 ADVANCE \d6 

RESPONSIBLE APPLIANCE DISPOSAL PROGRAM

	TABLE OF CONTENTS

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc159662713"  1. 
IDENTIFICATION OF THE INFORMATION COLLECTION	  PAGEREF _Toc159662713 \h 
1  

  HYPERLINK \l "_Toc159662714"  1(a)	Title of the Information Collection
  PAGEREF _Toc159662714 \h  1  

  HYPERLINK \l "_Toc159662715"  1(b)	Short Characterization	  PAGEREF
_Toc159662715 \h  1  

  HYPERLINK \l "_Toc159662716"  2.	NEED FOR AND USE OF THE INFORMATION
COLLECTION	  PAGEREF _Toc159662716 \h  2  

  HYPERLINK \l "_Toc159662717"  2(a)	Need and Authority for the
Collection	  PAGEREF _Toc159662717 \h  2  

  HYPERLINK \l "_Toc159662718"  2(b)	Practical Utility and Users of the
Data	  PAGEREF _Toc159662718 \h  2  

  HYPERLINK \l "_Toc159662719"  3.	NONDUPLICATION, CONSULTATIONS, AND
OTHER COLLECTION CRITERIA	  PAGEREF _Toc159662719 \h  2  

  HYPERLINK \l "_Toc159662720"  3(a)	Nonduplication	  PAGEREF
_Toc159662720 \h  2  

  HYPERLINK \l "_Toc159662721"  3(b)	Public Notice Request Prior to ICR
Submission to OMB	  PAGEREF _Toc159662721 \h  3  

  HYPERLINK \l "_Toc159662722"  3(c)	Consultations	  PAGEREF
_Toc159662722 \h  3  

  HYPERLINK \l "_Toc159662723"  3(d)	Effects of Less Frequent Collection
  PAGEREF _Toc159662723 \h  3  

  HYPERLINK \l "_Toc159662724"  3(e)	General Guidelines	  PAGEREF
_Toc159662724 \h  3  

  HYPERLINK \l "_Toc159662725"  3(f)	Confidentiality	  PAGEREF
_Toc159662725 \h  3  

  HYPERLINK \l "_Toc159662726"  3(g)	Sensitive Questions	  PAGEREF
_Toc159662726 \h  3  

  HYPERLINK \l "_Toc159662727"  4.	THE RESPONDENTS AND THE INFORMATION
REQUESTED	  PAGEREF _Toc159662727 \h  4  

  HYPERLINK \l "_Toc159662728"  4(a)	Respondents/SIC and NAICS Codes	 
PAGEREF _Toc159662728 \h  4  

  HYPERLINK \l "_Toc159662729"  4(b)	Information Requested	  PAGEREF
_Toc159662729 \h  4  

  HYPERLINK \l "_Toc159662730"  5. 	THE INFORMATION COLLECTED: AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	  PAGEREF
_Toc159662730 \h  5  

  HYPERLINK \l "_Toc159662731"  5(a)	Agency Activities	  PAGEREF
_Toc159662731 \h  5  

  HYPERLINK \l "_Toc159662732"  5(b)	Collection Methodology and
Management	  PAGEREF _Toc159662732 \h  6  

  HYPERLINK \l "_Toc159662733"  5(c)	Small Entity Flexibility	  PAGEREF
_Toc159662733 \h  6  

  HYPERLINK \l "_Toc159662734"  5(d)	Collection Schedule	  PAGEREF
_Toc159662734 \h  6  

  HYPERLINK \l "_Toc159662735"  6.	ESTIMATING THE BURDEN AND COST OF THE
COLLECTION	  PAGEREF _Toc159662735 \h  7  

  HYPERLINK \l "_Toc159662736"  6(a)	Estimating Respondent Burden	 
PAGEREF _Toc159662736 \h  7  

  HYPERLINK \l "_Toc159662737"  6(b)	Estimating Respondent Costs	 
PAGEREF _Toc159662737 \h  9  

