1
OMB­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STRATOSPHERIC
OZONE
PROTECTION
A.
JUSTIFICATION
1.
Identification
of
the
Information
Collection
a)
Title:
Recordkeeping
and
Periodic
Reporting
of
the
Production
Import,
Export,
Recycling,
Destruction,
Transhipment
and
Feedstock
Use
of
Ozone­
Depleting
Substances.

OMB
Number:
2060­
0170
EPA
Number:
1432.21
b)
Short
Characterization:

With
this
ICR,
the
Office
of
Air
and
Radiation
(
OAR)
is
revising
the
previously
approved
information
collection
by
the
same
title
(
ICR
#
1432.18)
to
include
an
exemption
for
the
ozonedepleting
substance,
methyl
bromide,
specifically
for
use
in
quarantine
or
preshipment
applications.

2.
Need
For,
and
Use
Of,
the
Collection
a)
Authority
for
the
Collection
This
information
collection
is
authorized
under
section
603(
b)
of
the
Clean
Air
Act
Amendments
of
1990
(
CAAA).
Although
not
authorized
by
an
international
treaty,
this
information
collection
is
conducted
to
meet
U.
S.
obligations
under
Article
7,
Reporting
Requirements,
of
the
Montreal
Protocol
on
Substances
that
Deplete
the
Ozone
Layer
(
Protocol).

b)
Practical
Utility/
Users
of
the
Data
The
addition
of
these
reporting
requirements
to
those
already
established
is
designed
to:
1)
Ensure
compliance
with
the
restrictions
on
production,
import
and
export
of
class
I,
Group
VI
controlled
ozone­
depleting
substances
(
methyl
bromide);
2)
To
allow
exempted
production
and
import
for
quarantine
and
preshipment
applications
and
the
consequent
tracking
of
that
production
and
import;
3)
Satisfy
U.
S.
obligations
under
the
international
treaty,
the
Montreal
Protocol
on
Substances
that
Deplete
the
Ozone
Layer
(
Protocol),
to
report
data
under
Article
7;
2
4)
Fulfill
statutory
obligations
under
Section
603(
b)
and
(
c)
of
Title
VI
of
the
Clean
Air
Act
Amendments
of
1990
(
CAAA)
for
reporting
and
monitoring;
5)
Provide
information
to
report
to
Congress
on
the
production,
use
and
consumption
of
class
I
and
class
II
controlled
substances
as
statutorily
required
in
Section
603(
d)
of
Title
VI
of
the
CAAA.
This
action
revises
the
reporting
requirements
of
the
established
regulations
so
companies
may
produce
and
import
for
special
exempted
uses
of
methyl
bromide
for
quarantine
and
preshipment
applications
during
the
interim
period
when
production
and
consumption
is
capped
at
50%
of
the
1991
baseline
level.
In
order
to
monitor
each
company's
production,
import,
export,
destruction,
and
transformation,
the
reporting
system
continues
to
require
information
which
can
be
used
to
check
industry
compliance
with
the
stratospheric
ozone
protection
regulations.
Compliance
during
the
reduction
steps
for
methyl
bromide
mean
that
companies
can
produce
and
import
50%
of
1991
baseline
levels,
except
for
the
specific
exemption
created
by
this
action
for
quarantine
and
preshipment
applications.
The
information
required
satisfies
statutory
mandates
for
reporting
and
monitoring
under
section
603
of
Title
VI
of
CAAA
and
will
be
used
to
generate
reports
to
Congress
as
mandated
under
section
603(
d)
of
Title
VI.
To
ensure
that
the
quantities
produced
or
imported
under
the
quarantine
and
preshipment
exemption
are
used
solely
for
these
exempted
purposes,
this
action
creates
reporting
and
recordkeeping
requirements
in
addition
to
those
already
required
by
existing
regulations
and
collected
under
an
approved
Information
Collection
Request.
Information
is
collected
to
provide
reports
to
the
Secretariat
of
Protocol
to
meet
U.
S.
international
treaty
obligations.
Requirements
to
report
data
are
listed
in
Article
7
of
the
Protocol.
The
information
reported
to
EPA
is
entered
into
an
electronic
tracking
system
to
ensure
companies
do
not
exceed
the
exempted
production
and
import
limits
and
to
guarantee
the
U.
S.
does
not
violate
it
obligations
under
the
Protocol.
Thus,
the
information
is
used
for
compliance
monitoring
for
individual
companies
and
for
monitoring
U.
S.
compliance
with
obligations
under
the
Montreal
Protocol.

