Page
1
of
27
INFORMATION
COLLECTION
REQUEST
(
ICR)

ENVIRONMENTAL
PROTECTION
AGENCY
STRATOSPHERIC
OZONE
PROTECTION
SUPPORTING
STATEMENT
PART
A
1.
Identification
of
the
Information
Collection
a)
Title:
Reporting
and
Recordkeeping
Requirements
of
the
HCFC
Allowance
System
OMB
Number:
2060­
0498
EPA
ICR
Number:
2014.03
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
(
ODS).
Under
its
Protocol
commitments,
the
United
States
(
U.
S.)
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,
destroyed,
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)
with
limited
potential
exemptions
beyond
the
phaseout.
Under
the
Protocol,
the
U.
S.
is
obligated
to
limit
HCFC
consumption
(
defined
by
the
Protocol
as
production
plus
imports,
minus
exports)
under
a
specific
cap.
The
U.
S.
is
also
a
signatory
to
amendments
that
create
a
schedule
with
graduated
reductions
and
the
eventual
phaseout
of
the
consumption
of
HCFCs.
The
schedule
called
for
a
35
percent
reduction
of
the
cap
on
January
1,
2004,
followed
by
a
65
percent
reduction
on
January
1,
2010,
a
90
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)
must
adhere
to,
and
enforce
these
limits
to
both
production
and
consumption
of
HCFCs.

To
ensure
the
U.
S.
compliance
with
these
limits
and
restrictions
established
by
the
Protocol
and
the
CAAA,
EPA
established
an
allowance
system
to
control
U.
S.
production
and
import
of
HCFCs
by
granting
control
measures
referred
to
as
baseline
allowances,
based
on
the
historical
activity
of
individual
companies.
There
are
two
types
of
allowances:
consumption
allowances
(
reflecting
production,
import,
and
export
(
but
not
use)
of
ODS),
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.
Page
2
of
27
The
limits
and
restrictions
for
individual
U.
S.
companies
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
can
download
voluntary
reporting
forms
from
EPA's
stratospheric
ozone
web
site
(
http://
www.
epa.
gov/
ozone/
record.
index.
html),
complete
them,
and
then
send
them
to
EPA
via
postal
mail,
private
courier,
or
fax.
Upon
receipt
of
the
reports,
the
data
is
entered
and
subsequently
stored
in
the
ODS
Tracking
System.
The
ODS
Tracking
System
is
a
secure
database
that
maintains
the
data
that
is
submitted
to
EPA
and
allows
the
Agency
to:
(
1)
maintain
oversight
over
total
production
and
consumption
of
controlled
substances
to
satisfy
conditions
of
the
CAAA
and
fulfill
the
U.
S.
obligations
under
the
Protocol;
(
2)
monitor
compliance
with
limits
and
restrictions
on
production,
imports,
and
trades
and
specific
exemptions
from
the
phaseout
for
individual
U.
S.
companies;
and
(
3)
enforce
against
illegal
imports
and
violations
related
to
the
control
of
class
I
and
class
II
substances.

EPA
is
developing
an
electronic
reporting
system
through
the
Agency's
Central
Data
Exchange
(
CDX)
that
will
allow
regulated
entities
to
prepare
and
submit
their
data
electronically.
Electronic
reporting
is
expected
to
improve
data
quality
and
make
the
reporting
process
more
effective
and
efficient
for
reporting
companies
and
EPA.

Pursuant
to
regulations
40
CFR
part
2,
subpart
B,
reporting
businesses
are
entitled
to
assert
a
business
confidentiality
claim
covering
any
part
of
the
submitted
business
information
as
defined
in
40
CFR
2.201(
c).

Based
on
EPA
records,
the
information
collection
is
predicted
to
involve
approximately
9
producers,
30
importers
(
accounting
for
those
that
petition
to
import
used
substances),
14
exporters,
15
transformers
and
destroyers,
8
HCFC­
141b
exemption
allowance
petitioners
and
recipients,
and
21
other
respondents,
including
those
requesting
additional
consumption
allowances,
those
submitting
international
and
domestic
transfer
reports,
and
those
submitting
requests
for
allowance
trades.
Because
many
respondents
submit
multiple
report
types
and
qualify
as
multiple
respondent
types,
a
total
of
only
70
entities
will
be
affected
by
this
information
collection.
The
total
average
annual
industry
burden
and
cost
are
estimated
at
approximately
1,632
hours
and
$
138,963.

Terms
of
Clearance
When
OMB
approved
the
previous
ICR
2014.02
in
2003,
it
encouraged
EPA
to
develop
a
database
that
allows
for
direct
electronic
reporting.
OMB
stated
that
if
and
when
such
change
is
made,
EPA
should
revise
its
guidance
document
and
this
ICR
to
reflect
the
change.
OMB
further
recommended
that
should
EPA
not
include
the
option
for
electronic
reporting
in
the
future,
the
Agency
should
include
a
discussion
in
its
renewal
of
this
ICR
of
why
such
changes
were
not
made.

EPA
is
currently
pursuing
electronic
reporting.
The
Agency
is
conducting
a
pilot
test,
with
full
functionality
available
for
all
respondents
expected
to
be
ready
by
the
end
of
year
1
of
this
ICR.
EPA
is
preparing
revised
guidance
for
those
choosing
to
use
electronic
reporting.
The
Page
3
of
27
changes
in
burden
estimates
caused
by
the
availability
of
electronic
reporting
are
reflected
in
this
ICR.

2.
Need
For,
and
Use
Of,
the
Collection
a)
Authority
for
the
Collection
This
information
collection
is
authorized
under
the
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.

