Supporting Statement

Information Collection Request 

GreenChill Advanced Refrigeration Partnership

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection Request

This Information Collection Request (ICR) is entitled “Information
Collection Activities under the U.S. Environmental Protection Agency’s
(EPA’s) GreenChill Advanced Refrigeration Partnership Program,” ICR
number 2349.01.

1(b) Short Characterization

The Montreal Protocol on Substances that Deplete the Ozone Layer
(Montreal Protocol) is an international agreement with universal
participation aimed at reducing and eventually eliminating the
production and consumption of ozone-depleting substances (ODS).  The
United States was one of the original signatories to the 1987 Montreal
Protocol. Congress then enacted into law the Clean Air Act Amendments of
1990 (CAA), which included Title VI on Stratospheric Ozone Protection to
ensure that the United States could satisfy its obligations under the
Montreal Protocol. Title VI includes provisions that establish
restrictions on production, consumption, and reduce use and emissions of
ODS.  

ODS are divided into two groups: Class I and Class II. Class I ODS
includes chlorofluorocarbons (CFCs), methyl bromide and other substances
that have a high ozone-depleting potential (ODP) that have been phased
out in the United States; and Class II substances are
hydrochlorofluorocarbons (HCFCs), which are transitional substitutes for
many Class I substances and are currently being phased out. For the HCFC
phaseout the United States is implementing the phaseout schedule on a
chemical-by-chemical basis employing a ‘‘worst-first’’ approach.
On December 15, 2009, EPA published two rules (74 FR 66412, 74 FR 66450)
that together restrict the availability and use of HCFCs (including
HCFC-22) in 2010. One rule allocates a reduced amount of allowances for
the production and import of HCFCs. The other rule bans the sale or
distribution (including import and export) of pre-charged
air-conditioning and refrigeration products and components containing
HCFC-22 or HCFC-142b. EPA’s Stratospheric Protection Division (SPD)
manages these programs in conjunction with the Title VI complementary
measures to ensure a smooth transition to alternatives that reduce
overall risk to human health and the environment. The complementary
measures include the refrigerant management program established under
Section 608, the Significant New Alternatives Policy (SNAP) program
authorized by Section 612, as well as partnership programs that focus on
opportunities to assist specific industries in achieving SPD’s
regulatory goals and in going above and beyond regulatory requirements. 
The GreenChill Advanced Refrigeration Partnership (hereafter referred to
as GreenChill Partnership or GreenChill) is a partnership program that
assists the supermarket industry in reducing ozone-depleting and
greenhouse gas (GHG) refrigerant emissions.   

The GreenChill Advanced Refrigeration Partnership, launched November 27,
2007, is an EPA alliance with the supermarket industry to reduce its
impact on the ozone layer and climate change.  Working with EPA,
GreenChill Partners transition to non-ozone-depleting refrigerants,
reduce refrigerant charges, reduce refrigerant leaks, and promote
supermarkets’ adoption of advanced refrigeration technologies,
strategies, and practices. The GreenChill Partnership intends to promote
innovation by serving as a forum for Partners to communicate successful
ODS and GHG reduction techniques, along with helping Partners identify
and access the latest information on improvements in refrigerants,
refrigeration technology, and best environmental practices. The program
also provides companies with recognition for environmental action beyond
regulatory requirements, thus allowing the industry to build substantial
good will with consumers.  The GreenChill Partnership was developed and
is managed by SPD. This ICR is for information collection from
supermarket Partners.

In 2007, there were 34,937 supermarkets with annual sales exceeding $2
million per establishment. Smaller grocery stores, which are defined as
accruing less than $2 million in annual sales per unit, accounted for
another 13,652 establishments, and large wholesale club stores accounted
for 1,152 entities. All of these entities, from large conglomerates to
small independent store operators, represent potential GreenChill
Partners. According to a March 2009 report by the Chain Store Guide, a
market research service, the top 23 food retailers, each with more than
200 stores, held 74% of the U.S. grocery market share. An advantage of
having major chains join the GreenChill Partnership is the inclusion of
a large number of individual stores.

Most of the U.S. supermarkets use what is generally referred to as a
“direct expansion (DX) refrigeration system” to chill their
products. These systems typically use large charges of refrigerant, and
they usually have high leak rates, often in excess of 20% of their
charge per year. The majority of the supermarkets in the United States
use HCFC-22 (also known as R-22) as the primary refrigerant. Under
EPA’s implementation of the Montreal Protocol, HCFC-22 is being phased
out under the following schedule:

On January 1, 2003, EPA limited how much and who could import/produce
HCFC-22. 

On January 1, 2010, production and import of virgin HCFC-22 will be
reduced by more than 75% (74 FR 66412) and the use of virgin HCFC-22
limited to servicing of equipment made before this date, for export, and
for processes resulting in transformation or destruction of the
substances. HCFC-22 amounts will be reduced each year between 2010-2014,
when another rule will be issued governing amounts of HCFC-22 for
2015-2019. 

On January 1, 2020, all production and import of virgin HCFC-22 will be
banned, with exceptions for export and for processes resulting in
transformation or destruction of the substances. 

EPA also restricts the import of used HCFC-22 without prior approval
from both EPA and the government representing the country of export.

Most supermarkets moving to HCFC-22 alternatives use refrigerants
consisting entirely or primarily of hydrofluorocarbons (HFCs). HCFCs and
HFCs are both GHGs. 

There are several refrigeration technology options available for
supermarkets to reduce their refrigerant charges and refrigerant
emissions. Two of the most common advanced refrigeration technologies
are distributed and secondary loop technologies. The GreenChill
Partnership has the potential to promote emissions reductions and
accelerate the phaseout of ODS in supermarket refrigeration and
air-conditioning by encouraging the use of these advanced refrigeration
technologies.

An organization’s decision to participate in EPA’s GreenChill
Partnership is completely voluntary. Partners voluntarily join
GreenChill because the Partnership is an exceptional source of
supermarket refrigerant emissions data, which gives partners the
opportunity to benchmark their emissions reductions versus their
competitors. Any company that does not want to participate in
GreenChill’s data collection process can avoid it by not signing up
for the Partnership.  Partners are free to terminate their participation
in GreenChill at any time.