  HYPERLINK \l "_Toc159662738"  6(c)	Estimating Agency Burden and Cost	 
PAGEREF _Toc159662738 \h  9  

  HYPERLINK \l "_Toc159662739"  6(d) 	Estimating the Respondent Universe
and Total Respondent Burden and Costs	  PAGEREF _Toc159662739 \h  11  

  HYPERLINK \l "_Toc159662740"  6(e)	Bottom Line Burden Hours and Costs	
 PAGEREF _Toc159662740 \h  12  

  HYPERLINK \l "_Toc159662741"  6(f)	Reasons for Change in Burden	 
PAGEREF _Toc159662741 \h  12  

  HYPERLINK \l "_Toc159662742"  6(g)	Burden Statement	  PAGEREF
_Toc159662742 \h  12  

 

1. 	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title of the Information Collection

This ICR is entitled "Reporting Responsible Appliance Disposal Program,"
EPA ICR number 2254.01.

1(b)	Short Characterization

The 1987 international treaty, the Montreal Protocol on Substances that
Deplete the Ozone Layer (Protocol), established limits on total U.S.
production, import, and export of class I and class II controlled ozone
depleting substances (ODS) in an effort to ultimately eliminate ODS
emissions.  The 1990 U.S. Clean Air Act Amendments followed, setting
limits for the U.S. on production and consumption of controlled
substances and guidelines for their treatment that EPA must adhere to
and enforce.  Refrigerants, such as those used in old refrigerated
household appliances, are ODS and are regulated under Section 608 of the
1990 Clean Air Act Amendments (40 CFR Part 82 Subpart F).

In addition to ODS refrigerant, refrigerated household appliances may
also contain a variety of other substances that may be harmful to the
environment if not properly treated at equipment end of life.  These
include ODS foam blowing agents, used oil, PCBs, and/or mercury.  With
regards to the handling of household appliances at end-of-life, Federal
law requires that: (1) all refrigerant be recovered prior to dismantling
or disposal (40 CFR Part 82 Subpart F); and (2) universal waste (e.g.,
mercury), used oil, and PCBs be properly managed and stored (40 CFR
Parts 273, 279, 761).  State laws may have additional requirements. For
example, some States require that certain durable appliance materials be
recycled. At this time, no Federal or State laws require that ODS foam
blowing agent contained in appliances be removed and destroyed. 
However, like refrigerants, ODS foam blowing agents are harmful to the
ozone layer when not properly recovered and destroyed/reclaimed.  ODS
foam blowing agents and refrigerants also have high global warming
potentials (GWPs); therefore, preventing their release to the
environment helps combat global climate change as well as the thinning
of the ozone layer.

	The Responsible Appliance Disposal (RAD) Program is a voluntary program
that promotes the proper handling of refrigerated household appliances
at the time of their disposal.  Although the handling of many appliance
components is regulated, reports have surfaced of illegal activities,
including appliance dumping, venting of refrigerant, and improper
treatment of hazardous components.  Moreover, the RAD Program requires
the removal and destruction/reclamation of ODS foam blowing agents that
are not covered under existing Federal regulations.  

More specifically, through the RAD Program, EPA is partnering with
utilities, municipalities, retailers, manufacturers, and universities to
promote the proper disposal of old refrigerators, freezers, window air
conditioning units, and dehumidifiers, in order to prevent emissions of
ODS and GHG refrigerants and foam-blowing agents. The Program is also
expected to save landfill space, save energy used by older appliances,
lead to the recovery of valuable materials for use in making new
products (e.g., metals, plastics, glass), and prevent the release of
hazardous substances—including PCBs, mercury, and used oil. Additional
environmental benefits may also be achieved through the Program in the
form of reduced energy consumption and associated greenhouse gas
emissions, if Partner programs actively promote the retirement of old
appliances, to permanently remove energy inefficient units from the
electricity grid.