CAAA
'
603(
b)
Production,
import,
and
export
level
reports
On
a
quarterly
basis,
or
such
other
basis
(
not
less
than
annually)
as
determined
by
the
Administrator,
each
person
who
produced,
imported,
or
exported
a
class
I
or
class
II
substance
shall
file
a
report
with
the
Administrator
setting
forth
the
amount
of
the
substance
that
such
person
produced,
imported,
and
exported
during
the
preceding
reporting
period.
Each
such
report
shall
be
signed
and
attested
by
a
responsible
officer.
No
such
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
notified
the
Administrator
in
writing.

Article
7
of
the
Montreal
Protocol
on
Substances
that
Deplete
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
respectively
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,
separately,
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
respectively,

for
the
year
during
which
provisions
concerning
the
substances
in
Annexes
A,
B,
C
and
E
respectively
entered
into
force
for
that
Party
and
for
each
year
thereafter.
Each
Party
shall
provide
to
the
Secretariat
statistical
data
on
the
annual
amount
of
the
controlled
substance
listed
Page
4
of
27
in
Annex
E
used
for
quarantine
and
pre­
shipment
applications.
Data
shall
be
forwarded
not
later
than
nine
months
after
the
end
of
the
year
to
which
the
data
relate.

3
bis.
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
I
of
Annex
C
that
have
been
recycled.

4.
For
Parties
operating
under
the
provisions
of
paragraph
8
(
a)
of
Article
2,
the
requirements
in
paragraphs
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
ODS
enable
EPA
to:

1)
Ensure
compliance
with
the
restrictions
on
production,
import
and
export
of
controlled
ODS
during
the
phaseout
of
class
II
substances;
2)
Allow
exempted
production
and
import
for
certain
uses
and
the
consequent
tracking
of
that
production
and
import;
3)
Address
industry
and
Federal
concerns
regarding
the
illegal
import
of
mislabeled
used
controlled
substances;
4)
Satisfy
U.
S.
obligations
under
international
treaty
to
report
data
annually
to
the
Ozone
Secretariat,
as
listed
in
Article
7
of
the
Protocol;
5)
Fulfill
statutory
obligations
under
Section
603(
b)
and
of
Title
VI
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
statutorily
required
in
Section
603(
d)
of
Title
VI
of
the
CAAA.

The
information
reported
to
EPA
is
entered
into
an
electronic
tracking
system
to
ensure
companies
do
not
exceed
their
allowances
and
to
guarantee
the
U.
S.
does
not
violate
its
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.

Industry
representatives
and
many
Federal
agencies,
including
EPA,
are
concerned
about
claims
of
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
in
the
form
of
a
petition
about
the
previous
use
and
future
intended
use
of
the
material.
Page
5
of
27
3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
a)
Nonduplication
All
the
information
requested
from
respondents
under
this
ICR
is
required
by
statute
(
CAAA
'
603(
b))
and
is
not
available
from
other
sources
because
it
is
proprietary
information
submitted
by
industry
sources.

b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
Paperwork
Reduction
Act
of
1995,
EPA
has
issued
a
public
notice
in
the
Federal
Register
on
December
20,
2005
(
70
FR
75458).
The
public
comment
period
extended
through
February
21,
2006.
EPA
received
one
comment
letter
in
response
to
the
FRN.
The
comments
in
the
letter,
however,
do
not
pertain
to
this
ICR
or
its
information
collections
and
therefore
no
action
was
taken
on
the
comments
in
relation
to
the
ICR's
renewal.

c)
Consultations
The
recordkeeping
and
reporting
requirements
were
established
in
the
original
HCFC
allowance
system
rule
promulgated
January
21,
2003
(
68
FR
2820).
Prior
to
that
rule,
in
1998,
EPA
conducted
two
stakeholder
meetings
for
members
of
the
industry
while
considering
the
many
aspects
of
an
HCFC
allowance
system.
EPA
published
an
Advance
Notice
of
Proposed
Rulemaking
(
ANPRM)
on
April
5,
1999,
in
which
the
options
for
an
allowance
system
were
discussed.
These
experiences
strengthened
EPA's
understanding
of
the
impacts
of
the
requirements
on
respondents.
EPA
has
used
this
knowledge
in
developing
the
burden
estimates
in
this
ICR.

In
addition,
EPA
recently
prepared
an
ICR
entitled,
"
Record
Keeping
and
Periodic
Reporting
of
the
Production,
Import,
Recycling,
Destruction,
Transshipment
and
Feedstock
Use
of
Ozone­
Depleting
Substances
(
ICR
Number
1432.25)."
In
preparing
that
ICR,
EPA
assessed
respondent
burden
through
informal
consultations
with
regulated
entities.
Because
the
information
collection
requirements
in
ICR
1432.25
are
very
comparable
in
scope
and
nature
to
the
information
collection
requirements
in
ICR
2014.03,
EPA
has
applied
in
this
ICR
some
of
the
assumptions
used
in
ICR
1432.25.

As
EPA
moves
towards
the
implementation
of
an
electronic
reporting
option,
EPA
has
consulted
with
a
range
of
respondents
to
understand
their
general
business
practices
as
they
concern
recordkeeping
and
reporting
requirements.

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.
Penalties
for
exceeding
the
regulatory
limits
are
assessed
at
$
27,500
per
kilogram
per
Page
6
of
27
day
which
necessitates
frequent
information
collection.
Violations
would
be
much
more
complex
to
pursue
and
enforce
if
the
information
were
submitted
less
frequently.

Less
frequent
reporting
would
potentially
put
the
United
States
in
a
non­
compliance
status
under
the
Protocol.
If
the
U.
S.
were
to
exceed
the
limits
established
by
international
treaty
it
would
jeopardize
the
ability
of
the
U.
S.
to
negotiate
and
secure
favorable
positions
in
the
international
forum.
Quarterly
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.