3.
Non­
Duplication,
Consultations,
and
Other
Collection
Criteria
a)
Non­
Duplication
The
amended
information
collection
required
by
this
notice
was
not
previously
collected
by
EPA.
The
collection
is
limited
to
a
unique
universe
and
specific
information
related
to
ozonedepleting
substances.
To
certify
the
specific
quarantine
or
preshipment
requirement,
EPA
is
accepting
forms
provided
directly
to
the
applicator
by
an
official
from
a
national
plant,
animal,
environmental
protection
or
health
authority
requesting
the
treatment
of
commodities
to
control
quarantine
pests,
such
as
the
phytosanitary
certificates
(
PPQ
Form
577,
PPQ
Form
578,
and
PPQ
Form
579)
issued
by
USDA/
APHIS
or
an
authorized
State
agency
b)
Public
Notice
Required
Prior
to
ICR
submissions
to
OMB
3
Since
this
is
a
rule­
related
ICR,
public
notice
soliciting
public
comments
on
the
ICR
and
estimates
of
burden
were
done
as
part
of
the
preamble.

c)
Consultations
EPA
held
two
large
meetings
with
stakeholders,
including
representatives
from
the
affected
industries,
at
the
initiation
of
the
process
of
developing
this
methyl
bromide
quarantine
and
preshipment
regulation.
The
industry
representatives
made
a
few
suggestions
for
reducing
information
collection
burden.
Based
on
an
analysis
of
the
industry
suggestions,
EPA
amended
a
few
of
the
reporting
requirements.

d)
Effects
of
Less
Frequent
Collection
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
Montreal
Protocol.
Companies
expressed
a
desire
to
continue
quarterly
reporting
to
ensure
accuracy
of
submitted
data
and
ease
the
overall
reporting
burden.
Several
companies
said
semi­
annual
or
annual
reporting
would
hinder
their
ability
to
monitor
their
own
compliance
with
regulatory
limits.
Companies
stated
that
internal
processes
to
collect
and
report
information
work
more
smoothly
on
a
quarterly
basis
than
on
a
less
frequent
basis.
Less
frequent
collection
of
data
would
compromise
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
daily
at
$
27,500
per
kilogram
per
day
which
necessitates
frequent
information
collection.
Violations
would
be
much
more
complex
to
pursue
and
enforce
if
the
information
was
submitted
less
frequently.
Less
frequent
reporting
would
potentially
put
the
United
States
in
a
non­
compliance
status
under
the
Montreal
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
begin
to
exceed
Protocol
limits
or
the
limits
set
in
Section
604
of
Title
VI
in
the
CAAA.

e)
General
Guidelines
None
of
these
reporting
or
recorrdkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.5.

