INFORMATION
COLLECTION
REQUEST
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STRATOSPHERIC
OZONE
PROTECTION
A.
JUSTIFICATION
Section
1:
Identification
of
Information
Collection
1(
a)
Title:
"
National
Recycling
and
Emissions
Reduction
Program"

ICR
Number:
1626.07
OMB
Number:
2060­
0256
1(
b)
Short
Characterization/
Abstract
The
Environmental
Protection
Agency
(
EPA)
has
developed
regulations
under
the
Clean
Air
Act
Amendments
of
1990
(
Act)
establishing
standards
and
requirements
regarding
the
use
and
disposal
of
class
I
and
class
II
refrigerants
during
the
service,
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.

Regulations
implementing
the
above
provisions
were
published
in
58
FR
28660
and
are
codified
at
40
CFR
Subpart
F
(
§
82.150
et
seq.).
The
information
required
to
be
collected
under
the
Section
608
regulations
is
described
below.
This
information
was
approved
for
use
through
June
30,
1999
and
was
recently
extended
thru
December
1999.

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,
recycling
and
recovery
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
should
significantly
reduce
emissions
of
ozone
depleting
refrigerants,
and
therefore
aid
U.
S.
and
global
efforts
to
minimize
damage
to
the
ozone
layer
and
the
environment
as
a
whole.
­
2
­
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
and
wholesalers
of
refrigerants
must
maintain
proof
of
technician
certification;
approved
equipment
testing
organizations
must
maintain
records
of
equipment
testing
and
performance
and
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
testing
schedules;
approved
equipment
testing
organizations
must
submit
an
annual
list
of
equipment
that
meets
EPA
standards
and
must
notify
EPA
whenever
a
model
of
equipment
fails
a
recertification
test;
refrigerant
reclaimers
must
submit
annual
reports
noting
the
mass
of
refrigerant
reclaimed
and
the
mass
of
waste
products
produced;
and
owners
of
industrial
process
refrigeration
equipment
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.

EPA
has
estimated
that
there
are
2,342,047
annual
respondents
consisting
of
representatives
from
the
air­
conditioning
and
refrigeration
community.
The
annual
cost
of
collection
and
maintenance
of
records
for
the
respondents
is
estimated
to
total
$
20,977,300.
­
3
­
Section
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,
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
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
Office
of
Management
and
Budget
(
OMB)
approved
Information
Collection
Request
(
ICR)
Number
1626.05.
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
June
30,
1999
and
was
recently
extended
thru
December
1999.

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
are
made
directly
to
EPA's
Office
of
Air
and
Radiation.

Section
3:
Non­
duplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Non­
duplication
The
specific
information
requested
by
this
notice
is
not
currently
collected
by
EPA
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.
­
4
­
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
The
announcement
of
a
public
comment
period
for
the
renewal
of
ICR
Number
1626.07,
OMB
Number
2060­
0256,
"
National
Recycling
and
Emissions
Reduction
Program"
was
published
in
the
Federal
Register
Volume
64,
Number
98
published
on
May
21,
1999.
The
announcement
stated
EPA's
intention
to
submit
the
continuing
ICR
to
OMB,
and
that
public
comments
on
the
previous
burden
estimates
and
any
proposed
changes
were
being
sought
by
EPA.
There
were
no
written
comments
received
concerning
the
renewal
of
ICR
1626.07.

3(
c)
Consultations
In
developing
the
regulations
(
40
CFR
82,
Subpart
F)
under
the
Act
that
led
to
the
Ozone
Refrigerant
Recycling;
Final
Rule
(
FR28660,
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
all
met
at
least
twice
and
discussed
all
aspects
of
the
proposed
regulations
for
Section
608
of
the
Act.
The
names
and
contact
information
for
members
of
the
STOPAC
are
provided
in
the
Appendix
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
the
Appendix
to
this
Supporting
Statement.

EPA
also
received
comments
regarding
the
record
keeping
and
reporting
requirements
during
the
public
comment
period.
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
record
keeping
and
reporting
provisions
in
the
final
rule.
Most
commenters
agreed
with
the
negotiating
group.
Two
commenters
disagreed.
All
comments
are
maintained
in
the
Air
Docket
Number
A­
92­
01
and
are
physically
located
at
U.
S.
EPA;
401
M
Street,
SW;
Washington,
DC
20460;
Room
M­
1500
ground
floor
of
the
Waterside
Mall
complex.