	As a benefit for joining, Partners can enjoy technical and logistical
support from EPA to help establish and implement responsible appliance
disposal programs, as well as public recognition for their efforts. 
Participation in the program begins with completion of a Partnership
Agreement that outlines responsibilities of the RAD Partnership.  This
Partnership Agreement is a legal agreement between EPA and a utility,
municipality, retailer, manufacturer, or university.  By joining the
program, a Partner agrees to complete an annual reporting form
identifying the number and types of appliances handled and the fates of
their individual components.  If the reporting form is completed
electronically, it automatically generates feedback for the user on the
gross impact of their program in terms of ODS and GHG emissions avoided,
quantity of used oil/PCBs/mercury destroyed or recycled, energy savings
achieved, and consumer savings realized.  This agreement can be
terminated by either Party 20 days after the receipt of written notice
by the other Party with no penalties or continuing obligations.

2.	NEED FOR AND USE OF THE INFORMATION COLLECTION

2(a)	Need and Authority for the Collection

The Clean Air Act establishes the nation’s commitment to eliminating
emissions of ODS.  The RAD Program is an important action contributing
to the overall reduction of ODS emissions, specifically through the
assurance of ODS refrigerant and foam destruction or reclamation.  The
RAD Program also contributes to the overall reduction of greenhouse gas
(GHG) emissions.  Authority for collection of the information described
in this ICR is provided in Section 608 of the 1990 Clean Air Act
Amendments (40 CFR §82.166).

EPA has developed this ICR to obtain authorization to collect
information from Partners participating in the RAD Program.  By
participating in the program, a Partner agrees to the terms of various
information collections specified by EPA in the Partnership Agreement. 
Specifically, Partners must submit the Partnership Agreement to EPA, as
well as an annual report that details the quantity of materials handled
by the Partner in their appliance recycling practice and how those
materials were handled.  From these reports, EPA will be able to
evaluate the overall impact of the RAD Program, including the quantity
of ODS emissions avoided.

2(b)	Practical Utility and Users of the Data

The Agency will use the Partnership Agreement to establish a framework
for a voluntary agreement with Partners in the Program.  EPA will use
information submitted in the annual reports to demonstrate that Partners
are reducing ODS emissions from appliance recycling operations.  EPA
also will use the information to determine (1) the types, number,
average age, and charge levels of refrigerated appliances collected by
recycling programs, (2) the ultimate fates of appliance components, (3)
the energy savings resulting from programs that offer an incentive for
removing old appliances from the electricity grid, (4) the amount of GHG
emissions avoided, (5) the amount of durable materials prevented from
being landfilled, and (6) the number of PCB-containing capacitors and
mercury switches properly disposed.  In addition, EPA will use the
information to publicize Partner and Program successes. 

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a)	Nonduplication

The information to be obtained under this ICR is not collected by any
other EPA program or Federal agency.  The information is not available
from other sources because it is proprietary information submitted by
industry sources.  

3(b)	Public Notice Request Prior to ICR Submission to OMB

In compliance with the Paperwork Reduction Act of 1995, EPA issued a
public notice in the Federal Register (72 FR 45423) soliciting public
comments for a 60-day period ending August 14, 2007.  EPA received no
public comments on the ICR during the comment period. 

3(c)	Consultations

In January of 2007, EPA consulted with stakeholders to obtain feedback
on the burdens and costs associated with the Partnership’s paperwork
activities.  EPA contacted the parties that had helped to create the
reporting form about its time requirements, and considered feedback from
existing partners about the time associated with completing the
Partnership Agreement and the annual reports.  After collecting this
feedback, EPA developed an average burden and cost estimate for each
respondent activity in this ICR and incorporated these estimates into
the ICR’s burden and cost calculations.  See Section 6 of this ICR for
these calculations.

3(d)	Effects of Less Frequent Collection

EPA requests that the Partner submit information on its appliance
recycling practices to the Agency once per year.  EPA believes that any
reduction in the frequency of this information collection would impede
efforts by EPA to evaluate results of this program.  Less frequent
collection of data would also place an undue burden on both EPA and
Partners to ensure accuracy of data.  For example, any one data
inaccuracy would be compounded by the greater time between actual data
collection and the efforts required to correct the historical
information.