Less
frequent
collection
of
information
would
place
an
undue
burden
on
both
EPA
and
industry
to
ensure
accuracy
of
data.
Any
inaccuracy
would
be
compounded
by
the
greater
time
between
an
actual
event
and
the
efforts
needed
to
correct
the
historical
information.
Inaccuracies
in
information
would
compromise
EPA's
ability
to
implement
the
program.
Inaccuracies
would
also
reduce
the
validity
of
both
reports
to
Congress
and
reports
to
the
Secretariat
of
the
Protocol.

e)
General
Guidelines
Information
collections
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.
Information
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).

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
and
SIC
codes
associated
with
producers,
importers,
exporters,
transformers,
and
destroyers
of
HCFCs
affected
by
the
reporting
and
recordkeeping
requirements
covered
under
this
ICR.
Page
7
of
27
Table
1:
NAICS
and
SIC
Codes
Associated
with
the
ICR
Category
NAICS
Code
SIC
Code
Examples
of
Regulated
Entities
Chlorofluorocarbon
Gas
Manufacturing
Chlorodifluoromethane
Manufacturers
Dichlorofluoroethane
Manufacturers
Chlorodifluoroethane
Manufacturers
Chlorofluorocarbon
Gas
Importers
Chlorodifluoromethane
Importers
Dichlorofluoroethane
Importers
Chlorodifluoroethane
Importers
Chlorofluorocarbon
Gas
Exporters
325120
2869
Chlorodifluoromethane
Exporters
Dichlorofluoroethane
Exporters
Chlorodifluoroethane
Exporters
Urethane
and
Other
Foam
Product
(
Except
Polystyrene)
Manufacturing
326150
3086
Insulation
and
Cushioning,
Foam
Plastics
(
Except
Polystyrene)
Manufacturing
b)
Information
Requested
EPA
monitors
the
system
of
production
allowances
and
consumption
allowances
for
the
production
and
import
of
class
II
controlled
substances
through
quarterly
and
annual
reports.
Producers,
importers,
exporters
and
others
identified
in
§
82.16,
§
82.18,
§
82.20,
§
82.23,
and
§
82.24
must
maintain
records
and
report
the
following
to
EPA:

(
i)
Data
Items
Producers
(
§
82.24)

 
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
by
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
unexpended
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;

 
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
destroyed
and
therefore
were
not
produced
expending
production
or
consumption
allowances;

 
For
transformation
in
the
U.
S.
or
by
a
person
of
another
Party,
one
copy
of
a
transformation
verification
from
the
transformer
for
a
specific
class
II
controlled
Page
8
of
27
substance
and
a
list
of
additional
quantities
shipped
to
that
same
transformer
for
the
quarter;

 
For
destruction
in
the
U.
S.
or
by
a
person
of
another
Party,
one
copy
of
a
destruction
verification
for
a
particular
destroyer,
destroying
the
same
class
II
controlled
substance,
and
a
list
of
additional
quantities
shipped
to
that
same
destroyer
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
quantity
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
or
for
use
in
processes
that
result
in
their
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
records
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
class
II
controlled
substance
introduced
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
shipments
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
recycled
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
transformation,
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
destroy
the
class
II
controlled
substance,
or
sell
the
class
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
Page
9
of
27
 
Written
verifications
from
a
U.
S.
purchaser
that
HCFC­
141b
was
manufactured
for
the
express
purpose
of
meeting
HCFC­
141b
exemption
needs,
in
cases
where
HCFC­
141b
exemption
allowances
were
expended
to
produce
the
HCFC­
141b.

Importers
(
§
82.24)

 
The
following
information
must
be
reported:

 
Summaries
of
the
required
records
for
the
previous
quarter;

 
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
quantity
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
by
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
each
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;

 
The
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
substances
imported
and
sold
for
use
in
processes
that
result
in
their
destruction
or
transformation;

 
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
copy
of
the
bill
of
lading;
import
invoices;
quantity
of
imports
of
used
class
II
controlled
substances;
and
the
U.
S.
Customs
Summary
Entry
form;
Page
10
of
27
 
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
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,
phone
number
and
fax
number
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
of
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
the
material
was
recovered
at
each
source
facility;
­
The
name,
address,
contact
person,
phone
number
and
fax
number
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
transporting
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
fax
number
of
the
ultimate
purchaser
in
the
United
States;
­
The
name,
address,
contact
person,
phone
number
and
fax
number
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
fax
numbers
of
that
person;
­
If
the
imported
class
II
controlled
substance
was
reclaimed
in
a
foreign
Party,
the
name,
address,
contact
person,
phone
number
and
fax
number
of
any
or
all
foreign
reclamation
facility(
ies)
responsible
for
reclaiming
the
cited
shipment;
­
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
Page
11
of
27
­
A
certification
of
accuracy
of
the
information
submitted
in
the
petition.

 
A
person
receiving
an
objection
notice
from
the
Administrator
may
re­
petition
within
ten
working
days
after
receipt,
only
if
the
Administrator
indicated
"
insufficient
information"
as
the
basis
for
the
objection
notice
for
the
original
petition.

 
A
person
receiving
a
non­
objection
notice
from
the
Administrator
for
a
petition
to
import
used
class
II
controlled
substances
must
maintain
the
following
records:
­
A
copy
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
by
persons
that
tranship
class
II
controlled
substances:

 
Records
that
indicate
that
the
class
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
days
of
the
end
of
the
control
period.