EPA
also
had
several
meetings
with
Ted
Koss
,
of
the
U.
S.
Department
of
Energy's
Office
of
Environmental
Guidance
(
202­
586­
7964),
to
discuss
the
unique
problems
that
the
Agency
experienced
with
meeting
leak
repair
deadlines
for
commercial
and
comfort­
cooling
equipment.
­
5
­
The
ongoing
effort
of
requiring
technician
certification
and
record
keeping
of
their
credentials
was
supported
with
meetings
between
EPA
and
members
of
technician
certifying
programs.
The
meetings
were
held
to
update
the
set
of
Test
Bank
questions
used
for
technician
certification,
and
also
served
as
a
forum
for
discussion
of
technician
certification
issues.
Stakeholder
meetings
between
EPA
and
refrigeration
service
contractors,
refrigerant
wholesalers,
and
refrigeration
reclaimers
have
taken
place
since
the
last
OMB
approval
for
this
collection.
A
listing
of
meeting
attendees
is
included
in
the
Appendix.

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
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);
and
°
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
are
detailed
below.
Collecting
this
information
less
than
annually
would
hinder
EPA
enforcement
efforts.

°
Testing
organization
notification
of
all
previously
certified
recovery
devices;
and
°
Reclaimer
reports
on
the
quantities
of
used
refrigerant
received
and
processed.

Approved
technician
certification
organizations
must
submit
to
EPA
an
activity
report
every
six
months
that
includes
the
pass/
fail
rate
and
testing
schedules.
­
6
­
3(
e)
General
Guidelines
Section
608(
a)(
3)
of
the
Act
requires
maximization
of
the
recapture
and
recycling
of
class
I
and
class
II
refrigerants.
Enforcement
of
these
provisions
of
the
Act
is
insured
by
requiring
annual
reports
of
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.
Approved
equipment
testing
organizations
shall
submit
a
list
of
all
certified
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
refrigerants
as
mandated
by
Section
608(
a)(
3)(
B)
of
the
Act,
EPA
has
established
a
30­
day
reporting
deadline
for
approved
equipment
testing
organizations
when
a
new
model
line
of
recycling/
recovery
equipment
has
been
certified
or
when
retests
of
equipment
show
that
a
previously
certified
model
line
fails
to
meet
EPA
requirements.
A
deadline
of
greater
than
30
days
might
allow
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.

Owners
or
operators
of
commercial
refrigeration
equipment
normally
containing
more
than
50
pounds
of
refrigerant
must
have
leaks
repaired
in
accordance
with
40
CFR
82.156(
i)(
9),
if
the
appliance
is
leaking
at
a
rate
such
that
the
loss
of
refrigerant
will
exceed
35
percent
of
the
total
charge
during
a
12­
month
period.
Repairs
must
bring
the
annual
leak
rate
to
below
35
percent.

In
order
to
reduce
the
emissions
of
class
I
and
class
II
refrigerants
to
the
lowest
achievable
amount,
EPA
is
requesting
continued
collection
of
information
concerning
the
following
leak
repair
reporting
requirements:

°
For
instances
where
the
owners
or
operators
apply
to
EPA
for
an
extension
to
the
leak
repair
time
frames
or
if
their
repair
efforts
do
not
pass
follow­
up
verification
tests,
the
owner
must
keep
on­
site
documentation
and
report
to
EPA
within
30­
days
of
a
failed
follow­
up
verification
test.

°
Upon
a
failed
follow­
up
verification
test,
the
owner
or
operator
is
also
required
to
develop
a
retrofit/
retirement
plan
within
30­
days
after
the
failed
verification
test.
The
plan
is
maintained
onsite,
and
the
original
plan
must
be
readily
available
to
EPA
upon
request.
­
7
­
°
If
after
submission
of
the
retrofit/
retirement
plan
the
owner
believes
that
they
will
be
released
from
the
requirement
to
retrofit/
retire
because
the
leak
rate
will
be
below
the
35%
trigger
rate,
then
the
owner
has
30­
days
from
the
date
of
the
failed
follow­
up
verification
test
to
submit
a
plan
to
EPA
stating
a
plan
to
repair
other
outstanding
leaks
for
which
repairs
may
be
planned
but
not
yet
completed
to
achieve
an
acceptable
leak
rate.