f)
Confidentiality
and
Sensitive
Questions
4
EPA
informs
respondents
that
they
may
assert
claims
of
business
confidentiality
for
any
of
the
information
they
submit.
Information
claimed
confidential
will
be
treated
in
accordance
with
the
procedures
for
handling
information
claimed
as
confidential
under
40
CFR
Part
2,
Subpart
b,
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/
NAIC
Codes
Respondents
to
this
added
segment
of
the
information
collection
request
include
producers,
feedstock
users,
importers,
exporters,
and
destroyers
of
ozone­
depleting
substances
in
NAIC
Category
32532,
Pesticide
and
Other
Agricultural
Chemical
Manufacturing;
NAIC
Category
115,
Support
Activities
for
Agriculture
and
Forestry;
NAIC
Category
311,
Food
Manufacturing;
NAIC
Category
4225,
Farm
Product
Raw
Material
Wholesalers;
NAIC
Category
56171,
Exterminating
and
Pest
Control
Services;
NAIC
Category
4889,
Other
Support
Activities
for
Transportation
b)
Information
Requested
i)
Data
Items,
including
Recordkeeping
Requirements
Methyl
bromide
producers
and
importers
continue
to
report
quarterly
expenditure
of
production
and
consumption
allowances.
The
current
methyl
bromide
reporting
identifies
gross
quantities
produced
and
imported
and
then
subtracts
the
exempted
quantities
that
are
transformed
or
destroyed.
This
action
creates
an
additional
category
of
exempted
production
and
import
of
methyl
bromide
solely
for
use
in
quarantine
and
preshipment
applications.
The
additional
reporting
for
the
methyl
bromide
quarantine
and
preshipment
exemption
is:

Producers
Reporting:

!
production
of
methyl
bromide
solely
for
quarantine
or
preshipment
applications
Importers
Reporting
!
imports
of
methyl
bromide
solely
for
quarantine
or
preshipment
applications
Exporters
!
certification
to
producers/
importers
that
purchased
quantity
will
be
exported
solely
for
quarantine
or
preshipment
applications
!
quantity
exported
for
quarantine
or
preshipment
applications.
5
Distributors
!
certification
to
producers/
importers
that
purchased
quantity
will
be
solely
for
quarantine
or
preshipment
applications;

!
quantity
distributed
solely
for
quarantine
or
preshipment
applications
Applicators
!
certification
to
distributors
that
purchased
quantity
will
be
used
solely
for
quarantine
or
preshipment
applications
Commodity
Owners,
Shippers
or
their
Agents
!
documentation
that
the
use
of
methyl
bromide
is
to
meet
an
official
control
or
official
requirement.

Requirements
for
keeping
records
associated
with
the
reports
listed
above
are
for
three
years.
These
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
are
summarized
in
reports.
Recordkeeping
requirements
are
designed
to
aid
EPA
in
compliance
monitoring,
site
inspection
and
enforcement
actions.

(
ii)
Respondent
Activities
Since
1994,
the
producers,
importers
and
exporters
of
methyl
bromide
have
participated
in
the
accelerated
phaseout
program
for
ozone­
depleting
substances
submitted
reports
on
a
quarterly
basis.
This
change
in
information
collection
for
the
producers,
importers
and
exporters
will
require
the
designation
of
exempted
quantities
of
methyl
bromide
as
being
distinct
from
other
current
categories.
Distributors
of
methyl
bromide
will
need
to
review
the
reporting
and
recordkeeping
instructions
and
send
a
Quarantine
and
Preshipment
Certification
Form
to
any
person
who
places
an
order
for
a
quantity
of
methyl
bromide
that
is
explicitly
and
solely
for
quarantine
and
preshipment
applications
as
defined.
A
draft
copy
of
this
form
is
attached.
At
the
end
of
the
calendar
year,
distributors
will
compile
the
total
quantity
ordered
solely
for
quarantine
and
preshipment
applications
(
for
which
certifications
were
received)
and
transmit
this
summary
data
to
EPA.
Applicators
will
need
to
review
instructions
regarding
completion
of
the
Quarantine
and
Preshipment
Certification
Form,
but
once
understood
the
process
will
simply
involve
writing
down
the
quantity
of
methyl
bromide
being
ordered
and
signing
the
form
before
tranmitting
it
back
to
the
distributor.
For
quarantine
applications,
the
applicator
will
need
to
collect
documentation
citing
the
regulatory
requirement
that
justifies
the
use
of
the
exempted
methyl
bromide.
This
documentation
will
be
maintained
by
the
applicator
as
a
record.