Exporters
(
§
82.24)

 
The
following
information
must
be
reported:

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

 
The
exporter's
Employer
Identification
Number;

 
The
type
and
quantity
of
each
class
II
controlled
substance
exported
and
what
percentage,
if
any
of
the
class
II
controlled
substance
is
used;

 
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
exported
to
each
Article
5
country;

 
The
commodity
code
for
the
class
II
controlled
substances
shipped;
Page
12
of
27
 
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
vessel
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)

 
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
class
II
controlled
substances
received
by
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
copy
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
the
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.

 
A
copy
of
the
person's
destruction
verification
in
the
case
where
class
II
controlled
substances
were
purchased
or
transferred
for
destruction
purposes;
Page
13
of
27
 
The
following
information
on
transformation
and
destruction
must
be
reported:

 
The
names
and
quantities
of
the
class
II
controlled
substances
transformed
for
each
control
period
within
45
days
of
the
end
of
such
control
period;

 
The
names
and
quantities
of
the
class
II
controlled
substances
destroyed
for
each
control
period
within
45
days
of
the
end
of
such
control
period;

 
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:

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

 
The
quantity
of
class
II
controlled
substances
intended
for
transformation;

 
Identity
of
shipments
by
purchase
order
number(
s),
purchaser
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
destroyed
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
originally
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:

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

 
Indication
of
whether
those
class
II
controlled
substances
will
be
completely
destroyed,
or
less
than
completely
destroyed,
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
Allowance
Petitioners
(
§
82.16)

 
A
person
petitioning
for
an
HCFC­
141b
exemption
allowance
must
submit
the
following:

 
Name
and
address
of
the
HCFC­
141b
formulator,
U.
S.
government
entity
or
nongovernmental
space
vehicle
entity;

 
Name
of
contact
person,
phone
number,
fax
number
and
e­
mail
address;
Page
14
of
27
 
Quantity
of
HCFC­
141b
needed
for
each
relevant
calendar
year,
supported
by
documentation
about
past
use
for
at
least
the
previous
three
years;

 
Quantities
of
HCFC­
141b,
if
any,
contained
in
systems
that
were
sold
to
other
systems
houses
for
at
least
the
previous
three
years;

 
Description
of
the
markets
and
applications
served
by
the
use
of
HCFC­
141b
or
systems
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
analysis
showing
why
stockpiled,
recovered
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
verification;

 
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
the
number
of
control
periods
identified.

Persons
allocated
HCFC­
141b
Exemption
Allowances
(
§
82.24)

 
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;
and
Page
15
of
27
 
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.

Request
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
Employer
Identification
Number;

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

 
The
quantity
and
type
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
copy
of
the
bill
of
lading
and
the
invoice
indicating
the
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.

International
Transfers
of
Allowances
for
class
II
controlled
substances
(
§
82.20)

 
A
person
must
submit
the
following
information
on
a
trade
from
a
Party:

 
A
signed
document
from
the
principal
diplomatic
representative
in
the
Polish
or
Norwegian
embassy
in
the
U.
S.
stating
that
the
appropriate
authority
within
that
nation
will
establish
or
revise
consumption
limits
for
the
nation
to
equal
the
lowest
of
the
following
three
consumption
quantities:


The
maximum
consumption
that
the
nation
is
allowed
under
the
Protocol
minus
the
quantity
traded;


The
maximum
consumption
that
is
allowed
under
the
nation's
applicable
domestic
law
minus
the
quantity
traded;
or

The
average
of
the
nation's
actual
consumption
level
for
the
three
years
prior
to
the
trade
minus
the
consumption
traded.

 
A
person
requesting
a
consumption
trade
from
Poland
or
Norway
must
also
submit
to
the
Administrator
a
true
copy
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
type
and
quantity
of
consumption
being
traded;


Documentation
that
the
Party
possesses
the
necessary
quantity
of
unexpended
consumption
rights;
and

The
control
period(
s)
to
which
the
trade
applies.
Domestic
Transfers
of
Allowances
for
class
II
controlled
substances
(
§
82.23)
Page
16
of
27
 
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
type
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
type
and
for
the
control
period
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
receiving
a
notice
from
the
Administrator
disallowing
the
transfer
may
file
a
notice
of
appeal,
with
supporting
reasons,
with
the
Administrator
within
10
working
days
after
receipt
of
notification.

 
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
type
of
allowances
being
converted,
including
the
names
of
the
class
II
controlled
substances
for
which
allowances
are
to
be
converted;

 
The
quantity
and
type
of
allowances
to
be
converted;

 
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
type
and
for
the
control
period
being
converted
that
the
transferor
holds
under
authority
of
this
subpart
as
of
the
date
the
claim
is
submitted
to
EPA.

 
A
person
receiving
a
notice
from
the
Administrator
disallowing
the
transfer
may
file
a
notice
of
appeal,
with
supporting
reasons,
with
the
Administrator
within
10
working
days
after
receipt
of
notification.
Page
17
of
27
Availability
of
production
in
addition
to
baseline
production
allowances
for
class
II
controlled
substances
(
§
82.18)

 
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
must
be
submitted
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
equal
the
lowest
of
the
following
three
production
quantities:


The
maximum
production
that
the
nation
is
allowed
under
the
Protocol
minus
the
quantity
to
be
traded;


The
maximum
production
that
is
allowed
under
the
nation's
applicable
domestic
law
minus
the
quantity
to
be
traded;
or

The
average
of
the
nation's
actual
national
production
level
for
the
three
years
prior
to
the
trade
minus
the
production
to
be
traded.

 
A
true
copy
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
type
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,
for
a
specified
control
period,
must
submit
a
request
to
EPA
that
sets
forth
the
following
information:

 
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
type
and
quantity
of
allowable
production
being
traded;
and
 
The
control
period(
s)
to
which
the
trade
applies.