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

3(
f)
Confidentiality
This
section
does
not
apply
because
the
rule
and
this
ICR
do
not
request
information
of
a
confidential
nature.

3(
g)
Sensitive
Questions
This
section
does
not
apply
because
the
rule
and
this
ICR
do
not
request
information
of
a
sensitive
nature.

Section
4:
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
Following
is
a
list
of
SIC
codes
associated
with
the
respondents
affected
by
the
manifest
information
requirements
covered
under
this
ICR:

7623
Refrigeration
and
Air­
conditioning
Service
and
Repair
Shops
1711
Plumbing,
Heating,
and
Air­
conditioning
Contractors
5012
Automobile
and
Other
Motor
Vehicles
including
refrigerated
transport
service
dealers
5093
Scrap
and
Waste
Materials
and
Used
Motor
Vehicle
Parts
Dealers
5015
Automobile
Dismantlers
­
8
­
4(
b)
Information
Requested
(
1)
Data
items,
including
record
keeping
requirements
(
i)
Record
Keeping
All
records
pursuant
to
this
ICR
must
be
kept
onsite
at
the
respondents'
place
of
business
for
a
minimum
of
three
years,
unless
stated
otherwise.
Records
are
required
in
accordance
with
40
CFR
§
82.166
unless
stated
otherwise.
Reports
are
submitted
from
the
respondents
to
EPA
headquarters
in
a
written
or
electronic
media
format.

°
Certified
technicians
must
maintain
a
copy
of
their
certification.

°
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).

°
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).

°
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.

°
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.

°
Purchasers
of
any
class
I
or
class
II
refrigerants
who
employ
certified
technicians
must
provide
written
proof
of
the
certification
to
the
wholesaler
who
sells
them
refrigerant.

°
Approved
equipment
testing
organizations
must
maintain
records
of
equipment
testing
and
performance
and
a
list
of
equipment
that
meets
EPA
requirements.

°
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.

°
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.
­
9
­
°
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.

°
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.

°
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.

°
The
owners/
operators
of
appliances
containing
50
or
more
pounds
of
refrigerant
must
keep
records
of
refrigerant
purchased
and
added
to
such
appliances
in
cases
where
owners
add
their
own
refrigerant.

(
ii)
Reporting
°
Approved
equipment
testing
organizations
shall
submit
a
list
of
all
certified
equipment
to
EPA
within
30
days
of
the
organization's
approval
by
EPA
and
annually
at
the
end
of
each
calendar
year
thereafter.

°
Approved
equipment
testing
organizations
shall
submit
to
EPA
within
30
days
of
the
certification
of
a
new
model
line
of
recycling
or
recovery
equipment
the
name
of
the
manufacturer
and
the
name
and/
or
serial
number
of
the
model
line.

°
Approved
equipment
testing
organizations
shall
notify
EPA
if
retests
of
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.

°
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.

°
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).

°
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.
­
10
­
(
ii)
Respondent
Activities
Equipment
Certification
­
Independent
laboratory
testing
of
recycling
and
recovery
equipment
is
required
to
ensure
that
the
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
equipment
certification
programs,
independent
laboratories
are
required
to
submit
an
application
to
EPA.

Applications
for
equipment
testing
approval
must
include
written
information
verifying
the
following:
(
l)
the
list
of
equipment
present
at
the
organization
that
will
be
used
for
testing
recycling
and
recovery
equipment;
(
2)
expertise
in
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
recycling
and
recovery
equipment
over
the
long
term.

The
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
equipment
must
notify
EPA
of
newly
certified
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
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)).
­
11
­
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
recycling
or
recovery
equipment
and
is
complying
with
the
requirements
of
the
rule;
(
2)
the
name
and
address
of
the
purchaser
of
the
equipment;
(
3)
the
number
of
trucks
operated
by
the
establishment;
(
4)
the
name
and
address
of
the
establishment
where
the
equipment
is
or
will
be
located;
and
(
5)
the
manufacturer's
name,
the
date
of
manufacture,
and
the
model
and
serial
number
of
the
equipment.
The
owner
of
the
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)).

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.

(
1)
identification
of
the
facility;
(
2)
the
leak
rate;
(
3)
the
method
used
to
determine
the
leak
rate
and
full
charge;
­
12
­
(
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
annual
leak
rate.
In
those
cases,
items
(
9)
and
(
10)
may
replace
items
(
7)
and
(
8).