5.
The
Information
Collected,
Agency
Activities,
Collection
Methodology,
and
Information
Management
a)
Agency
Activities
!
Refine
new
Post­
Phaseout
Tracking
System
to
incorporate
changes
to
post­
6
phaseout
regulatory
requirements;

!
Enter
and
store
information
submitted
from
companies
in
the
electronic
Post­
Phaseout
Tracking
System;

!
Review
information
and
conduct
compliance
monitoring
activities
related
to
restrictions
on
production,
import,
export,
transformation
and
destruction
of
ozone­
depleting
controlled
substances
for
individual
companies
comparing
data
with
information
from
U.
S.
Customs
for
imports
(
quarterly),
exports
to
Article
5
countries
(
quarterly),
and
with
information
from
the
International
Trade
Commission
for
production;

!
Inspect
records
maintained
by
producers,
importers,
exporters,
transformers,
and
destroyers
of
ozone­
depleting
substances;

!
Review
information
in
tracking
system
to
ensure
U.
S.
is
not
exceeding
obligations
under
the
Montreal
Protocol
limiting
production
and
imports;

!
Review
information
in
tracking
system
to
ensure
exempted
production
and
imports
do
not
exceed
limits
statutorily
set
in
Section
604
of
Title
VI
of
the
CAAA.

!
Compile
reports
mandated
by
U.
S.
obligations
under
the
Montreal
Protocol
and
Title
VI
of
the
Clean
Air
Act
Amendments
of
1990,
including
Reports
to
Congress.

b)
Collection
and
Methodology
and
Management
After
the
many
current
separate
rulemakings
pertaining
to
40
CFR
Part
82,
Subpart
A
are
published
as
final
rules,
the
Agency
will
revise
forms
distributed
to
companies
in
a
newly
revised
Guidance
Document.
A
copy
of
the
current
Guidance
Document
for
Stratospheric
Ozone
Protection
Program
after
January
1,
1996
is
attached.
The
forms
are
also
being
prepared
as
"
pdf"
file
for
easy
access
on
the
web.
Procedures
for
allowing
direct
electronic
input
of
data
in
"
pdf"
versions
of
the
forms
are
being
investigated.
Allowing
for
direct
electronic
input
of
data
into
a
form
may
permit
companies
to
save
a
form
electronically
 
with
a
unique
name
according
to
a
recommended
file­
naming
protocol
 
and
may
possibly
permit
the
submission
of
the
form
by
e­
mail
(
if
confidentiality
concerns
can
be
met).
Although
the
use
of
the
forms
is
voluntary,
they
are
generally
used
by
every
participant
in
the
regulatory
program.
In
the
past,
the
forms
greatly
facilitated
and
eased
submission
of
data
for
respondents.
The
reporting
requirements,
first
promulgated
in
the
July
30,
1992
final
rule,
were
significantly
simplified
through
amendments
published
in
the
Federal
Register
on
May
10,
1995,
and
the
administrative
and
reporting
burden
were
greatly
reduced
and
eased.
An
electronic
version
of
the
Post­
Phaseout
Tracking
System
is
available
for
distribution
to
companies
to
allow
electronic
reporting
by
diskette.
The
system
is
operated
using
a
Microsoft
Access
97
format.
The
diskette
sent
to
companies
will
contain
a
stand­
alone
executable
file
of
7
Microsoft
Access
so
they
may
operate
the
reporting
system
without
needing
the
specific
software.