(
ii)
Respondent
Activities
 
Producers
must
submit
quarterly
reports
and
keep
records.
 
Importers
must:
­
Submit
quarterly
reports,
and
keep
records
­
Submit
information
in
a
petition
and
re­
petition
and
keep
records
of
petitions
if
applicable;
Page
18
of
27
­
Indicate
specified
information
of
an
import
of
heels
on
bill
of
lading;
and
­
Report
quarterly
on
a
container
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
quarterly
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
days
of
the
end
of
such
control
period,
and
keep
records,
if
applicable;
­
Submit
a
transformation
verification
(
transformers
only)
to
the
producer
or
importer,
if
applicable;
­
Submit
a
one­
time
destruction
efficiency
report
to
EPA
(
destroyers
only),
as
applicable;
and
­
Submit
a
destruction
verification
(
destroyers
only)
to
the
producer
or
importer,
as
applicable.
 
Persons
wanting
to
petition
for
an
HCFC­
141b
exemption
allowance
must
submit
a
petition.
 
Persons
allocated
HCFC­
141b
exemption
allowances
must
submit
a
report
semi­
annually
and
keep
records.
 
Persons
requesting
additional
consumption
allowances
must
submit
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),
respectively;
and
 
File
a
notice
of
appeal,
as
applicable.
 
Persons
wanting
to
increase
its
or
decrease
its
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
applicable.

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
must
be
kept
for
three
years.
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.
Information
from
these
recordkeeping
documents
is
summarized
in
reports.
Recordkeeping
requirements
are
designed
to
aid
EPA
in
compliance
monitoring,
site
inspection,
and
enforcement
actions.
Page
19
of
27
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
System
to
incorporate
revisions
to
the
regulations;
 
Revise
guidance
documents
to
describe
reporting
requirements;
 
Enter
and
store
information
submitted
from
companies
in
the
ODS
Tracking
System;
 
Respond
to
companies
submitting
tracked/
monitored
information,
such
as
requests
for
transfers;
 
Review
petitions
to
import
used
HCFCs;
 
Review
petitions
requesting
HCFC­
141b
exemption
allowances;
 
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
tracking
system
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
System
to
ensure
exempted
production
and
imports
do
not
exceed
limits
in
Section
605
of
Title
VI
of
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
regulated
entities
to
use
to
report
the
required
information.
All
forms
are
available
on
the
EPA's
Stratospheric
Ozone
web
site
at
http://
www.
epa.
gov/
ozone/
record/
index.
html.
In
addition,
a
Guidance
Document
for
Stratospheric
Ozone
Protection
Program
after
January
1,
2005,
is
provided
to
assist
participants
in
completing
the
forms.
Reporting
forms
can
be
sent
to
EPA
via
postal
mail,
private
courier,
or
fax.

Although
the
use
of
the
forms
is
voluntary,
they
are
generally
used
by
every
participant
in
the
regulatory
program
and
have
greatly
eased
submission
of
data.
EPA
is
currently
developing
and
testing
a
method
for
electronic
reporting
of
required
data
and
will
keep
regulated
participants
informed
throughout
the
process.
EPA
will
appropriately
revise
the
guidance
document
to
include
information
regarding
the
electronic
reporting
option
once
the
electronic
reporting
system
is
available.

The
reporting
requirements
are
similar
to
those
for
companies
that
produce
or
consume
class
I
controlled
substances
and
those
that
produce
or
consume
Class
II
controlled
substances,
which
are
covered
by
the
predecessor
to
this
ICR
(
2014.02)
Page
20
of
27
c)
Small
Entity
Flexibility
Much
of
this
information
collection
is
required
by
statute.
Any
additional
information
required
is
collected
in
response
to
Congressional
requests
for
reports
and
U.
S.
reporting
obligations
under
the
Protocol.
EPA
believes
the
information
collection
is
required
to
ensure
allowance
holders
have
intended
access
to
their
allowances,
to
produce
these
nationally
and
internationally
mandated
reports,
and
to
ensure
compliance
with
sections
605
and
606
of
the
CAAA.

Although
most
respondents
to
the
program
are
large
companies,
the
burden
on
all
affected
entities,
and
especially
the
burden
on
small
entities,
has
been
reduced
to
every
extent
possible.
For
example,
EPA
expects
to
give
respondents
the
flexibility
to
report
electronically
in
the
coming
two
years,
which
should
eventually
decrease
the
burden
to
both
large
and
small
entities.

d)
Collection
Schedule
The
collection
schedule
is
as
follows:

 
Producers,
importers,
and
exporters
are
to
report
to
EPA
quarterly
(
45
days
after
the
end
of
each
quarter).
 
Persons
that
transform
and/
or
destroy
class
II
controlled
substances
are
to
report
to
EPA
annually
(
45
days
after
the
end
of
the
control
period).
 
Persons
wanting
to
petition
for
HCFC­
141b
exemption
allowances,
transfer
consumption
allowances
to
another
company
or
to
another
chemical,
request
additional
consumption
allowances,
request
international
transfer
of
allowances,
request
a
trade
from
or
to
a
Party
to
increase
or
decrease
production
allowances,
export
production
allowances,
or
Article
5
allowances,
and
import
used
class
II
controlled
substances
(
i.
e.,
petition)
are
to
submit
reports
to
EPA
on
a
transactional
basis.
 
Entities
holding
HCFC­
141b
exemption
allowances
are
to
report
to
EPA
semi­
annually
(
30
days
after
the
end
of
the
second
and
fourth
quarters).

6.
Estimating
the
Burden
and
Cost
of
Collection
a)
Estimating
Respondent
Burden
The
basis
of
the
analysis
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
has
been
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
quarterly,
semiannual,
annual,
or
other
(
per
transaction)
reporting
requirements;
EPA's
experience
with
reporting
under
both
the
CFC
and
HCFC
allowance
systems
in
the
past;
and
dialogues
with
industry
representatives.