The
dates
and
types
of
static
and
dynamic
tests
performed
and
test
results
for
all
static
and
dynamic
tests
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;
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.
­
13
­
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
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
dates
and
types
of
static
and
dynamic
tests
performed
and
test
results
for
all
static
and
dynamic
tests
must
be
maintained.

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;
­
14
­
(
11)
if
time
changes
for
original
estimates
result
in
moving
the
date
of
completion
forwar
d,
docum
entatio
n
of
the
reason
for
these
change
s;
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.

§
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.

§
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
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.

Section
5:
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
­
15
­
5(
a)
Agency
Activities
Agency
activities
associated
with
the
review
of
the
reports
and
record
keeping
requirements
for
the
National
Recycling
Program
consist
of
the
following:

°
Review
applications
from
independent
equipment
testing
labs
that
wish
to
certify
recycling
and
recovery
equipment.

°
Review
lists
of
certified
equipment
submitted
annually
by
testing
organizations.

°
Review
notices
of
new
equipment
certification
and
of
decertification
of
previously
certified
equipment.

°
Review
applications
for
service
establishment
certification.

°
Review
applications
for
disposer
certification.

°
Review
applications
for
reclaimer
certification.

°
Review
annual
reports
from
reclaimers
on
their
activities.

°
Review
applications
for
approval
to
conduct
technician
certification
programs.

°
Review
reports
submitted
by
approved
technician­
certification
programs.

°
Review
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
recycling
and
recovery
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
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
­
16
­
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
MVACs
when
they
are
disposed
of
are
not
required
to
be
certified
at
all
and
are
not
required
to
use
certified
recovery
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
The
following
records
are
required
by
EPA.
They
must
be
maintained
for
a
three­
year
period
in
case
of
a
periodic
inspection.

°
Organizations
operating
equipment
certification
programs
must
complete
a
onetime
application
for
approval
from
EPA.
The
approved
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
onetime
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.

°
Organizations
seeking
approval
to
conduct
technician
certification
programs
must
­
17
­
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.
­
18
­
Section
6:
Estimating
the
Burden
and
Cost
of
the
Collection
6(
a)
Estimating
the
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
capital
costs
associated
with
it.

6(
b)
Estimating
Respondent
Costs
EPA
estimates
the
average
annual
respondent
hourly
cost
(
labor
plus
overhead)
for
all
affected
entities
below.
In
deriving
these
costs,
EPA
used
past
cost
estimates
provided
in
direct
consultations
with
industries
likely
to
be
affected
by
the
requirements.
The
$
50.
00
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.

i.
Equipment
Testing
Organizations
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Costs
Submit
to
EPA
annual
list
of
all
equipment
previously
certified
1
$
50
Notify
EPA
of
certification
of
new
models
5
$
250
Maintain
records
of
equipment
tested
and
its
performance
0
$
0
Notify
EPA
of
equipment
failing
retests
or
inspections
2
$
100
Subtotal
8
$
400
­
19
­
Two
equipment
testing
and
certifying
organizations
approved
by
EPA
are
estimated
to
spend
one
hour
each
year
preparing
and
submitting
a
list
of
all
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
one
half
hour
reporting
burden.
Two
hours
per
year
are
estimated
to
be
spent
by
each
firm
informing
EPA
of
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
would
be
maintained
as
a
part
of
normal
business
practices.
The
$
50.
00
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
assumed
that
no
additional
equipment
testing
organizations
will
apply
to
become
approved
equipment
testing
organizations.

ii.
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
.
5
$
25.
00
Maintain
proof
of
employee
certification
.
25
$
12.
50
Subtotal
.
75
$
37.
50
The
estimated
burden
of
forty­
five
minutes
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.
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
onetime
requirements,
but
five
percent
of
45,000
establishments
(
2,250)
are
assumed
to
change
ownership
annually,
thus
necessitating
recertification.
The
$
50.00
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.
­
20
­
ii
Certification
by
Disposal
Establishments
that
Change
Ownership
or
Enter
the
Market
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Costs
Compile
information,
complete
certification
requirements
.
5
$
25.
00
Subtotal
.
5
$
25.
00
The
estimated
burden
of
one
half
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.
It
is
estimated
that
each
state
has
on
average
10
such
establishments.
Most
of
these
have
already
fulfilled
this
onetime
requirement,
but
five
percent
of
these
are
assumed
to
change
ownership
annually,
necessitating
recertification.
The
$
50.00
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
of
a
private
firm.