Participation in the GreenChill Partnership begins with the completion
and submittal to EPA of a Partnership Agreement that provides EPA with a
corporate contact for Partnership-related activities. It is signed by a
senior official with authority to commit his or her organization to the
program and is also signed by an EPA representative. After completing
the Partnership Agreement, Partners are asked to submit a GreenChill
Stocks and Emissions Report within one year of becoming a Partner. The
form provides a list of refrigerants and requires Partners to provide
information on the stocks and emissions of each of these refrigerants in
commercial refrigeration and air-conditioning appliances. Finally, the
GreenChill Partnership asks all Partners to fill out a Corporate
Refrigerant Management Plan with information from their respective
existing refrigerant management plans, to inform EPA of their emissions
reductions goals and plans for retrofitting old equipment and installing
new equipment. 

There are a variety of environmental, economic, and synergistic benefits
to EPA’s GreenChill Partnership. Most notably, Partners can assist in
addressing global environmental impacts associated with use and
emissions of ODS and GHGs. In addition, advanced refrigeration systems
typically require smaller refrigerant charges and have lower leak rates
compared to conventional refrigeration systems, which could result in
significant savings on annual refrigerant costs.  Partners share
information with each other on new technologies, strategies, and
practices, including GreenChill pilot projects, which helps spur
innovation in the industry. 

2. NEED FOR AND USE OF THE INFORMATION COLLECTION

2(a) Need and Authority for the Collection

Title VI of the Clean Air Act required EPA to phase out production and
consumption of ODS. While Class I substances have already been phased
out, Class II substances (HCFCs) are currently being phased out. The
2010 milestone in the phaseout of HCFC-22 and HCFC-142b marks a major
step in the transition to non-ODS alternative refrigerants and a
strategic opportunity for the food retail industry, since companies can
simultaneously negotiate the required transition to non-ODS alternative
refrigerants and move to advanced technologies that can generate
additional benefits, such as cost savings. Because many alternative
refrigerants have high GWPs (e.g., HFCs), it is important during this
transition to consider reducing emissions of all refrigerants, not just
ODS. By promoting the use of advanced refrigeration technologies, the
GreenChill Partnership is an important component of EPA’s ODS phaseout
strategy. 

EPA has developed this ICR to obtain authorization to collect
information from supermarkets participating in the GreenChill
Partnership. By participating in the program, a Partner agrees to the
terms of three information collections specified by EPA in the
Partnership Agreement:

(1)  Partners must submit the Partnership Agreement to EPA;

(2)  Partners must annually submit the Stocks and Emissions Report; and 

(3)  Partners must annually submit a Corporate Refrigerant Management
Plan. 

2(b) Practical Utility/Users of the Data

The information collected by EPA’s GreenChill Partnership is not
designed or intended to support regulatory decision-making by SPD or
other EPA offices. These data are voluntarily reported by individual EPA
GreenChill Partners, and EPA will use this information as described
below.

Partnership Agreement

EPA will use information submitted in the Partnership Agreement to
officially establish participation in EPA’s GreenChill Partnership and
list Partners on EPA’s GreenChill Partnership website. The Partnership
Agreement is intended to clearly delineate the responsibilities and
activities expected to be completed by members of the GreenChill
Partnership. Information collected in the Partnership Agreement will
also be used by EPA to establish a contact person for EPA
communications.

GreenChill Stocks and Emissions Report 

EPA will use information submitted by Partners on refrigerant stocks to
establish a base year of stocks and emissions measurements and to
quantify refrigerant inventory and emissions. Subsequent annual
completion of this report will ensure that both GreenChill Partners and
EPA are able to easily track their progress in reducing emissions of
GHGs and ODS. 

Corporate Refrigerant Management Plan

The Corporate Refrigerant Management Plan, which includes information
from companies’ existing refrigerant management plans, allows Partners
to communicate to EPA the emissions reduction goals they have
established. These goals serve to focus Partner management on reduction
strategies and allow EPA to easily work with Partners to achieve a
measurable reduction in ODS and GHGs.

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 Required Prior to ICR Submission to OMB

In compliance with the Paperwork Reduction Act of 1995, EPA issued a
public notice in the Federal Register (Vol. 74, No. 105) on June 3,
2009, soliciting public comments for a 60-day period.

3(c) Consultations

EPA’s GreenChill Partnership had seven pilot program Partners. These
pilot Partners were asked how long it took them to complete the
activities necessary to provide the information requested for
participation in the Partnership. The Partners listed in Table 1
provided input:

Table 1. Partners that provided input to this ICR

Supermarket	Partnership contact

Food Lion	Wayne Rosa

Giant Eagle	Cliff Timko

Hannaford Bros. Co.	Harrison Horning

Harris Teeter	Michael Shepard

Publix	Stephen Sloan

Supervalu	George Ronn

Whole Foods	Kathy Loftus

Note: In certain cases information was gained from multiple staff
members. Only the designated Partnership contact is listed above.



In addition, Van Baxter at the Department of Energy’s Oak Ridge
National Laboratory (ORNL), who will process some of the forms, was
asked to estimate his time to process and synthesize the information.

3(d) Effects of Less Frequent Collection

The Partnership Agreement is a one-time information submittal for
organizations that wish to participate in EPA’s GreenChill
Partnership. Less frequent collection of the partner contact information
in this agreement is not feasible. 

GreenChill Partners are required to submit the GreenChill Stocks and
Emissions Report at the end of their first year in the Partnership and
each year thereafter. Less frequent collection is not feasible, since
data are used to create a baseline of emissions and track Partners’
progress relative to their annual goals in reducing their release of ODS
and GHGs.

Each GreenChill Partner must submit a Corporate Refrigerant Management
Plan, which includes information from companies’ existing refrigerant
management plans, at the end of their first year of participation in the
GreenChill Partnership, and every year thereafter. Less frequent
collection is not feasible, as this form allows Partners to establish
clear emissions reductions targets and enlist the help of EPA in
achieving these targets. 