It
was
estimated
that
the
burden
to
respondents
submitting
paper
reports
is
approximately
4.5
hours
per
report
prepared.
This
assumption
was
based
on
consultations
with
industry
Page
21
of
27
representatives
conducted
for
the
preparation
of
ICR
1432.25,
as
discussed
in
section
3c
of
this
ICR.
Four
hours
were
allotted
for
data
compilation
and
0.5
hours
for
report
preparation.
The
burden
to
respondents
submitting
petitions
was
estimated
at
eight
hours
per
petition
prepared.
Additional
hours
were
assumed
because
petitions
must
be
prepared
individually
depending
on
the
respondent's
request
and
no
standard
report
exists.

The
process
of
preparing
electronic
submittals
was
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
1432.25,
which
indicated
that
the
majority
of
respondents
maintain
their
data
in
an
electronic
format
and
manually
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.
In
addition,
it
was
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
appropriately,
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
for
in
ICR
2002.03,
"
Cross­
Media
Electronic
Reporting
and
Recordkeeping
Rule".)
The
eight
hours
were
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
years
=
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).

b)
Estimating
Respondent
Cost
To
determine
respondent
costs,
an
average
hourly
wage
rate
of
$
40.31
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
2005.
A
110
percent
increase
was
added
to
reflect
the
estimated
additional
costs
for
overhead
and
fringe,
which
increased
the
wage
rate
to
$
84.65
per
hour.
Burden
hours,
as
described
above,
were
multiplied
by
the
labor
rate
to
determine
respondent
costs.

Operations
and
Maintenance
(
O&
M)
costs,
including
photocopying,
packaging,
and
postage,
were
estimated
for
all
respondents
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
been
added
since
the
previous
ICR,
and
it
was
assumed
that
only
those
respondents
with
the
necessary
computer
equipment
to
report
electronically
would
choose
this
option.

c)
Estimating
Agency
Burden
and
Cost
Page
22
of
27
The
basis
of
this
analysis
is
the
identification
of
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.
Costs
are
subdivided
into
Agency
and
contractor
costs.
The
average
hourly
rates
for
EPA
staff
of
$
39.53
and
$
53.24,
respectively,
were
derived
from
the
2006
GS
Salary
Schedule
for
the
locality
pay
area
of
Washington­
Baltimore­
Northern
Virginia,
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
hourly
rates
of
$
63.25
for
technical
staff
and
$
85.18
for
managerial
staff.
The
cost
of
contractor
time
and
overhead
is
valued
at
$
85.00
per
hour,
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
systems.

Start­
up
costs
for
report
submittal
were
estimated
to
be
$
22,000
to
account
for
the
equipment
and
fees
necessary
to
implement
electronic
reporting.
These
costs
include
a
one­
time
fee
of
$
20,000
paid
to
CDX
to
cover
the
costs
of
taking
on
an
additional
electronic
reporting
client
and
an
additional
cost
of
approximately
$
2,000
for
equipment
purchase
and
set­
up.

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
ICR.
EPA
tracks
the
number
of
respondents
and
submittals
under
the
program
through
the
ODS
Tracking
System.
EPA
referred
to
historical
data
in
the
ODS
Tracking
System
to
estimate
the
annual
number
of
respondents
in
this
ICR,
as
shown
in
Table
2.
Because
not
all
submitted
reports/
petitions/
requests
are
tracked
by
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
Respondentsa
Type
of
Respondent
Annual
Number
of
Respondents
Producer
9
Importerb
30
Exporter
14
Transformers/
Destroyers
15
HCFC­
141b
Exemption
Allowance
Recipientsc
8
Otherd
21
Total
Respondents
70
aNumbers
in
the
table
are
not
additive.
The
information
collection
will
only
affect
70
distinct
companies.
Several
respondents
submit
multiple
report
types
(
e.
g.,
producers
can
also
be
exporters).
bRepresents
importers
and
respondents
that
petition
to
import
used
substances.
cRepresents
petitioners
and
recipients
of
HCFC­
141b
exemption
allowances.
dRepresents
requests
for
additional
consumption
allowances,
requests
for
allowance
trades,
and
international/
domestic
transfer
of
allowance
reports.
Page
23
of
27
EPA
expects
that
some
respondents
in
Table
2
will
choose
to
submit
their
reports
electronically
to
EPA
via
the
CDX,
while
others
will
continue
to
report
by
paper.
The
option
to
submit
reports
through
CDX
will
be
available
for
only
certain
response
types
and
will
not
be
available
until
the
second
year
that
this
ICR
will
be
in
effect.
Therefore,
EPA
has
made
the
assumption
that
all
respondents
would
submit
by
paper
during
the
first
year
of
this
ICR.
During
the
second
and
third
years
of
this
ICR,
EPA
estimates
that
approximately
90
percent
of
those
respondents
that
will
have
the
option
of
electronic
reporting
will,
on
average,
submit
their
reports
to
EPA
electronically
each
year.
The
remaining
~
10
percent
will
report
by
paper
each
year.

Given
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
by
paper
or
electronically
during
the
three­
year
period.
For
example,
EPA
estimates
that
all
nine
producers
will
submit
by
paper
in
Year
1
and
that
one
will
submit
by
paper
in
Year
2
and
in
Year
3
(
i.
e.,
9
producers
x
10%/
year
 
1
producer/
year).
Hence,
EPA
estimates
that
4
producers,
on
average,
would
submit
by
paper
annually
during
the
three­
year
period
of
this
ICR
(
i.
e.,
(
9
+
1
+
1)/
3
years
 
4/
year).
EPA
estimates
that
the
remaining
5
producers
will
submit
electronically,
on
average,
each
year.
EPA
performed
the
same
calculations
for
all
other
respondents
in
Table
2.
The
results
are
presented
in
Table
3.
These
respondent
estimates
are
used
in
the
burden
calculations
presented
in
Table
4.