iv.
Maintenance
of
copies
of
signed
statements
by
disposal
establishments
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Cost
Maintain
copies
of
signed
statements
verifying
evacuation
of
refrigerant
20
$
1,000
Subtotal
20
$
1000
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
five
minutes
per
day
are
spent
completing
and
filing
the
statements.
The
$
50.00
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.
­
21
­
v.
Certification
by
Refrigerant
Reclaimers
that
Change
Ownership
or
Enter
the
Market
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Cost
Completing
certification
and
submitting
it
to
EPA
Headquarters
2
$
100
Subtotal
2
$
100
Reclaimers
must
complete
a
onetime
application
to
EPA
to
be
certified.
Based
on
EPA's
experience
over
the
past
three
years,
it
is
assumed
that
20
reclaimers
per
year
will
submit
applications.
The
$
50.00
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.

vi.
Reclaimer
Reporting
and
Record
Keeping
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Cost
Compiling
information
and
submitting
it
to
EPA
Headquarters
5
$
250
Maintain
usual
business
records
of
refrigerant
sales
transactions
0
0
Subtotal
5
$
250
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
$
50.00
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.
­
22
­
vii.
Refrigerant
Wholesalers
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Cost
Maintain
usual
business
records
of
refrigerant
sales
transactions
0
$
0
Maintain
records
of
technician
certification
8
$
400
Subtotal
8
$
400
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
$
50.00
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.

viii.
Technician
Certification
Programs
Applying
for
Approval
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Cost
Compiling
information
to
become
approved
and
submitting
it
to
EPA
Headquarters
30
$
1,500
Subtotal
30
$
1500
Based
on
EPA's
experience
over
the
past
three
years,
10
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.
The
$
50.00
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.
­
23
­
ix.
Record
keeping
by
Existing
Technician
Certification
Programs
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Cost
Maintain
records
of
certified
technicians,
individuals
taking
the
tests,
test
scores,
locations,
and
dates
of
tests
0
0
Submit
report
to
EPA
every
6
months
16
$
800
Subtotal
16
$
800
One­
hundred
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
$
50.00
per
hour
estimate
of
labor
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.

x.
Technicians
Acquiring
Certification
and
Maintaining
Certification
Cards
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Cost
Register
and
take
certification
test
3
$
150
Maintain
certification
card
.
02
$
1
Subtotal
3.
02
$
151
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.
­
24
­
xi.
Owners
of
Refrigeration
and
Air­
Conditioning
Equipment
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Cost
Keep
records
of
the
quantity
of
refrigerant
used
during
service
procedures
.
1
$
5
Develop
and
maintain
plan
to
retire,
replace,
or
retrofit
equipment
2
$
100
Subtotal
2.
1
$
105
The
estimated
burden
of
five
minutes
is
to
keep
records
of
the
quantity
of
refrigerant
used
during
service
procedures
on
refrigeration
or
air­
conditioning
equipment
containing
more
than
50
pounds
of
refrigerant.
This
includes
most
equipment
in
the
retail
food,
cold
storage,
chiller
and
industrial
process
refrigeration
end­
uses.
The
unit
of
measurement
is
the
number
of
service
jobs.
The
number
of
respondents
is
less
than
this
because
many
companies
or
individuals
order
more
than
one
service
job
per
year.

The
estimated
burden
of
two
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
$
50.00
per
hour
estimate
of
cost
is
the
average
hourly
administrative
labor
cost,
including
direct
labor
and
overhead,
for
a
private
firm.
­
25
­
xii.
Owners
of
Industrial
Process
Refrigeration
Equipment
Annual
Respondent
Burden
Collection
Activities
Burden
Hours
Annual
Costs
Prepare
requests
for
30­
day
extensions
5
$
250
Prepare
requests
for
retrofit
extensions
8
$
400
Maintain
information
on
purged
and
destroyed
refrigerant
4
$
200
Maintain
information
on
the
calculation
of
the
full
charge
using
a
range
4
$
200
Perform
and
document
results
of
static
and
dynamic
tests
4
$
200
Subtotal
25
$
1250
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
$
50.00.
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.
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.
We
have
estimated
that
approximately
60
entities
will
take
advantage
of
the
extensions
and
exclusion
each
year
over
a
five­
year
period,
30
requesting
an
extension
to
the
30­
day
repair
requirement
and
30
requesting
an
extension
to
the
one­
year
retrofit
requirement.