3(e)	General Guidelines

This ICR adheres to the guidelines stated in the Paperwork Reduction Act
of 1995, OMB's implementing regulations, OMB's Information Collection
Review Handbook, and other applicable OMB guidance.

3(f)	Confidentiality

EPA informs the respondents that they may assert claims of business
confidentiality for any of the information they submit.  Information
claimed as confidential will be treated in accordance with the
procedures for handling information claimed as confidential under 40 CFR
Part 2, Subpart B (“Confidentiality of Business Information”), 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).  

3(g)	Sensitive Questions

No questions of a sensitive nature or of matters usually considered
private to individuals will be asked.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)	Respondents/SIC and NAICS Codes

The North American Industry Classification System (NAICS) codes of
entities most likely to be affected by the information collection
requirements covered under this ICR are listed below in   REF
_Ref159661745 \h  \* MERGEFORMAT  Table 1 .  

Table   SEQ Table \* ARABIC  1 . NAICS Classification of Affected
Industries

Potentially Affected Entities	NAICS Code	NAICS Category

Utilities	2211	Electric Power Generation, Transmission & Distribution

Manufacturers	3352	Household Appliance Manufacturing

Retailers	443111	Household Appliance Stores

Universities	611300	Colleges, Universities, and Professional Schools

Municipality	999300	Local Government

4(b)	Information Requested

Partners participating in the RAD Program submit a Partnership Agreement
to the EPA.  The Partners also agree to submit the annual reporting form
that provides data on materials handled by the appliance recycling
program and calculates environmental benefits achieved through the
program.  Each of these information collections is described separately
below, along with the respective data items and respondent activities.

Partnership Agreement

A number of Partners worked with EPA to prepare the Partnership
Agreement establishing the terms of participation in the RAD Program. 
After finalizing the Partnership Agreement, each Partner must review,
sign, and submit it to the Agency.

(i)	Data Item

Partnership Agreement

(ii)	Respondent Activities

Prepare the Partnership Agreement in collaboration with EPA (varies by
Partner);

Review and sign the Partnership Agreement; and

Submit the Partnership Agreement to EPA.

Annual Reporting Form

The Partner agrees that it will complete an annual reporting form either
electronically, using Excel, or manually, using a printed PDF form.  The
electronic version of the reporting form includes an auto-generated
sheet that summarizes the environmental benefits achieved through the
Partner’s program, based on the data entered for that reporting year. 
The forms are provided by EPA, and the Partner must submit the completed
form to the Agency. 

(i)	Data items

The reporting form requests the following information:

The Partner name, names of a primary and alternative contact, address,
phone number, fax number, and e-mail address;

Reporting period;

Equipment types included in the Partner’s program
(refrigerators/freezers, stand alone freezers, window air conditioning
units, and/or dehumidifiers);

Whether the program actively encourages the disposal of old equipment;

Number of households in the area served by the program;

For each type of appliance included in the program: 

Total number of units processed;

Number of units with an empty charge;

Average age of equipment collected;

Total amount and fate(s) of each appliance component processed;

Method for estimating the total number/amounts of various components
processed;

If the program provides an incentive to encourage the disposal of old
equipment: the average number of remaining years of useful life of that
equipment, average energy consumed/year/unit, and average energy cost
for residential consumers; and

Additional comments.

In the electronic version of the reporting form, the following
calculations are automatically generated for the user:

Estimates of gross energy impact, if the program provides an incentive
to encourage the disposal of old equipment. The user must review these
estimates (which include total saved energy and total dollar savings to
residential consumers), and provide corrections if necessary.

Summary of the environmental benefits achieved through the user’s
program, including ODS and GHG emissions avoided. This page is intended
only for the user’s interest; no data or additional information is
requested.

(ii)	Respondent activity

Partners will complete and submit the annual reporting form each
calendar year the Partnership Agreement is in effect.