3(e) General Guidelines

This ICR adheres to the guidelines stated in the Paperwork Reduction Act
of 1995, OMB’s guidelines, and EPA’s Information Collection Review
Handbook.

3(f) Confidentiality

The GreenChill Stocks and Emissions Report is sent annually to an
independent third party, ORNL, where all submitted forms are stripped of
specific identifying information (e.g., the name of the supermarket),
aggregated into a database, and sent to EPA. EPA guarantees the
confidentiality of all information collected from participants in the
GreenChill Partnership.

3(g) Sensitive Questions

No questions of a sensitive nature or of matters usually considered
private to individuals will be asked. Sensitive questions generally deal
with race, sexual orientation, nationality, gender, medical history,
etc. 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and North American Industrial Classification System
(NAICS) Codes

Respondents will consist of supermarkets that partner with EPA’s
GreenChill Partnership. The NAICS code for supermarkets is 445110.

4(b) Information Requested

Once a prospective Partner reviews EPA’s GreenChill materials and
decides to join the program, the company must submit a Partnership
Agreement. By the end of the first year of entry into the Program, and
each year thereafter, each Partner must complete and submit the annual
Corporate  Stocks and Emissions Report (aggregated, not by individual
store) and the Corporate Refrigerant Management Plan, which includes
information from companies’ existing refrigerant management plans.

Partnership Agreement 

Program participants complete and submit two copies of a two-page
Partnership Agreement that lays out Partner and EPA responsibilities to
EPA.

(i) Data items

The reporting items include:

The name and signature of an authorized company representative

Name, title, address, county, postal code, phone number, fax number, and
e-mail address of the Partner’s designated GreenChill representative.

(ii) Respondent activities

Participants conduct the following activities in order to complete and
submit the Partnership Agreement:

Review the Partnership Agreement

Complete the Partnership Agreement and obtain the signature of a senior
official 

Send the completed Partnership Agreement to EPA via fax, mail, or
online, and file a copy.

GreenChill Stocks and Emissions Report 

By the end of the first year of entry as a Partner in GreenChill and
each year thereafter, Partners must complete a Corporate Stocks and
Emissions Report. 

(i) Data items

The reporting items include:

General Partner information [e.g., company name, the Partner’s
selected base year (the year in which this agreement was signed or up to
two years prior to the signing year), reporting year]

Corporate-wide refrigerant stocks by refrigerant type in commercial
refrigeration and air-conditioning appliances

Corporate-wide emissions by refrigerant type in commercial refrigeration
and air-conditioning appliances 

Name and signature of an authorized company representative, and the
date.

(ii) Respondent activities

Participants conduct the following activities in order to complete and
submit the GreenChill Stocks and Emissions Report:

Select the base year (first year only) and aggregate records on
refrigerant stocks and emissions 

Fill out and sign the GreenChill Stocks and Emissions Report 

Send the completed report to Van Baxter at ORNL via fax, mail, or
online, and file a copy.

Corporate Refrigerant Management Plan

The Corporate Refrigerant Management Plan, which includes information
from companies’ existing refrigerant management plans, must be filled
out within one year of GreenChill Partnership and submitted annually
thereafter.

(i) Data items

The reporting items include:

Participant information (e.g., business name)

Upcoming year’s annual emissions reduction goal (e.g., total corporate
base line emissions rate, target emissions rate, optional stretch target
goal)

Planned activities for upcoming year to retrofit existing stores, to
repair and/or prevent refrigerant leaks in existing stores, and /or
plans to install advanced refrigeration technology in newly constructed
stores.

(ii) Respondent activities

Participants conduct the following activities in order to complete and
submit the Corporate Refrigerant Management Plan:

Develop an emissions reduction goal

Fill out the Corporate Refrigerant Management Plan using information
from their existing refrigerant management plans

Gain corporate approval of the filled-out form

Send the filled-out form to EPA via fax, mail, or email, and file a
copy.

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

5(a) Agency Activities

EPA’s GreenChill Program will require EPA to engage in the following
activities related to the Partnership Agreement, the GreenChill Stocks
and Emissions Report, and the Corporate Refrigerant Management Plan,
which includes information from companies’ existing refrigerant
management plans.

Partnership Agreement 

Develop Partnership Agreement and distribute to prospective Partners

Answer questions posed by potential Partners regarding the Partnership
Agreement

Review completed agreements

Countersign the agreement and return a copy to Partner.

GreenChill Stocks and Emissions Report 

Develop the Corporate Stocks and Emissions Report form and distribute to
Partners

Annual conference call to answer questions posed by Partners regarding
annual reporting

Review completed GreenChill Stocks and Emissions Reports (done by third
party data collector for confidentiality, Van Baxter at ORNL)

Develop data tracking system

Enter data into a tracking system

Aggregate data for tracking program benefits and Partner achievements.

Corporate Refrigerant Management Plan

Answer questions posed by Partners regarding the Corporate Refrigerant
Management Plan 

Review company submissions

File company submissions

Develop charts of projected emission reductions based on goals and
compare Partner results to Partner goals (beginning in the second year
of submission).

5(b) Collection Methodology and Management

In collecting and analyzing the information associated with this ICR,
EPA uses a telephone system, personal computers, and database software.
EPA ensures the reasonableness and completeness of collected information
by reviewing each submittal. EPA plans to offer all information
collection instruments in hard copy and electronically. Electronic
submissions do not have a significant impact on respondent or Agency
burden.

5(c) Small Entity Flexibility

EPA currently expects that few participants in EPA’s GreenChill
Partnership might be small entities. In any event, EPA has designed its
reporting forms to minimize respondent burden while obtaining sufficient
and accurate information. In addition, the burden associated with the
GreenChill Partnership is inherently minimized since the initial
agreement to participate is voluntary. 