6(
c)
Estimating
Agency
Burden
and
Cost
Each
year,
ten
organizations
are
assumed
to
apply
for
approval
to
become
technician
certification
organizations.
EPA
is
assumed
to
spend
24
hours
reviewing
and
approving
each
application,
for
a
total
of
240
hours
per
year.
Twenty
refrigerant
reclaimers
are
assumed
to
apply
for
certification
annually;
EPA
is
assumed
to
spend
one
hour
reviewing
and
approving
each
certification
for
a
total
of
20
hours
per
year.
EPA
Regional
personnel
are
assumed
to
spend
15
minutes
reviewing
each
certification
from
2,250
service
establishments
and
25
disposal
establishments
per
year.
This
will
take
562
and
six
hours
respectively
per
year.
­
26
­
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
equipment
is
complete.
Each
evaluation
will
require
one
half
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
equipment
has
been
tested
and
certified,
spending
a
total
of
five
hours
per
year.
In
addition,
EPA
will
expend
15
minutes
reviewing
each
of
the
estimated
4
annual
notifications
by
each
of
the
two
organizations
that
previously
certified
equipment
has
failed
retests
or
inspections,
spending
a
total
of
two
hours
per
year.
EPA
will
spend
one
hour
each
reviewing
6­
month
statistical
reports
submitted
by
the
100
technician
testing
organizations,
for
a
total
of
200
hours
per
year.
In
addition,
EPA
will
spend
one
half
hour
reviewing
each
of
the
annual
reports
submitted
by
the
80
reclaimers,
for
a
total
of
40
hours
per
year.

EPA
estimates
one
half
hour
to
review
and
make
a
determination
on
each
request
for
an
extension
to
the
30­
day
repair
requirement
and
each
set
of
results
of
the
static
and
dynamic
tests.
EPA
estimates
an
hour
to
review
requests
for
extension
to
the
one­
year
retrofit
requirement.
Based
on
the
number
of
respondents
given
in
(
a)(
xii)
above,
EPA
expects
these
activities
to
consume
15,
30,
and
30
hours
respectively.
Agency
labor
costs
are
assumed
to
be
$
45
per
hour.
This
assumption
is
based
upon
the
average
salary
of
two
EPA
civil
servants
at
a
GS­
12
pay
scale.

Agency
Activity
EPA
Hours/
yr.
EPA
Costs/
yr.

Review
applications
from
organizations
seeking
approval
as
technician
certification
organizations
240
$
10,800
Review
certifications
from
refrigerant
reclaimers
20
$
900
Review
certifications
from
service
establishments
562.
5
$
25,313
Review
certifications
from
disposal
establishments
6.
25
$
281
Review
annual
lists
of
certified
equipment
for
completeness
1
$
45
Review
semiannual
reports
from
technician
certification
organizations
200
$
9,000
Review
notifications
of
new
equipment
certification
5
$
225
­
27
­
Review
notifications
of
equipment
failing
retests
2
$
90
Review
annual
reports
submitted
by
reclaimers
40
$
1,800
Review
Requests
and
Make
Determination
on
30­
Day
Extensions
15
$
675
Review
Requests
and
Make
Determination
on
Retrofit
Extensions
30
$
1,350
Review
Results
of
Static
and
Dynamic
Tests
30
$
1,350
Total
1,151.
75
$
51,829
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
EPA
has
used
past
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.
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
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.