5. 	THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT

5(a)	Agency Activities

The Partnership requires EPA to perform certain activities associated
with the Partnership Agreement, the annual reporting forms, and
information sharing.  Each of these three information collections, and
the Agency’s activities associated with them, are described in more
detail below. 

Partnership Agreement

EPA must perform the following activities related to the Partnership
Agreement for RAD Partners:

Develop the draft Partnership Agreement in collaboration with first
Partner(s);

Solicit and review stakeholder comments;

Develop the final Partnership Agreement;

Disseminate the Partnership Agreement; and

Review and file the completed Partnership Agreement.

Annual Reporting Form

EPA will perform the following activities with regard to the annual
reporting form to be submitted by the Partners:

Develop the reporting form;

Solicit and review stakeholder comments;

Disseminate the reporting form;

Review annual reporting forms submitted by Partners and aggregate/
analyze the data to estimate overall RAD Program results;

Develop a summary annual report; abd

File and maintain copies of the reporting forms.

5(b)	Collection Methodology and Management

In collecting and analyzing the information associated with this ICR,
EPA uses electronic equipment, such as personal computers and applicable
database software.  EPA also provides hardcopies of all forms at
request.  EPA will ensure the accuracy and completeness of collected
information by reviewing each Partner’s submitted information.  EPA
will maintain files of Partnership Agreements and reporting forms.  

	EPA is currently developing an Internet web page for this program that
will facilitate access to general program information and allow
interested parties to download the Partnership Agreement, guidelines for
proper appliance handling, and the annual reporting form.

5(c)	Small Entity Flexibility

EPA has designed its reporting forms to minimize respondent burden while
obtaining sufficient and accurate information.  In addition, the burden
associated with the Partnership is inherently minimized since the
initial agreement to participate is voluntary.  

5(d)	Collection Schedule

EPA collects basic Partner information in the Partnership Agreement,
which is completed and submitted by the Partner.  EPA will collect
reporting forms from Partners on an annual basis.  EPA may collect other
program information on a periodic basis or as the information is
submitted.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a)	Estimating Respondent Burden

  REF _Ref159661774 \h  \* MERGEFORMAT  Table 2  presents the estimated
annual respondent burden and costs for information collection activities
associated with the RAD Program. In the “Hours and costs per
respondent or activity” section,   REF _Ref159661774 \h  \*
MERGEFORMAT  Table 2  presents the average burden for each Partner,
accounting for the varying labor rates among the five types of Partners.
  REF _Ref159661774 \h  \* MERGEFORMAT  Table 2  includes the number of
hours required to conduct the information collection activity and the
cost associated with each requirement.  In developing burden estimates
for each information collection requirement in this ICR, EPA consulted
with third party stakeholders and considered Partner feedback.  (See
Section 3(c) of this ICR for information on the consultations.)  As
shown in   REF _Ref159661774 \h  \* MERGEFORMAT  Table 2 , EPA estimates
a total average annual respondent burden of approximately 6 hours. 
Assumptions used in calculating this estimate are described below.



Table   SEQ Table \* ARABIC  2 . Respondent Burden and Costa

INFORMATION COLLECTION ACTIVITY	Frequency/ Number of Responsesb	Hours
Costs



Legal Hours per Response	Manager Hours per Response	Technical Hours per
Response	Clerical Hours per Response	Total Labor

Hours per Response 	Average Total Hours/Year over 3 years	 Total Labor

Cost per Responsec	Average Cost/Year over 3 years

Partnership Agreement

Develop the Partnership Agreement in collaboration with EPA	One time
occurrence; only one partner involved	4	6	0	0	10	3.33	$1,118.42	$372.81

Review the Partnership Agreement	One occurrence per partner; 50 new
partners assumed over 3 years	2	2	2	0	6	100.00	$517.22	$8,620.37