5(d) Collection Schedule

Organizations may submit Partnership Agreements to join the EPA’s
GreenChill Partnership at any time. Partners will also submit a
GreenChill Stocks and Emissions Report and a Corporate Refrigerant
Management Plan, which includes information from companies’ existing
refrigerant management plans, within one year of joining the
Partnership. Thereafter, these reports and forms will be submitted
annually. 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

EPA used input from pilot Partners and its experience implementing other
voluntary programs to estimate burden for respondents. EPA reviewed all
pilot Partner estimates of hours required to complete each activity. In
reviewing these estimates, EPA found nine outliers that distorted the
seven-company average burden estimates to the point of making them
unrepresentative of actual respondent activities. EPA views the
occurrence of these outlier estimates as a consequence of inadequate
communication of the nature and requirements of each activity to the
pilot Partners, rather than a reflection of the actual time required to
complete each activity. EPA calculated average burden and cost estimates
for each respondent activity, omitting the nine outliers. 

Table 2 presents the burden hours and costs per respondent for the
first, second, and third years they participated in the program. The
burden hours in the second and third years are less than the first year.
The Partnership Agreement involves a one-time burden and pilot Partners
indicated the hours required to collect and provide the information for
the other two forms would be less in the second and third years due to a
better understanding of the requirements and the experience gained in
the first year. Table 3 presents the aggregate burden hours for all
respondents during each of the three years covered under this ICR. The
annual reporting burden for each Partner for this information collection
is estimated to be 18.1 hours for the first year and 11.0 hours per year
for the second and third years. The total burden hours for all
respondents are estimated as 121, 172, and 216 hours for the first,
second, and third years, respectively. 

6(b) Estimating Respondent Costs

The estimated annual respondent cost per respondent is presented in
Table 2 and for all respondents in Table 3. The estimated annual
respondent costs are discussed below.

Table 2. Individual respondent burden in Year 1 and Years 2 and 3
(labor costs, O&M costs)

Information collection activity	Manager	Technical	Clerical	Legal
Consultant	Total hours	Labor costs 	Annual O&M costs

	Hours and costs per respondent per submission – Year 1

Partnership Agreement









Review the Partnership Agreement	1.6	0.0	0.3	1.3	0.0	3.1	$295.53	$0.00

Complete the Partnership Agreement and obtain signature of senior
official	1.5	0.0	0.1	0.2	0.1	1.8	$175.81	$0.00

Send the completed Partnership Agreement to EPA via fax, mail, or
online, and file a copy	0.1	0.0	0.3	0.0	0.0	0.4	$15.84	$5.57

Subtotal	3.1	0.0	0.6	1.5	0.1	5.3	$487.19	$5.57

GreenChill Stocks and Emissions Report









Select base year and aggregate records on refrigerant stocks and
emissions	1.2	0.4	0.1	0.0	0.9	2.6	$186.47	$0.00

Fill out and sign GreenChill Stocks and Emissions Report	0.9	0.1	0.4	0.0
0.0	1.5	$109.29	$0.00

Send the completed GreenChill Stocks and Emissions Report to Van Baxter
at ORNL via fax, mail, or online, and file a copy	0.2	0.0	0.1	0.0	0.0
0.4	$25.67	$2.86

Subtotal	2.2	0.5	0.6	0.0	0.9	4.4	$321.42	$2.86

Corporate Refrigerant Management Plan



Develop an emissions reduction goal	2.4	0.8	0.5	0.0	0.0	3.8	$297.23
$0.00

Fill out Corporate Refrigerant Management Plan	1.9	0.6	0.6	0.0	0.0	3.1
$235.50	$0.00

Gain corporate approval of the Corporate Refrigerant Management Plan	1.0
0.0	0.0	0.2	0.2	1.3	$122.93	$0.00

Send the Corporate Refrigerant Management Plan to EPA via fax, mail, or
online, and file a copy	0.2	0.0	0.1	0.0	0.0	0.4	$25.67	$2.00

Subtotal	5.5	1.4	1.2	0.2	0.2	8.4	$681.33	$2.00

Total	10.8	2.0	2.4	1.7	1.2	18.1	$1,489.93	$10.43

Notes: There are no capital start-up costs associated with this
information collection. Total values may not sum due to rounding.



Table 2. Individual respondent burden in Year 1 and Years 2 and 3 (labor
costs, O&M costs) (cont.)

Information collection activity	Manager	Technical	Clerical	Legal
Consultant	Total hours	Labor costs 	Annual O&M costs

	Hours and costs per respondent per submission – Years 2 and 3

Partnership Agreement









Review the Partnership Agreement	0.0	0.0	0.0	0.0	0.0	0.0	$0.00	$0.00

Complete the Partnership Agreement and obtain signature of senior
official	0.0	0.0	0.0	0.0	0.0	0.0	$0.00	$0.00

Send the completed Partnership Agreement to EPA via fax, mail, or
online, and file a copy	0.0	0.0	0.0	0.0	0.0	0.0	$0.00	$0.00

Subtotal	0.0	0.0	0.0	0.0	0.0	0.0	$0.00	$0.00

GreenChill Stocks and Emissions Report









Select base year and aggregate records on refrigerant stocks and
emissions	1.1	0.4	0.1	0.0	0.7	2.3	$172.75	$0.00

Fill out and sign GreenChill Stocks and Emissions Report	0.7	0.1	0.3	0.0
0.0	1.1	$87.83	$0.00

Send the completed GreenChill Stocks and Emissions Report to Van Baxter
at ORNL via fax, mail, or online, and file a copy	0.2	0.0	0.1	0.0	0.0
0.4	$25.67	$2.86

Subtotal	2.0	0.5	0.5	0.0	0.8	3.8	$286.25	$2.86

Corporate Refrigerant Management Plan



Develop an emissions reduction goal	1.8	0.6	0.3	0.0	0.0	2.6	$211.19
$0.00

Fill out Corporate Refrigerant Management Plan	1.8	0.6	0.6	0.0	0.0	3.0
$225.37	$0.00

Gain corporate approval of the Corporate Refrigerant Management Plan	1.0
0.0	0.0	0.2	0.2	1.3	$122.93	$0.00

Send the Corporate Refrigerant Management Plan to EPA via fax, mail, or
online, and file a copy	0.2	0.0	0.1	0.0	0.0	0.4	$25.67	$2.00

Subtotal	4.7	1.2	0.9	0.2	0.2	7.2	$585.15	$2.00

Total	6.7	1.7	1.4	0.2	0.9	11.0	$871.40	$4.86

Notes: There are no capital start-up costs associated with this
information collection. Total values may not sum due to rounding.



