
requirement
for
mandatory
leak
repair
8
1
4.0
$
178.00
Review
of
owner/
operator's
IPR
requests
for
an
extension
to
the
retrofit/
retire
plan
2
1
2.0
$
89.00
TOTALS
2,802
12
933.3
$
41,529.63
(
iii)
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
course
of
the
clearance
period.
Likewise,
the
government
burdens
and
costs
are
not
anticipated
to
vary
significantly.

6(
f)
Reasons
for
Change
in
Burden
34
There
have
been
no
regulatory
changes
associated
with
this
rulemaking
since
the
previous
renewal
of
the
ICR.
However,
EPA
has
adjusted
the
burden
for
a
number
of
the
requirements
of
the
rulemaking.
EPA
has
also
adjusted
costs
based
on
updated
labor
rates.
These
following
adjustments
have
been
made
based
upon
the
number
of
reports
that
the
Agency
has
received
and
the
number
of
programs
that
the
Agency
has
approved
or
revoked
over
the
past
few
years.

°
The
number
of
testing
organizations
for
refrigerant
recovery/
recycling
equipment
has
remained
at
two,
and
the
number
of
activities
has
remained
at
four.
EPA
has
adjusted
the
burden
hours
from
16
to
18,
based
on
the
number
and
detail
of
the
submitted
reports
received
for
equipment
that
failed
an
initial
or
three­
year
retest.

°
EPA
has
adjusted
the
total
hours
needed
for
persons
servicing
refrigeration
and
airconditioning
equipment
to
certify
with
their
EPA
regional
office.
The
hours
were
increased
from
1,687.5
to
3,375
based
on
the
detail
of
information
provided
to
the
Agency
in
such
certifications.

°
EPA
has
increased
its
estimate
of
disposal
facilities
from
500
to
7500.
This
increase
has
resulted
in
an
increase
in
the
Agency's
estimate
of
the
number
of
certifications
received
from
new
disposal
establishments
from
25
to
375.
This
adjustment
is
based
on
the
number
of
facilities
that
may
be
involved
in
the
final
disposal
of
appliances
(
for
example,
metal
recyclers
or
haulers),
and
is
not
limited
to
scrap
dealers.

°
The
number
of
EPA­
certified
refrigerant
reclaimers
has
decreased
from
80
to
55.
The
number
of
new
programs
seeking
EPA
certification
has
also
decreased
from
an
average
of
20
to
4
per
year.
This
adjustment
is
based
on
actual
numbers
of
reclaimers
certified
and
revoked
by
EPA.

°
Based
on
inspection
reports
of
refrigerant
wholesalers,
EPA
finds
that
wholesalers
generally
maintain
records
on
their
transactions
as
a
normal
part
of
doing
business;
therefore,
EPA
has
reduced
the
burden
for
wholesalers
by
40,000
hrs
and
$
2,000,000.
However,
EPA
has
retained
the
burden
of
verifying
certifications
of
purchasers
of
ozonedepleting
refrigerants.

°
The
number
of
EPA­
approved
technician
certifying
programs
have
decreased
from
100
to
97.
The
number
of
new
programs
seeking
EPA
certification
has
also
decreased
from
an
average
of
10
to
5
per
year.
This
adjustment
is
based
on
actual
numbers
of
certifying
programs
certified
and
revoked
by
EPA.

°
EPA
has
eliminated
the
previous
burden
for
owners
of
refrigeration
and
air­
conditioning
equipment.
Such
owners/
operators
of
comfort
cooling,
commercial,
or
industrial
process
refrigeration
equipment
with
charge
sizes
greater
than
50
lbs
of
an
ozone­
depleting
refrigerant
are
required
to
maintain
service
records
indicating
the
amount
of
refrigerant
added
and
the
date
and
type
of
service
performed
on
their
equipment.
EPA
experience
prior
to
this
renewal
shows
that
such
records
are
generally
maintained
as
a
normal
business
practice.
35
°
EPA
has
increased
its
estimates
of
the
number
of
owners
of
industrial
process
refrigeration,
comfort
cooling
appliances,
and
commercial
refrigeration
appliances
who
will
seek
extensions
to
the
leak
repair
and
retrofit
requirements,
exclude
purged
refrigerant
from
their
leak
rate
calculations,
and
maintain
details
on
how
they
determined
the
full
charge
from
210
to
320.

°
EPA
has
provided
more
detail
in
its
breakdown
of
the
activities
for
clarity,
by
making
separate
activity
rows
for
the
submission
and
review
of
certifications
by
owner/
operator's
of
industrial
process
refrigeration
equipment
who
request
for
an
extension
to
the
30­
day
repair
requirement
for
mandatory
leak
repair,
and
the
submission
and
review
of
owner/
operator's
request
for
an
extension
to
the
retrofit/
retire
plan
(
eight
and
two
respondents
per
year,
respectively).
EPA
has
adjusted
its
estimates
based
upon
the
number
of
requests
for
such
extensions
that
the
Agency
has
received
over
the
past
few
years.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
from
1.2
to
30
hours
per
year
for
each
respondent.
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
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2003­
0018,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
OAR
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
36
"
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,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­
2003­
0018)
and
OMB
control
number
(
2060­
0256)
in
any
correspondence.
37
APPENDIX
1
38
APPENDIX
1
(
contd)
39
APPENDIX
1
(
contd)
40
APPENDIX
1
(
contd)
41
APPENDIX
2
ACKNOWLEDGMENTS
This
guide
was
prepared
by
a
joint
partnership
between
the
Chemical
Manufacturers
Association
and
the
Environmental
Protection
Agency.
At
the
time
of
publication
of
this
Guide,
the
development
team
had
the
following
membership:

Scot
Cidzik
Eastman
Kodak
Company
Sharon
Gidumal
DuPont
Chris
Jones
Eastman
Chemical
Company
Jim
Kinney
Union
Carbide
Corporation
Kurt
Martin
Monsanto
Chemical
Company
Shannon
Moses
Union
Carbide
Corporation
Toby
Threet
The
Dow
Chemical
Company
Paul
Winkler
Quantum
Chemical
Company
*
Donn
Hirschmann
Allied­
Signal,
Inc.

Tracy
Back
EPA,
Office
of
Compliance
Emily
Chow
EPA,
Office
of
Compliance
Ken
Gigliello
EPA,
Office
of
Compliance
Dan
Lucero
EPA,
Region
III
Cindy
Newberg
EPA,
Stratospheric
Protection
Division
James
Conrad
CMA,
Office
of
General
Counsel
Susan
Connella
CMA,
Office
of
General
Counsel
Lucinda
Schofer
CMA,
Regulatory
Affairs
Department
Rasma
Zvaners
CMA,
Regulatory
Affairs
Department
Their
technical
insights,
experiences,
and
suggestions
were
essential
to
the
development
of
this
guide.

*
contributing
participant
of
the
development
team