i.
Equipment
Testing
Organizations
Total
Annual
Burden:
Hour
total
(
8)
x
Number
of
Respondents
(
2)
=
16
hours
Total
Annual
Costs:
Cost
total
($
400)
x
Number
of
Respondents
(
2)
=
$
800
ii.
Certification
by
Service
Establishments
that
Change
Ownership
or
Enter
the
Market
Total
Annual
Burden:
Hour
total
(.
75)
x
Number
of
Respondents
(
2,250)
=
1687.
5
hours
Total
Annual
Costs:
­
28
­
Cost
total
($
37.
50)
x
Number
of
Respondents
(
2,250)
=
$
84,375
iii.
Certification
by
Disposal
Establishments
that
Change
Ownership
or
Enter
the
Market
Total
Annual
Burden:
Hour
total
(.
5)
x
Number
of
Respondents
(
25)
=
12.
5
hours
Total
Annual
Cost:
Cost
total
($
25)
x
Number
of
Respondents
(
25)
=
$
625
iv.
Maintenance
of
copies
of
signed
statements
by
disposal
establishments
Total
Annual
Burden:
Hour
total
(
20)
x
Number
of
Respondents
(
500)
=
10,000
hours
Total
Annual
Cost:
Cost
total
($
1,000)
x
Number
of
Respondents
(
500)
=
$
500,000
v.
Certification
by
Refrigerant
Reclaimers
that
Change
Ownership
or
Enter
the
Market
Total
Annual
Burden:
Hour
Total
(
2)
x
Number
of
respondents
(
20)
=
40
hours
Total
Annual
Cost:
Cost
Total
($
100)
x
Number
of
respondents
(
20)
=
$
2,000
vi.
Reclaimer
Reporting
and
Record
Keeping
Total
Annual
Burden:
Hour
Total
(
5)
x
Number
of
respondents
(
80)
=
400
hours
Total
Annual
Cost:
Cost
Total
($
250)
x
Number
of
respondents
(
80)
=
$
20,000
vii.
Refrigerant
Wholesalers
Total
Annual
Burden:
Hour
total
(
8)
x
Number
of
respondents
(
5,000)
=
40,000
hours
Total
Annual
Cost:
Cost
total
($
400)
x
number
of
respondents
(
5,000)
=
$
2,000,000
viii.
Technician
Certification
Programs
Applying
for
Approval
Total
Annual
Burden:
­
29
­
Hour
Total
(
30)
x
Number
of
respondents
(
10)
=
300
hours
Total
Annual
Cost:
Cost
Total
($
1,500)
x
Number
of
respondents
(
10)
=
$
15,000
ix.
Record
keeping
by
Existing
Technician
Certification
Programs
Total
Annual
Burden:
Hour
Total
(
16)
x
Number
of
respondents
(
100)
=
1600
hours
Total
Annual
Cost:
Cost
Total
($
800)
x
Number
of
respondents
(
100)
=
$
80,000
x.
Technicians
Acquiring
Certification
and
Maintaining
Certification
Cards
Total
Annual
Burden:
Hour
Total
(
3)
x
Number
of
respondents
(
30,000)
=
90,000
hours
Hour
Total
(.
02)
x
Number
of
respondents
(
300,000)
=
6,000
hours
Total:
96,000
hours
Total
Annual
Cost:
Cost
Total
($
150)
x
Number
of
respondents
(
30,000)
=
$
4,500,000
Cost
Total
($
1)
x
Number
of
respondents
(
300,000)
=
$
300,000
Total:
$
4,800,000
xi.
Owners
of
Refrigeration
and
Air­
Conditioning
Equipment
Total
Annual
Burden:
Hour
Total
(.
1)
x
Number
of
respondents
(
1,968,000)
=
196,800
Hour
Total
(
2)
x
Number
of
respondents
(
35,850)
=
71,700
Total:
268,500
hours
Total
Annual
Cost:
Cost
Total
($
5)
x
Number
of
respondents
(
1,968,000)
=
$
9,840,000
Cost
Total
($
100)
x
Number
of
respondents
(
35,850)
=
$
3,585,000
Total:
$
13,425,000
xii.
Owners
of
Industrial
Process
Refrigeration
Equipment
Total
Annual
Burden
(
same
order
as
above):
Hour
total
(
5)
x
Number
of
respondents
(
30)
=
150
Hour
total
(
8)
x
Number
of
respondents
(
30)
=
240
Hour
total
(
4)
x
Number
of
respondents
(
60)
=
240
Hour
total
(
4)
x
Number
of
respondents
(
30)
=
120
Hour
total
(
4)
x
Number
of
respondents
(
60)
=
240
­
30
­
Total:
990
hours
Total
Annual
Cost
(
same
order
as
above):
Cost
total
(
250)
x
Number
of
respondents
(
30)
=
$
7,500
Cost
total
($
400)
x
Number
of
respondents
(
30)
=
$
12,000
Cost
total
($
200)
x
Number
of
respondents
(
60)
=
$
12,000
Cost
total
($
200)
x
Number
of
respondents
(
30)
=
$
6,000
Cost