Table 3. Total respondent burden in Years 1-3 (hours, labor costs)

Information collection activity	Year 1	Year 2	Year 3

	Total hours	Total 

cost	Total hours	Total 

cost	Total hours	Total 

cost

Partnership Agreement







Review the Partnership Agreement	12.4	$1,182.13	12.4	$1,182.13	12.4
$1,182.13

Complete the Partnership Agreement and obtain signature of senior
official	7.3	$703.23	7.3	$703.23	7.3	$703.23

Send the completed Partnership Agreement to EPA via fax, mail, or
online, and file a copy	1.4	$85.66	1.4	$85.66	1.4	$85.66

Subtotal	21.1	$1,971.03	21.1	$1,971.03	21.1	$1,971.03

GreenChill Stocks and Emissions Report







Select base year and aggregate records on refrigerant stocks and
emissions	21.1	$1,554.71	31.3	$2,300.57	40.6	$2,991.55

Fill out and sign GreenChill Stocks and Emissions Report	10.3	$790.50
16.1	$1,227.64	20.7	$1,578.97

Send the completed GreenChill Stocks and Emissions Report to Van Baxter
at ORNL via fax, mail, or online, and file a copy	3.2	$256.75	4.6
$370.86	6.1	$484.98

Subtotal	34.6	$2,601.96	52.0	$3,899.07	67.4	$5,055.50

Corporate Refrigerant Management Plan







Develop an emissions reduction goal	23.3	$1,900.69	38.3	$3,089.63	48.6
$3,934.38

Fill out Corporate Refrigerant Management Plan	27.5	$2,119.46	38.8
$2,970.31	50.6	$3,871.80

Gain corporate approval of the Corporate Refrigerant Management Plan
11.6	$1,106.33	16.8	$1,598.03	22.0	$2,089.73

Send the Corporate Refrigerant Management Plan to EPA via fax, mail, or
online, and file a copy	3.2	$249.04	4.6	$359.72	6.1	$470.40

Subtotal	65.5	$5,375.51	98.4	$8,017.70	127.2	$10,366.31

Total	121.2	$9,948.50	171.6	$13,887.79	215.7	$17,392.84

Notes: Total values may not sum due to rounding. Four new partners are
assumed per year over the three-year period.



Estimating Labor Costs

The labor rates used to determine the estimated costs to respondents are
based on the hourly wage rates published by the Bureau of Labor
Statistics publications on employment and earnings. Rates include the
cost of overhead and fringe benefits. EPA estimated an average
respondent hourly labor rate (including a multiplier of 1.6 for fringe
benefits) as follows:

Manager: $101.25

Technical: $46.37

Clerical: $27.82

Legal: $101.26

Consultant: $54.11. 

Estimating Capital and Operations and Maintenance (O&M) Costs

The Partners participating in the GreenChill Partnership are not
required to incur any capital costs under the Partnership. The Partners
normally track their program data as a standard business practice. They
are also not required to incur any notable O&M costs since EPA will
encourage them to submit materials electronically and also retain
materials in electronic format to conserve paper. Estimates of O&M costs
reported by pilot Partners were minimal copying, faxing, and mailing
costs ($10.43 for the first year and $4.86 per year for the second and
third years per Partner). 

Table 4 provides the net present value of the total respondent cost and
annualized respondent costs over the three years using 3% and 7%
discount rates. The net present value of total cost is $39,826 with an
average annualized cost of $13,670 using a 3% discount rate and $38,119
with an average annualized cost of $13,575 using a 7% discount rate. 

6(c) Estimating Agency Burden and Costs

EPA used its experience implementing the GreenChill Partnership and
other voluntary programs to develop burden estimates for Agency staff.
Table 5 presents the Agency burden hours and costs per respondent in the
first year as well as for the subsequent two years. Table 6 presents
one-time Agency costs (such as forms and database development and
Partnership conference calls). The hourly labor rates used to determine
the estimated costs to the Agency are consistent with annual labor rates
published in the Federal Register and are based on the 2008 General
Schedule (GS) pay schedule available from the Office of Personnel
Management. To derive 

Table 4. Total respondent burden in Years 1-3 (net present value and
annualized cost, 3% and 7% discount rate)

Information collection activity	Discount rate 3%	Discount rate 7%

	Net present value of total cost 

(3 years, 2008$)	Annualized cost per year 

(2008$)	Net present value of total cost 

(3 years, 2008$)	Annualized cost per year 

(2008$)

Partnership Agreement





Review the Partnership Agreement	$3,444.11	$1,182.13	$3,319.45	$1,182.13

Complete the Partnership Agreement and obtain signature of senior
official	$2,048.84	$703.23	$1,974.68	$703.23

Send the completed Partnership Agreement to EPA via fax, mail, or
online, and file a copy	$249.57	$85.66	$240.54	$85.66

Subtotal	$5,742.52	$1,971.03	$5,534.68	$1,971.03

GreenChill Stocks and Emissions Report





Select base year and aggregate records on refrigerant stocks and
emissions	$6,608.09	$2,268.12	$6,317.71	$2,249.88

Fill out and sign GreenChill Stocks and Emissions Report	$3,470.71
$1,191.26	$3,316.96	$1,181.25

Send the completed GreenChill Stocks and Emissions Report to Van Baxter
at ORNL via fax, mail, or online, and file a copy	$1,073.95	$368.62
$1,026.95	$365.72

Subtotal	$11,152.76	$3,828.00	$10,661.62	$3,796.85

Corporate Refrigerant Management Plan





Develop an emissions reduction goal	$8,608.87	$2,954.85	$8,224.64
$2,928.98

Fill out Corporate Refrigerant Management Plan	$8,652.80	$2,969.93
$8,277.23	$2,947.71

Gain corporate approval of the Corporate Refrigerant Management Plan
$4,627.58	$1,588.34	$4,425.07	$1,575.87

Send the Corporate Refrigerant Management Plan to EPA via fax, mail, or
online, and file a copy	$1,041.68	$357.54	$996.10	$354.73

Subtotal	$22,930.93	$7,870.66	$21,923.03	$7,807.30

Total	$39,826.21	$13,669.69	$38,119.32	$13,575.17

Notes: Total values may not sum due to rounding. Four new partners are
assumed per year over the three-year period.