c)
Small
Entity
Flexibility
The
information
required
is
collected
for
U.
S.
reporting
obligations
under
Article
7
of
the
Montreal
Protocol.
EPA
believes
the
information
collection
is
required
to
ensure
allowance
holders
have
intended
access
to
their
allowances
and
to
allow
production
and
import
of
exempted
quantities
of
methyl
bromide.
The
information
collection
is
also
required
to
produce
nationally
mandated
reports
under
Section
603
of
the
CAA
and
internationally
mandated
reports
under
Article
7
of
the
Montreal
Protocol,
and
to
ensure
compliance
with
sections
604
and
606
of
the
Clean
Air
Act
Amendments
of
1990.
The
burden
on
all
affected
entities,
and
especially
the
burden
on
small
entities,
has
been
reduced
to
every
extent
possible.
Distributors,
possibly
the
only
small
entities
required
to
submit
information
to
EPA,
are
required
to
certify
purchases
of
exempted
class
I,
Group
VI
methyl
bromide
one
time
per
year,
indicating
that
it
will
be
sold
only
to
a
person
who
certifies
it
will
be
solely
be
used
for
quarantine
and
preshipment
applications.
This
requirement
is
to
ensure
proper
use
of
exempted
production
and
import
and
allow
the
U.
S.
to
report
specific
information
to
the
Montreal
Protocol
regarding
the
use
of
ozone­
depleting
substances
for
quarantine
and
preshipment
applications
as
required
under
Decision
IX/
28.
All
the
producers
and
importers
of
methyl
bromide
are
large
companies.

d)
Collection
Schedule
For
2001
and
2002
calendar
years
(
control
periods):

!
Producers,
importers
and
exporters
will
report
quarterly,
with
reports
due
45
days
after
the
end
of
each
quarter.

!
Distributors
will
report
annually.

!
Applicators
submit
a
certification
to
distributors
for
each
shipment
of
methyl
bromide
solely
for
quarantine
and
preshipment
applications
!
Commodity
owners,
shippers
or
their
agents
submit
a
document
to
the
applicators
for
each
request
that
a
commodity
be
fumigated
with
methyl
bromide
to
meet
a
specified
official
quarantine
control
or
official
preshipment
requirement.
Some
companies
expressed
a
desire
to
report
quarterly
rather
than
annually
in
order
to
ease
their
overall
burden
and
increase
the
accuracy
of
their
submissions.
Companies
claimed
that
quarterly
submissions
allow
more
accurate
self­
monitoring
for
maintaining
compliance
with
the
regulations.
Companies
claim
that
smaller
quarterly
reports
are
easier
to
compile
than
larger
semi­
annual
or
annual
reports.

6)
Estimating
the
Burden
and
Cost
of
Collection
a)
Estimating
the
Burden
and
b)
Estimating
the
Respondent
Cost
The
basis
of
the
analysis,
unchanged
from
the
previously
approved
ICR
relating
to
ODS
8
reporting
requirements,
is
identification
of
the
principal
steps
involved
in
complying
with
EPA
reporting
requirements
and
the
estimated
costs
associated
with
each
step.
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
assigned
an
average
value
of
$
83.00.
This
value
represents
an
average
hourly
labor
rate
plus
overhead
for
a
private
firm
and
is
based
on
anecdotal
information
gleaned
through
the
operation
of
the
allowance
tracking
system
during
the
10
past
years.
The
number
of
occurrences
of
each
of
the
activities
is
based
on
quarterly
reporting
requirements,
or
less
frequent
reporting,
as
well
as
EPA
experience
with
the
allowance
tracking
system.

c)
Estimating
Agency
Burden
and
Cost
The
basis
of
this
analysis,
also
unchanged
from
previous
submissions,
is
the
identification
of
the
steps
involved
in
modifying
the
existing
tracking
system,
and
the
identification
of
the
steps
involved
in
the
operation
of
this
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.
Based
on
the
FY2001
GS
pay
schedule,
EPA
estimates
an
average
hourly
labor
cost
of
Grade
14,
Step
5
at
$
40.56
for
managerial
staff,
Grade
12,
Step
5
at
$
28.87
for
technical
staff,
and
Grade
9,
Step
5
at
$
19.90
for
clerical
staff.
These
hourly
basic
rates
are
from
the
Office
of
Personnel
Management
website.
EPA
then
multiplied
hourly
rates
by
the
standard
government
benefits
multiplication
factor
of
1.6.
The
cost
of
contractor
time
and
overhead
is
valued
at
$
75.00
per
hour
and
a
6
percent
contract
fee
is
included.
The
number
of
occurrences
of
each
activity
is
based
on
quarterly
reporting
requirements
as
well
as
EPA
experience
with
the
allowance
tracking
system.