Complete the Partnership Agreement

0	0.25	0	0	0.25	4.17	$22.18	$369.67

Submit the Partnership Agreement to EPA

0	0	0	0.25	0.25	4.17	$8.48	$141.34

Subtotal	NA	6	8.25	2	0.25	16.5	111.67	$1,666.30	$9,504.20

Annual Report

Complete and submit first annual report	One occurrence per partner; 50
first annual reports assumed to be completed by partners over 3 years
(from 16 partners in Program Year 1, and 17 partners in both Program
Years 2 and 3)	0	6	0	0.25	6.25	104.17	$540.81	$9,013.51

Complete and submit subsequent annual report	Zero to two occurrences per
partner over 3 years; 49 subsequent annual reports assumed to be
completed over 3 years (from 16 partners in Program Year 2 and 33
partners in Program Year 3)	0	5	0	0.25	5.25	85.75	$452.09	$7,765.28

Subtotal	NA	0	11	0	0.5	11.5	189.92	$992.90	$16,778.79

TOTAL 

(Annual average for first 3 yrs of RAD)	NA	6	19.25	2	0.75	28	301.58
$2,659.20	$26,282.98

TOTAL per Partner 

(Annual average for first 3 yrs of RAD)	NA	6	19.25	2	0.75	28	6.03
$2,659.20	$525.66

a See Section 6(b) for more information on how respondent burden is
estimated.

b Number of responses is based on the estimated number of new partners
over a 3-year period, as presented in   REF _Ref159661873 \h  \*
MERGEFORMAT  Table 6 .

c Labor costs are calculated based on the labor rates presented in   REF
_Ref159661896 \h  \* MERGEFORMAT  Table 3 .6(b)	Estimating Respondent
Costs

Labor Costs

EPA estimates respondent labor costs (hourly rate plus overhead and
fringe) based on the average hourly labor rates of the Partners.  For
each Partner, EPA estimates average hourly labor rates according to the
type of Partner – utility, municipality, retailer, manufacturer, or
university. These labor rates are based on national averages reported by
the Bureau of Labor Statistics, to which 110% is added to reflect the
estimated additional costs for overhead and fringe.    REF _Ref159661896
\h  \* MERGEFORMAT  Table 3  summarizes the labor rates.

Table   SEQ Table \* ARABIC  3 . Average Hourly Respondent Labor Rates

	Managerial	Technical	Clerical	Legal

Utilities	$100.32	$63.46	$37.78	$129.13

Municipalities	$62.96	$44.73	$31.14	$81.61

Retailers	$92.46	$50.97	$26.10	$115.88

Manufacturers	$95.21	$48.97	$32.57	$109.20

Universities	$81.71	$52.08	$30,28	$107.94



Capital and Operation and Maintenance (O&M) Costs

The Partners participating in the RAD Program are not required to incur
any notable capital costs under the Partnership.  The Partners normally
keep track of their program data as a standard business practice.

The Partners participating in the RAD Program are not required to incur
any notable operation and maintenance (O&M) costs.  The Partners need
only to submit their information to EPA.

6(c)	Estimating Agency Burden and Cost

  REF _Ref159661958 \h  \* MERGEFORMAT  Table 5  presents the estimated
Agency burden hours and costs associated with the information collection
activities for this ICR.  Agency labor costs are based on national
averages for the Federal Executive branch reported by the Bureau of
Labor Statistics, which are multiplied by 1.6, the standard government
benefits multiplier.  See   REF _Ref159661931 \h  \* MERGEFORMAT  Table
4  for EPA estimates of average hourly labor costs for legal,
managerial, technical, and clerical staff.  As shown in   REF
_Ref159661958 \h  \* MERGEFORMAT  Table 5 , EPA estimates that the
annual Agency burden for all activities covered in this ICR is 905 hours
at a total cost of $51,149 per year.