– Year 1

Partnership Agreement







	Answer questions posed by potential Partners regarding the Partnership
Agreement	0.0	0.3	0.0	0.0	0.3	$15.21	$0.00

Review completed Partnership Agreement, record/enter information into a
database and EPA’s GreenChill Program Web site 	0.0	0.3	0.0	0.0	0.3
$15.21	$0.00

Sign Partnership Agreement and return to partner	0.3	0.0	0.0	0.0	0.3
$20.74	$1.00

Subtotal	0.3	0.5	0.0	0.0	0.8	$51.15	$1.00

GreenChill Stocks and Emissions Report







	Review completed GreenChill Stocks and Emissions Report 	0.0	16.0	0.0
0.0	16.0	$973.14	$0.00

Enter data in a tracking system	0.0	8.0	0.0	0.0	8.0	$486.57	$0.00

Subtotal	0.0	24.0	0.0	0.0	24.0	$1,459.72	$0.00

Corporate Refrigerant Management Plan







	Answer questions posed by Partner regarding the Corporate Refrigerant
Management Plan	0.0	0.3	0.0	0.0	0.0	$15.21	$0.00

Review company submission	0.0	0.3	0.0	0.0	0.0	$15.21	$0.00

File company submission	0.0	0.3	0.0	0.0	0.0	$15.21	$0.00

Develop charts of projected emission reductions based on goals and
compare Partner results to Partner goals (beginning in the second year
of submission)	0.0	0.3	0.0	0.0	0.0	$15.21	$0.00

Subtotal	0.0	1.0	0.0	0.0	0.0	$60.82	$0.00

Total	0.3	25.5	0.0	0.0	24.8	$1,571.69	$1.00

Notes: There are no capital start-up costs associated with this
information collection. Hours for Van Baxter at ORNL are included in the
Technical Staff labor category. Total values may not sum due to
rounding.



– Years 2 and 3

Partnership Agreement







	Answer questions posed by potential Partners regarding the Partnership
Agreement	0.0	0.0	0.0	0.0	0.0	$0.00	$0.00

Review completed Partnership Agreement, record/enter information into a
database and EPA’s GreenChill Program Web site	0.0	0.0	0.0	0.0	0.0
$0.00	$0.00

Sign Partnership Agreement and return to partner	0.0	0.0	0.0	0.0	0.0
$0.00	$0.00

Subtotal	0.0	0.0	0.0	0.0	0.0	$0.00	$0.00

GreenChill Stocks and Emissions Report







	Review completed GreenChill Stocks and Emissions Report 	0.0	12.0	0.0
0.0	12.0	$729.86	$0.00

Enter data in a tracking system	0.0	6.0	0.0	0.0	6.0	$364.93	$0.00

Subtotal	0.0	18.0	0.0	0.0	18.0	$1,094.79	$0.00

Corporate Refrigerant Management Plan







	Answer questions posed by Partner regarding the Corporate Refrigerant
Management Plan	0.0	0.0	0.0	0.0	0.0	$0.00	$0.00

Review company submission	0.0	0.3	0.0	0.0	0.3	$15.21	$0.00

File company submission	0.0	0.3	0.0	0.0	0.3	$15.21	$0.00

Develop charts of projected emission reductions based on goals and
compare Partner results to Partner goals (beginning in the second year
of submission)	0.0	0.5	0.0	0.0	0.5	$30.41	$0.00

Subtotal	0.0	1.0	0.0	0.0	1.0	$60.82	$0.00

Total	0.0	19.0	0.0	0.0	19.0	$1,155.61	$0.00

Notes: There are no capital start-up costs associated with this
information collection. Hours for Van Baxter at ORNL are included in the
Technical Staff labor category. Total values may not sum due to
rounding.



Table 6. Agency one time burdens in Year 1, and Years 2 and 3 (hours and
costs per respondent per submission)

Information collection activity	Manager	Technical	Clerical	Legal	Total
hours	Labor 

costs	Annual O&M costs

	Hours and costs per respondent per submission – Year 1

Partnership Agreement







	Develop Partnership Agreement and distribute to Partners	0.0	15.0	0.0
3.0	18.0	$1,168.72	$0.00

Subtotal	0.0	15.0	0.0	3.0	18.0	$1,168.72	$0.00

GreenChill Stocks and Emissions Report







	Develop GreenChill Stocks and Emissions Report and distribute to
Partners	0.0	2.0	0.0	0.0	2.0	$121.64	$0.00

Annual conference call to answer questions posed by Partners regarding
annual reporting	0.0	0.5	0.0	0.0	0.5	$30.41	$0.00

Develop data tracking system	0.0	80.0	0.0	0.0	80.0	$4,865.72	$0.00

Aggregate data for tracking program benefits and Partner achievements
0.0	12.0	0.0	0.0	12.0	$729.86	$0.00

Subtotal	0.0	94.5	0.0	0.0	94.5	$5,747.64	$0.00

Total	0.0	109.5	0.0	3.0	112.5	$6,916.35	$0.00

	Hours and costs per respondent per submission – Years 2 and 3

Partnership Agreement







	Develop Partnership Agreement and distribute to Partners	0.0	0.0	0.0
0.0	0.0	$0.00	$0.00

Subtotal	0.0	0.0	0.0	0.0	0.0	$0.00	$0.00

GreenChill Stocks and Emissions Report







	Develop GreenChill Stocks and Emissions Report and distribute to
Partners	0.0	0.0	0.0	0.0	0.0	$0.00	$0.00

Annual conference call to answer questions posed by Partners regarding
annual reporting	0.0	0.5	0.0	0.0	0.5	$30.41	$0.00

Develop data tracking system	0.0	0.0	0.0	0.0	0.0	$0.00	$0.00

Aggregate data for tracking program benefits and Partner achievements
0.0	12.0	0.0	0.0	12.0	$729.86	$0.00