d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost
EPA
estimated
the
respondent
universe
by
taking
the
number
of
respondents
identified
in
the
previous
reporting
requirement
ICR
and
adding
those
respondents
effected
by
this
additional
requirement,
specifically,
those
producers,
importers,
exporters,
distributors,
applicators
and
commodity
owners,
shippers
and
their
agents
of
methyl
bromide
involved
in
the
use
of
the
chemical
for
quarantine
or
preshipment
applications.
Estimation
of
total
burden
and
cost
is
described
above
in
Sections
6
a
and
b.

e)
Bottom
Line
Burden
Hours
and
Cost
Tables
EPA
intends
to
revise
the
current
Guidance
Document
for
the
Stratospheric
Ozone
Protection
Program
After
January
1,
1996
to
reflect
the
changes
in
this
information
collection.
EPA's
development
and
dissemination
of
the
Guidance
Document
for
the
Stratospheric
Ozone
Protection
Program
After
January
1,
1996,
is
designed
to
inform
all
entities
potentially
subject
to
the
reporting
and
recordkeeping
requirements
of
the
amended
accelerated
phaseout
regulation.
The
Guidance
Document
explains
the
reasons
the
information
is
collected
and
the
ways
in
which
the
information
is
used
by
the
Agency.
In
addition,
the
Guidance
Document
cites
the
applicable
9
part
of
section
82.13
on
reporting
and
recordkeeping
requirements
for
each
type
of
respondent
published
in
the
Federal
Register.
The
preamble
to
the
regulation
and
the
Guidance
Document
both
cite
the
authority
under
which
respondents
may
claim
information
to
be
confidential.
The
Guidance
Document,
the
forms
and
the
final
industry
version
of
the
electronic
reporting
diskette
will
be
amended
to
include
a
clear
burden
statement.
All
forms
currently
cite
the
OMB
Control
Number
and
will
be
amended
to
include
the
expiration
date
once
approved.
The
reporting
burden
for
the
reporting
of
methyl
bromide
quarantine
and
preshipment
uses
is
estimated
for
one
calendar
year
in
the
following
table
and
added
to
the
burden
previously
approved
for
the
EPA
reporting
requirements.
The
estimate
includes
the
time
needed
to
comply
with
EPA's
reporting
requirements,
as
well
as
that
used
for
the
completion
of
the
reports
under
the
amended
regulations
for
a
calendar
year.

TABLE
I
­
RESPONDENT
BURDEN
HOURS
PER
YEAR
COLLECTION
ACTIVITY
No.
of
Respondents
Responses/
Respondent
Total
Responses
Hours
per
Response
Total
Hours
Producers
&
Importers
Report
4
4
16
1
16
Exporters
Report
2
4
8
8
64
Applicator
Certification
15
6
90
0.5
45
Distributor
Report
15
1
15
16
240
Commodity
Owner,
Shipper
or
Agent
Recordkeeping
500
10
500
1
500
Previously
Approved
ODS
Reporting
Requirements
1081
25
1213
283
6492
TOTAL
BURDEN
HRS
1617
50
1842
309.5
7357
The
methyl
bromide
quarantine
and
preshipment
interim
final
rule
requires
respondents
to
submit
reports
to
the
Agency
and
maintain
records.
Operating
and
maintenance
(
O&
M)
costs
include
file
storage,
photocopying,
and
postage.
Operating
and
maintenance
costs
also
include
the
general
upkeep
of
start­
up
capital
equipment,
as
well
as
any
purchase
of
services
such
as
contractor
or
auditing
services.
The
O&
M
costs
are
estimated
at
$
141.87
for
the
methyl
bromide
quarantine
and
preshipment
rule
bringing
the
total
O&
M
costs
when
combined
with
the
previously
approved
reporting
requirements
to
$
3,173.87.
No
additional
cost
will
be
added
as
a
result
of
this
renewal.