Table
3.
Average
Annual
Number
of
Respondents
that
Report
by
Paper
or
Electronically
During
Three­
Year
Life
of
ICR
Average
Annual
Number
of
Respondents
Type
of
Respondent
Reporting
by
Paper
Reporting
Electronically
Producer
4
5
Importer
12
18
Exporter
5
9
Transformers/
Destroyers
6
9
HCFC­
141b
Exemption
Allowance
Recipients
8
0
Othera
11
10
a
Includes
requests
for
additional
consumption
allowances,
requests
for
allowance
trades,
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
24
of
27
Table
4.
Respondent
Burden
and
Costs
Estimates
Hours
and
Costs
Per
Activity
Total
Hours
and
Costs
Information
Collection
Activity:

Recordkeeping
and
Reportinga
Hours/
Activityb
Number
of
Activities/

Year
Annualized
Startup
Hours
Hours/

Year
Labor
Costs/
Year
Annualized
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
0.0
18.0
$
1,523.70
$
0.00
$
20.00
4
72.0
$
6,174.80
Electronic
4.0
4.0
2.7
18.7
$
1,582.96
$
0.00
$
0.00
5
93.5
$
7,914.78
Importer
Submit
Quarterly
Reports
Paper
4.5
4.0
0.0
18.0
$
1,523.70
$
0.00
$
20.00
12
216.0
$
18,524.40
Electronic
4.0
4.0
2.7
18.7
$
1,582.96
$
0.00
$
0.00
18
336.6
$
28,493.19
Petition
to
Import
Used
Substance
(
Paper)
8.0
1.0
0.0
8.0
$
677.20
$
0.00
$
5.00
4
32.0
$
2,728.80
Exporter
Submit
Quarterly
Reports
Paper
4.5
4.0
0.0
18.0
$
1,523.70
$
0.00
$
20.00
5
90.0
$
7,718.50
Electronic
4.0
4.0
2.7
18.7
$
1,582.96
$
0.00
$
0.00
9
168.3
$
14,246.60
Transformers/
Destroyers
Submit
Second
Party
Transformation
Report
Paper
4.5
1.0
0.0
4.5
$
380.93
$
0.00
$
5.00
2
9.0
$
771.85
Electronic
4.0
1.0
2.7
6.7
$
567.16
$
0.00
$
0.00
3
20.1
$
1,701.47
Submit
Second
Party
Destruction
Report
Paper
4.5
1.0
0.0
4.5
$
380.93
$
0.00
$
5.00
4
18.0
$
1,543.70
Electronic
4.0
1.0
2.7
6.7
$
567.16
$
0.00
$
0.00
6
40.2
$
3,402.93
Submit
Transformation
Verification
Report
4.5
1.0
0.0
4.5
$
380.93
$
0.00
$
5.00
5
22.5
$
1,929.63
Submit
Destruction
Efficiency
Report
4.5
1.0
0.0
4.5
$
380.93
$
0.00
$
5.00
5
22.5
$
1,929.63
Submit
Destruction
Verification
Report
4.5
1.0
0.0
4.5
$
380.93
$
0.00
$
5.00
10
45.0
$
3,859.25
HCFC­
141b
Exemption
Allowance
Recipients
Submit
Semi­
annual
Reports
4.5
2.0
0.0
9.0
$
761.85
$
0.00
$
10.00
8
72.0
$
6,174.80
Other
Request
for
Additional
Consumption
Allowances
Paper
4.5
3.0
0.0
13.5
$
1,142.78
$
0.00
$
15.00
2
27.0
$
2,315.55
Electronic
4.0
3.0
2.7
14.7
$
1,244.36
$
0.00
$
0.00
3
44.1
$
3,733.07
Submit
International
Transfer
of
Allowances
Report
4.5
1.0
0.0
4.5
$
380.93
$
0.00
$
5.00
2
9.0
$
771.85
Submit
Domestic
Transfer
of
Allowances
Report
Paper
4.5
4.0
0.0
18.0
$
1,523.70
$
0.00
$
20.00
5
90.0
$
7,718.50
Electronic
4.0
4.0
2.7
18.7
$
1,582.96
$
0.00
$
0.00
7
130.9
$
11,080.69
Submit
Request
for
Allowance
Trade
4.5
1.0
0.0
4.5
$
380.93
$
0.00
$
5.00
2
9.0
$
771.85
Petition
for
HCFC­
141b
Exemption
Allowances
8.0
1.0
0.0
8.0
$
677.20
$
0.00
$
5.00
8
64.0
$
5,457.60
Total
102.5
51.0
18.9
244.9
$
20,730.79
$
0.00
$
150.00
129
1631.7
$
138,963.41
a
Electronic
reporting
is
only
applicable
to
certain
reporting
requirements.