Subtotal	0.0	12.5	0.0	0.0	12.5	$760.27	$0.00

Total	0.0	12.5	0.0	0.0	12.5	$760.27	$0.00

Notes: There are no capital start-up costs associated with this
information collection. Hours for Van Baxter at ORNL are included in the
Technical Staff labor category. There are no “one-time” costs
associated with the Corporate Refrigerant Management Plan. Total values
may not sum due to rounding.



hourly estimates, EPA divided annual compensation by 2,080 ( the number
of hours in the Federal work year. EPA then multiplied hourly rates by
the standard government fringe factor of 1.6. EPA estimates an average
hourly labor cost as follows:

Manager: $82.95 (based on GS Level 14 Step 4)

Technical: $60.82 (based on GS Level 12 Step 5)

Clerical: $24.42 (based on GS Level 5 Step 1)

Legal: $85.46 (based on GS Level 14 Step 5).

Since EPA anticipates communicating with Partners primarily
electronically rather than mailing paper, we have included minimal
photocopying and postage costs.

Table 7 presents total Agency burden and costs during each of the three
years covered under this ICR. The total Agency burden hours are
estimated as 287, 287, and 363 for the first, second, and third years,
respectively. Table 8 presents the net present value of the total cost
and annualized costs using a 3% and 7% discount rate. The net present
value of total Agency cost is $55,275 with an average annualized cost of
$18,972 using a 3% discount rate and $53,115 with an average annualized
cost of $18,916 using a 7% discount rate.

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

The universe of each respondent activity varies depending upon the
specific activity. The respondent universe for each information
collection activity associated with EPA GreenChill Partnership Program
is presented and explained separately below. 

Partnership Agreement

EPA estimates that four supermarkets will join the program each year.
EPA conducts two major outreach events a year that appear to result in
two new Partners per event. As shown in Table 3, the annual total
respondent burden for this activity is 21 hours and $1,971.

GreenChill Stocks and Emissions Report

EPA anticipates nine submissions in the first year of this ICR from
current Partners, and 13 and 17 submissions in the second and third
years, based on adding four new Partners a year. As shown in Tables 3
and 4, the annual burden hours for this activity are 35, 52, and 67
hours for the first, second, and third years, with an average annualized
cost of $3,828 using a 3% discount rate and $3,797 using a 7% discount
rate.

Table 7. Total Agency burden in Years 1-3 (hours, labor costs)

Information collection activity	Year 1	Year 2	Year 3

	Total hours	Total 

cost	Total hours	Total 

cost	Total hours	Total 

cost

Partnership Agreement







Develop Partnership Agreement and distribute to Partners 	18.0	$4,674.87
0.0	$0.00	0.0	$0.00

Answer questions posed by potential Partners regarding the Partnership
Agreement	1.0	$60.82	1.0	$60.82	1.0	$60.82

Review completed Partnership Agreements, record/enter information into a
database and EPA’s GreenChill Program Web site	1.0	$60.82	1.0	$60.82
1.0	$60.82

Sign agreement and return to partner	1.0	$86.95	1.0	$86.95	1.0	$86.95

Subtotal	21.0	$4,883.46	3.0	$208.59	3.0	$208.59

GreenChill Stocks and Emissions Report







Develop GreenChill Stocks and Emissions Report and distribute to
Partners	2.0	$121.64	0.0	$0.00	0.0	$0.00

Annual conference call to answer questions posed by Partners regarding
annual reporting 	0.5	$30.41	0.5	$30.41	0.5	$30.41

Review completed GreenChill Stocks and Emissions Reports 	108.0
$6,568.73	172.0	$10,461.30	220.0	$13,380.74

Develop data tracking system 	80.0	$4,865.72	0.0	$0.00	0.0	$0.00

Enter data in a tracking system	54.0	$3,284.36	86.0	$5,230.65	110.0
$6,690.37

Aggregate data for tracking program benefits and Partner achievements
12.0	$729.86	12.0	$729.86	12.0	$729.86

Subtotal	256.5	$15,600.72	270.5	$16,452.23	342.5	$20,831.38

Corporate Refrigerant Management Plan







Answer questions posed by Partners regarding the Corporate Refrigerant
Management Plan	0.0	$0.00	1.0	$60.82	1.0	$60.82

Review company submissions	2.3	$136.85	3.3	$197.67	4.3	$258.49

File company submissions	2.3	$136.85	3.3	$197.67	4.3	$258.49

Develop charts of projected emission reductions based on goals and
compare Partner results to Partner goals (beginning in the second year
of submission)	4.5	$273.70	5.5	$334.52	7.5	$456.16

Subtotal	9.0	$547.39	13.0	$790.68	17.0	$1,033.97

Total	286.5	$17,525.43	286.5	$17,451.50	362.5	$22,073.94

Notes: Total values may not sum due to rounding. Four new partners are
assumed per year over the three-year period.



Table 8. Total Agency burden in Years 1-3 (net present value and
annualized cost, 3% and 7% discount rate)

Information collection activity	Discount rate 3%	Discount rate 7%

	Net present value of total cost 

(3 years, 2008$)	Annualized cost per year 

(2008$)	Net present value of total cost 

(3 years, 2008$)	Annualized cost per year 

(2008$)

Partnership Agreement





Develop Partnership Agreement and distribute to Partners 	$1,168.72
$401.14	$1,168.72	$416.21

Answer questions posed by potential Partners regarding the Partnership
Agreement	$177.20	$60.82	$170.79	$60.82

Review completed Partnership Agreements, record/enter information into a
database and EPA’s GreenChill Program Web site	$177.20	$60.82	$170.79
$60.82

Sign agreement and return to partner	$253.33	$86.95	$244.16	$86.95

Subtotal	$1,776.45	$609.74	$1,754.45	$624.80

GreenChill Stocks and Emissions Report

	 	 

Develop GreenChill Stocks and Emissions Report and distribute to
Partners	$121.64	$41.75	$121.64	$43.32

Annual conference call to answer questions posed by Partners regarding
annual reporting 	$88.60	$30.41	$85.39	$30.41