Table   SEQ Table \* ARABIC  4 . Average Hourly Agency Labor Rates

Managerial	Technical	Clerical	Legal

$86.23	$69.42	$52.64	$35.18

Table   SEQ Table \* ARABIC  5 . Agency Burden and Costa

INFORMATION COLLECTION ACTIVITY	Frequency/ Number of Activities	Hours
Costs



Legal Hours per Activity	Manager Hours per Activity	Technical Hours per
Activity	Clerical Hours per Activity	Total Labor

Hours per Activity 	Average Total Hours/Year over 3 years	 Total Labor

Cost per Activityb	Average Cost/Year over 3 years

Partnership Agreement

Develop Draft Partnership Agreement	One time occurrence	0 	15 	50 	0 	65
	21.67	$3,673.36	$1,224.45

Solicit and review stakeholder comments

0 	5 	15 	0 	20 	6.67	$1,136.72	$378.91

Develop final Partnership Agreement

0	10 	20 	0 	30 	10	$1,747.04	$582.35

Disseminate the Partnership Agreement	One occurrence per partner; 50 new
partners assumed over 3 yearsc	0	0 	0 	0.25 	0.25 	4.17	$8.80	$146.60

Review the completed Partnership Agreement

0	0 	0.5 	0 	0.5 	8.3	$26.32	$438.67

Subtotal	NA	0 	30 	85.5 	0.25 	115.75 	50.83	$6,592.24	$2,770.97

Annual Report

Develop reporting form	One time occurrence	0	40	120	0	160 	53.33
$9,093.76	$3,031.25

Solicit and review stakeholder comments

0	5	15	0	20 	6.67	$1,136.72	$378.91

Disseminate the reporting form	One occurrence per year	0	0	0	1	1 	1.00
$35.18	$35.18

Review annual reports and analyze data	One occurrence per reporting form
submitted (total of 99 over 3 years)c	0	5	15	0	20 	660	$1,136.72
$37,511.76

Develop summary annual report	One occurrence per year	0	25	75	0	100 	100
$5,683.60	$5,683.60

File and maintain copies of annual reports	One occurrence per reporting
form submitted (total of 99 over 3 years)c	0	0	1	0	1 	33	$52.64
$1,737.12

Subtotal	NA	0	75	226	1	302 	854.00	$17,138.62	$48,377.82

TOTAL (Annual average for first 3 yrs of RAD)	NA	0 	105 	311.5 	1.25 
417.75 	904.83	$23,730.86	$51,148.80

a See Sections 6(c) and 6(d) for more information on how Agency burden
is estimated.

b Labor costs are calculated based on the labor rates presented in   REF
_Ref159661931 \h  \* MERGEFORMAT  Table 4 .

c Number of partner responses is based on the estimated number of new
partners over a 3-year period, as presented in   REF _Ref159661873 \h 
\* MERGEFORMAT  Table 6 .

6(d) 	Estimating the Respondent Universe and Total Respondent Burden
and Costs

Respondent Universe

  REF _Ref159661873 \h  \* MERGEFORMAT  Table 6  summarizes the number
of Partners expected to participate in the RAD Program during the
three-year effective life of this ICR.  In total, EPA expects to have 16
Partners by the end of the first year, 33 at the end of the second year,
and 50 after three years.    REF _Ref159661873 \h  \* MERGEFORMAT  Table
6  also breaks down the new Partners each year by the five different
types of partners in the program.  The following paragraphs discuss the
information collections these Partners will perform under the
Partnership.    REF _Ref159661774 \h  \* MERGEFORMAT  Table 2 
calculates the annual burden and cost to Partners in performing these
collections.

Table   SEQ Table \* ARABIC  6 . Number of Partners New to the RAD
Program Each Year by Partner Type 

 RAD Program Partners	Utilities	Municipalities	Retailers	Manufacturers
Universities	Total