b
Hours
per
activity
were
based
on
consultations
with
respondents.
The
similar
ICR
1432.25
used
the
assumption
of
4.5
hours
per
paper
report
prepared.
Electronic
reporting
is
estimated
to
require
four
hours
per
report
prepared,
with
an
additional
eight
hours
during
the
first
year
of
electronic
reporting.
Page
25
of
27
Table
5.
Agency
Burden
and
Costs
Estimates
Agency
Hours
and
Costs
Per
Activity
Total
Hours
and
Costs
Managerial
Technical
Contractor
Information
Collection
Activity
$
85.18
$
63.25
$
85.00
Number
of
Occurrences
per
Year
Labor
Costs/
Year
Annualized
Capital
Startup
Costs
Annual
O&
M
Costs
Total
Hours/
Year
Total
Cost/
Year
Notify
Submitters
of
Baseline
Allowances
0.5
1
0
19
$
2,010.96
$
0.00
$
0.00
28.5
$
2,010.96
Modify
Tracking
System
10
26
100
1
$
10,996.30
$
7,333.33
$
0.00
136.0
$
18,329.63
Revise
Guidance
Document
6
40
100
1
$
11,541.08
$
0.00
$
0.00
146.0
$
11,541.08
Enter
and
Store
Information
in
the
Tracking
System
0
169
0
1
$
10,689.25
$
0.00
$
0.00
169.0
$
10,689.25
Respond
to
Companies
Submitting
Transfer
Requests
0
1
0
12
$
759.00
$
0.00
$
0.00
12.0
$
759.00
Review
Petitions
Submitted
to
Import
Used
HCFCs
2
4
0
4
$
1,693.44
$
0.00
$
0.00
24.0
$
1,693.44
Review
Petitions
Submitted
Requesting
HCFC­

141b
Exemption
Allowances
2
4
0
8
$
3,386.88
$
0.00
$
0.00
48.0
$
3,386.88
Review
Information
and
Conduct
Compliance
Monitoring
Activities
Related
to
Restrictions
4
32
0
36
$
85,129.92
$
0.00
$
0.00
1,296.0
$
85,129.92
Inspect
Records
Maintained
by
Submitters
4
32
0
36
$
85,129.92
$
0.00
$
0.00
1,296.0
$
85,129.92
Review
Information
in
Tracking
System
to
Ensure
Non­
Exceedance
of
Montreal
Protocol
Caps
2
8
0
1
$
676.36
$
0.00
$
0.00
10.0
$
676.36
Review
Information
in
Tracking
System
to
Ensure
Non­
Exceedance
of
CAAA
Limits
2
8
0
1
$
676.36
$
0.00
$
0.00
10.0
$
676.36
Compile
Reports
Mandated
by
Montreal
Protocol
and
CAAA
4
30
0
1
$
2,238.22
$
0.00
$
0.00
34.0
$
2,238.22
Total
37
355
200
121
$
214,927.69
$
7,333.33
$
0.00
3,209.5
$
222,261.02
Page
26
of
27
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
be
on
average,
approximately
1,632
hours
and
$
138,963.
The
bottom­
line
burden
to
respondents
over
three
years
is
estimated
to
be
4,896
hours
and
$
416,889.

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
1,632
$
138,123
$
0
$
840
$
138,963
(
ii)
Agency
Tally
As
shown
in
Table
7,
EPA
estimates
the
total
annual
hour
and
cost
burden
to
the
Agency
to
be
3,210
hours
and
$
222,261.
The
bottom­
line
burden
to
the
Agency
over
three
years
is
estimated
to
be
9,630
hours
and
$
666,783.

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
3,210
$
214,928
$
7,333
$
0
$
222,261
f)
Reasons
for
Change
in
Burden
The
previously
approved
ICR
estimated
a
total
annual
respondent
burden
of
3,292
hours.
By
comparison,
this
ICR
estimates
a
total
annual
burden
of
1,632
hours,
which
is
a
decrease
of
1,660
hours.
This
change
can
be
attributed
to
two
factors,
as
discussed
below.

First,
the
previous
ICR
(
2014.02)
estimated
8
hours
for
a
respondent
to
prepare
and
submit
a
report.
This
ICR
estimates
a
respondent
will
need
4.5
hours.
The
4.5­
hour
estimate
is
based
on
recent
feedback
from
respondents
under
the
program
and
is
therefore
more
reliable
and
up­
to­
date
than
the
8­
hour
estimate.
1
Additionally,
EPA
believes
that,
in
comparison
with
three
years
ago,
respondents
are
more
familiar
with
the
reporting
requirements
and
have
improved
their
processes
for
collecting
and
documenting
the
information
requested.
Consequently,
respondents
have
reduced
their
burden
in
reporting
the
information.

Second,
EPA
has
improved
the
assumptions
used
to
calculate
the
respondent
burden
by
obtaining
recent
data
on
the
number
and
frequency
of
reports
retrieved
from
the
ODS
Tracking
System
and
from
records
maintained
on
submitted
reports/
petitions/
requests
not
tracked
by
the
ODS
Tracking
System.
These
improvements
adjusted
the
burden
estimates
to
more
accurately
reflect
the
current
reporting
situation.

1
The
burden
estimate
of
4.5
hours
was
used
in
the
recently
prepared
ICR
1432.25
for
class
I
substances
and
was
based
on
consultations
with
industry.
Because
ICR
1432.25
is
comparable
in
scope
and
nature
to
ICR
2014.03,
4.5
hours
is
used
to
more
accurately
reflect
the
actual
burden
to
respondents.
Page
27
of
27
The
option
of
electronic
reporting
imposes
a
minimal
change
to
burden
estimates
because
of
the
start­
up
hours
associated
with
electronic
reporting
that
EPA
estimates
will
be
required
during
the
three
years
of
this
ICR.
While
electronic
reporting
is
eventually
expected
to
reduce
the
reporting
burden
for
respondents,
as
well
as
the
O&
M
costs,
the
reduction
will
not
be
seen
until
after
this
ICR
period.

g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
be
on
average
approximately4.8
hours
per
response.
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
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
B102,1301
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
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Office
of
Air
and
Radiation
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
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
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
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
HQOAR
2003­
0039
and
OMB
Control
Number
2060­
0498
in
any
correspondence.