TABLE
II
­
AGENCY
BURDEN
HOURS
10
Hours
per
Response
Managerial
$
40.56/
Hour
Technical
$
28.87/
Hour
Agency
Hours/
Year
Agency
Costs/
Year
Enter
and
store
information
in
Tracking
System
0.00
0.5
0.50
$
14
Respond
to
companies
submitting
information
0.10
0.5
0.60
$
18
Conduct
compliance
monitoring
review
of
information
0.25
0.25
0.50
$
17
Inspect
records
at
plants
0.10
0.25
0.35
$
11
Previously
Approved
ODS
Reporting
Requirements
1,759.00
$
81,145
TOTAL
1,761
$
81,207
Summary
Bottom
Line
Burden
Hours
and
Costs
(
associated
with
the
addition
of
this
action
to
the
previously
approved
reporting
requirements
of
ICR
#
1432.18
):
a)
Respondent's
annual
burden
hours
7,357
b)
Respondent's
annual
labor
costs
$
610,631
c)
Respondent's
capital/
start­
up
costs
$
43
d)
Respondent's
O
&
M
costs
$
3,173.87
e)
Agency's
annual
burden
hours
1,761
f)
Agency's
annual
labor
costs
$
81,207
f)
Reason
for
Change
in
Burden
The
changes
are
to
meet
reporting
requirements
under
Section
603
of
the
Clean
Air
Act
and
fulfill
the
reporting
obligations
of
the
United
States
under
Article
7
of
the
Montreal
Protocol
on
Substances
that
Deplete
the
Ozone
Layer.
The
changes
are
also
to
monitor
and
track
quantities
of
exempted
methyl
bromide
to
ensure
that
these
exempted
quantities
are,
in
fact,
solely
used
for
quarantine
or
preshipment
applications
in
accordance
with
the
restrictions
under
the
CAA
and
Protocol.
The
changes
made
are
those
associated
with
the
addition
of
the
methyl
bromide
quarantine
and
preshipment
reporting
requirements,
there
are
no
additional
changes
made
to
the
overall
reporting
burden
as
a
result
of
this
renewal.

g)
Burden
Statement
Table
I
presents
the
average
annual
respondent
burden
for
companies
affected
by
this
rule
exempting
methyl
bromide
for
quarantine
and
preshipment
applications.
The
reporting
burden
is
estimated
to
be
an
average
of
1.38
hours
per
respondent
per
year.
This
estimate
includes
time
for
preparing
and
submitting
reports
and
adjusts
the
calculation
for
duplicate
respondents
who
submit
11
several
reports
in
a
year.
The
recordkeeping
burden
for
companies
affected
by
the
accelerated
phaseout
regulations
for
ozone­
depleting
substances
is
estimated
to
average
4.56
hours
per
respondent
per
year.
This
estimate
includes
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
Ms
Susan
Auby,
Collection
Strategies
Division
(
Mail
Code
2822),
Office
of
Environmental
Information,
United
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
NW,
Washington,
DC
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs
,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1432.21
and
OMB
Control
Number
2060­
0170
in
any
correspondence.
12
APPENDIX
I
Collection
Activity
CFR
Citation
for
Recordkeeping
and
Reporting
Producer's
Report
82.13(
f)

Importer's
Report
82.13(
g)(
q)(
r)

Notification
of
Trade
82.9(
c),
82.12
Export
Report
82.13(
h)

Lab
Certification
82.13(
y)

Class
II
Report
82.13(
o)

Transformation
&
Destruction
82.13(
i)(
j)(
k)(
l)(
m)

Essential
Use
Allowance
Holders
82.13(
u)

Lab
Suppliers
82.13(
v)(
w)(
x)

Lab
Suppliers
­
Reference
Standards
82.13(
z)