total
($
200)
x
Number
of
respondents
(
60)
=
$
12,000
Total:
$
49,500
6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
1)
Respondent
Tally
Annual
Respondent
Burden
and
Cost
Activity
Number
of
Respondents
Number
of
Activities
Total
Hours
per
Year
Total
Labor
Costs
($)
per
Year
Equipment
Testing
Organizations
2
4
16
800
Certification
of
New
Service
Establishments
2,250
2
1,687.
5
84,375
Certification
of
New
Disposal
Establishments
25
1
12.
5
625
Maintenance
of
Statements
From
Disposal
Establishments
500
1
10,000
500,000
Certification
by
New
Refrigerant
Reclaimers
20
1
40
2,000
Reclaimer
Reporting
and
Record
Keeping
80
2
400
20,000
Refrigerant
Wholesalers
5,000
2
40,000
2,000,000
Technician
Certification
Programs
Applying
for
Approval
10
1
300
15,000
Record
Keeping
by
Existing
Technician
Certification
Programs
100
2
1,600
80,000
Annual
Respondent
Burden
and
Cost
Activity
Number
of
Respondents
Number
of
Activities
Total
Hours
per
Year
Total
Labor
Costs
($)
per
Year
­
31
­
Technicians
Acquiring
Certification
and
Maintaining
Certification
Cards
330,000
2
96,000
4,800,000
Owners
of
Refrigeration
and
Air­
conditioning
Equipment
2,003,850
2
268,500
13,425,000
Owners
of
Industrial
Process
Refrigeration
Equipment
210
5
990
49,500
TOTAL
2,342,047
25
419,546
$
20,977,30
0
(
2)
The
Agency
Tally
Annual
Agency
Burden
and
Cost
Activity
Number
of
Respondents
Number
of
Activities
Total
Hours
per
Year
Total
Labor
Costs
($)
per
Year
Review
applications
from
organizations
seeking
approval
as
technician
certification
organizations
10
1
240
10,800
Review
Certifications
From
Refrigerant
Reclaimers
20
1
20
900
Review
Certifications
From
Service
Establishments
2,250
1
562.
5
25,313
Review
Certifications
From
Disposal
Establishments
25
1
6.
25
281
Review
Annual
Lists
of
Certified
Equipment
2
1
1
45
Annual
Agency
Burden
and
Cost
Activity
Number
of
Respondents
Number
of
Activities
Total
Hours
per
Year
Total
Labor
Costs
($)
per
Year
­
32
­
Review
Semiannual
Reports
From
Technician
Certification
Organizations
100
2
200
9,000
Review
Notifications
of
New
Equipment
Certification
2
1
5
225
Review
Notifications
of
Equipment
Failing
Retests
2
1
2
90
Review
Annual
Reports
Submitted
by
Reclaimers
80
1
40
1,800
Review
Requests
and
Make
Determinations
on
30­
Day
Extensions
30
1
15
675
Review
Requests
and
Make
Determinations
on
Retrofit
Extensions
30
1
30
1,350
Review
Results
of
Static
and
Dynamic
Tests
60
1
30
1,350
TOTAL
2,611
13
1,151.
75
$
51,829
6(
f)
Reasons
for
Change
in
Burden
The
overall
reporting
and
record
keeping
burden
for
the
rule
has
not
changed
since
the
previous
ICR
Number
1626.05
was
developed.
This
is
because
there
have
been
no
modifications
to
the
record
keeping
or
reporting
requirements
of
40
CFR
82.166.
­
33
­
6(
g)
Burden
Statement
EPA
has
estimated
that
there
are
2,342,047
annual
respondents
consisting
of
representatives
from
the
air­
conditioning
and
refrigeration
community.
The
annual
cost
of
collection
and
maintenance
of
records
for
the
respondents
is
estimated
to
total
$
20,977,300.
The
average
annual
respondent
burden
and
the
record
keeping
burden
for
affected
entities
is
provided
in
detail
above.
These
estimates
include
time
for
gathering
information
and
developing
and
maintaining
records.

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.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
OPPE
Regulatory
Information
Division,
U.
S.
Environmental
Protection
Agency
(
2137),
401
M
Street,
S.
W.,
Washington,
DC
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