New Partners Year 1	14	1	0	0	1	16

New Partners Year 2	5	3	2	2	5	17

New Partners Year 3	5	5	1	1	5	17

Total	24	9	3	3	11	50



Partnership Agreement

As shown in   REF _Ref159661873 \h  \* MERGEFORMAT  Table 6 , EPA
estimates that, over the three-year life of this ICR, 50 Partners will
participate in the Partnership.  One Partner worked with EPA to prepare
the Partnership Agreement establishing the terms of participation in the
Partnership.  All Partners must review, sign and submit the Partnership
Agreement to EPA to begin their participation in the Partnership.  As
shown in   REF _Ref159661774 \h  \* MERGEFORMAT  Table 2 , EPA has
annualized the one-time burden of Partnership Agreement preparation over
three years to estimate that 50/3 Partners will prepare and submit a
Partnership Agreement each year.  [Note that   REF _Ref159661774 \h  \*
MERGEFORMAT  Table 2  calculates respondent burden and costs on an
annual basis.  The table calculates the burden and cost of one-time
activities (i.e., activities performed once during the three-year period
of this ICR) by dividing the total number of respondents by three (e.g.,
50 Partners / 3 years = 16.67 Partners per year).] 

Annual Reporting Form

Each Partner agrees to complete an annual reporting form to be submitted
to the Agency.  The report will contain data on the types of appliances
handled and the fates of each appliance component.  In estimating burden
and costs for this information collection, EPA believes that new
Partners will incur a greater burden in preparing their first report
(i.e., for their first year of membership), than in preparing reports
for their subsequent years of membership. That is, new Partners may
encounter a one-time learning curve in compiling and examining data for
their “first-year” reporting forms.  After gaining such experience,
these Partners would likely incur a lower burden in preparing their
“subsequent-year” reports. 

As shown in Tables 2 and 6, EPA estimates that an average of 16.67
Partners each year will be new to the Partnership and that each will
incur about 6 hours in preparing and submitting their first-year reports
to the Agency.  EPA further estimates that, over the three-year life of
this ICR, 16.33 Partners on average will submit subsequent-year reports
to the Agency each year and incur about 5 hours per report.

6(e)	Bottom Line Burden Hours and Costs

Respondent Tally

In Table 2, EPA estimates the total annual respondent burden and cost
for the Responsible Appliance Disposal Partnership to be approximately
302 hours and $26,283.  The bottom line respondent burden over the
three-year period covered by this ICR is approximately 906 hours, at a
total cost of approximately $78,849.

Agency Tally

As shown in Table 5, the annual Agency burden and cost are estimated to
be approximately 905 hours and $51,149 per year.  The bottom line Agency
burden over the three-year period covered by this ICR is approximately
2,715 hours, at a total cost of approximately $153,447.

Variations in the Annual Bottom Line

EPA anticipates no significant variation in the annual respondent
reporting and/or recordkeeping burden over the next three years.	

6(f)	Reasons for Change in Burden

This is the first ICR for the Responsible Appliance Disposal Program.

6(g)	Burden Statement

The annual reporting burden for this information collection is estimated
to average approximately 6 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 1.

	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-2007-0358, which is available for online viewing at
www.regulations.gov, or in person viewing at the Air Docket in the EPA
Docket Center (EPA/DC), EPA West Room 3334, 1301 Constitution Avenue,
NW, Washington, D.C.  The EPA Docket Center Public Reading Room is open
from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal
holidays.  The telephone number for the Reading Room is (202) 566-1744,
and the telephone number for the Air 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-HQ-OAR-2007-0358 and OMB Control Number 2060-NEW in any
correspondence.

 NAICS codes were retrieved from the “2002 NAICS Codes and Titles”
provided by the U.S. Census Bureau at,
http://www.census.gov/epcd/naics02/naicod02.htm.

 Labor rates were retrieved from the “May 2005 National
Industry-Specific Occupational Employment and Wage Estimates” provided
by the U.S. Bureau of Labor Statistics at,
http://www.bls.gov/oes/current/oessrci.htm.

 Labor rates were retrieved from the “May 2005 National
Industry-Specific Occupational Employment and Wage Estimates” for the
Federal Executive Branch (NAICS Code 999100) provided by the U.S. Bureau
of Labor Statistics at,
http://www.bls.gov/oes/current/naics4_999100.htm.

 EPA and Partners prepared the Partnership Agreement in 2006.

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