Review completed GreenChill Stocks and Emissions Reports 	$29,337.96
$10,069.77	$28,032.90	$9,983.16

Develop data tracking system 	$4,865.72	$1,670.08	$4,865.72	$1,732.80

Enter data in a tracking system	$14,668.98	$5,034.88	$14,016.45
$4,991.58

Aggregate data for tracking program benefits and Partner achievements
$2,126.42	$729.86	$2,049.46	$729.86

Subtotal	$51,209.33	$17,576.75	$49,171.57	$17,511.13

Corporate Refrigerant Management Plan

	 	 

Answer questions posed by Partners regarding the Corporate Refrigerant
Management Plan	$116.38	$39.95	$109.97	$39.16

Review company submissions	$572.41	$196.47	$547.36	$194.93

File company submissions	$572.41	$196.47	$547.36	$194.93

Develop charts of projected emission reductions based on goals and
compare Partner results to Partner goals (beginning in the second year
of submission)	$1,028.45	$353.00	$984.76	$350.70

Subtotal	$2,289.66	$785.89	$2,189.45	$779.71

Total	$55,275.44	$18,972.37	$53,115.47	$18,915.64

Notes: Total values may not sum due to rounding. Four new partners are
assumed per year over the three-year period.



Corporate Refrigerant Management Plan

EPA anticipates nine submissions in the first year of this ICR from
current Partners, and 13 and 17 submissions in the second and third
years, based on adding four new Partners a year. As shown in Tables 3
and 4, the annual burden hours for this activity are 66, 98, and 127
hours for the first, second, and third years, with an average annualized
cost of $7,871 using a 3% discount rate and $7,807 using a 7% discount
rate.

Total Burden and Costs

Table 3 shows the aggregate annual respondent burden and costs for the
information collection activities associates with EPA’s GreenChill
Partnership. Total estimated respondent burden hours are 121, 172, and
216 for the first, second, and third years, totaling 508 hours over the
three years. As shown in Table 4, the net present value of total cost is
$39,826 with an average annualized cost of $13,670 using a 3% discount
rate and $38,119 with an average annualized cost of $13,575 using a 7%
discount rate.

6(e) Bottom Line Burden Hours and Costs Tables

Tables 9 and 10 summarize the total estimated annual burden hours and
costs for respondents and for the Agency. Total estimated respondent
burden hours are 121, 172, and 216 for the first, second, and third
years, totaling 508 hours over the three years. The net present value of
total cost is $39,826 with an average annualized cost of $13,670 using a
3% discount rate and $38,119 with an average annualized cost of $13,575
using a 7% discount rate. Total estimated Agency burden hours are 287,
287, and 363 for the first, second, and third years, totaling 936 hours
over the three years. The net present value of total Agency cost is
$55,275 with an average annualized cost of $18,972 using a 3% discount
rate and $53,115 with an average annualized cost of $18,916 using a 7%
discount rate. Total burden for all information collection activities
under the GreenChill Partnership for the three years amounts to 408,
458, and 578 hours for the first, second, and third years, resulting in
an aggregate combined total of 1,444 hours with a net present value of
total cost of $95,102 with an average annualized cost of $32,642 using a
3% discount rate and $91,235 with an average annualized cost of $32,491
using a 7% discount rate.

6(f) Reasons for Change in Burden

This is the first ICR for the GreenChill Partnership.

Table 9. Total respondent and Agency bottom line burden (hours, labor
costs)

All information collection activities	Year 1	Year 2	Year 3

	Total hours	Total 

cost	Total hours	Total 

cost	Total hours	Total 

cost

Respondent 	121.2	$9,948.50	171.6	$13,887.79	215.7	$17,392.84

Agency	286.5	$17,525.43	286.5	$17,451.50	362.5	$22,073.94

Total	407.7	$27,473.93	458.1	$31,339.29	578.2	$39,466.78

Notes: Total values may not sum due to rounding. Four new partners are
assumed per year over the three-year period.



Table 10. Total bottom line burden (net present value and annualized
cost, 3% and 7% discount rate)

All information collection activities	Discount rate 3%	Discount rate 7%

	Net present value of total cost 

(3 years, 2008$)	Annualized cost per year 

(2008$)	Net present value of total cost

(3 years, 2008$)	Annualized cost per year 

(2008 $)

Respondent 	$39,826.21	$13,669.69	$38,119.32	$13,575.17

Agency	$55,275.44	$18,972.37	$53,115.47	$18,915.64

Total	$95,101.65	$32,642.06	$91,234.80	$32,490.81

Notes: Total values may not sum due to rounding. Four new partners are
assumed per year over the three-year period.



6(g) Burden Statement

The annual reporting burden for each Partner for this information
collection is estimated to be 18.1 hours for the first year and 11.0
hours per year for the second and third years. 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 forms; 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-2008-0655, which is available for online viewing at  
HYPERLINK "www.regulations.gov"  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, DC. The EPA Docket
Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday
through Friday, excluding legal holidays. The telephone number for the
Reading Room is (202) 566-1744, and the telephone number for the Air
Docket is (202) 566-1742. An electronic version of the public docket is
available at   HYPERLINK "www.regulations.gov"  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, comments can be sent 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. Please include the EPA Docket ID Number EPA-HQ-OAR-2008-0655 and
OMB Control Number 2060-New in any correspondence.

 There are limited exceptions from the U.S. Class I ODS phaseout for
critical and essential uses as approved by the Parties to the Montreal
Protocol. 

. ODS refrigerants currently in use and their alternatives are also
potent GHGs.

. Food Marketing Institute. 2008. Key Facts: Number of Stores.
Available:   HYPERLINK
"http://www.fmi.org/facts_figs/keyfacts/?fuseaction=stores" 
http://www.fmi.org/facts_figs/keyfacts/?fuseaction = stores . Accessed
5/28/2009.

. Chain Store Guide. 2009. Grocery Industry Market Share Industry
Summary. Available:   HYPERLINK
"http://www.csgis.com/static_content/pdf/GROCES09.pdf" 
http://www.csgis.com/static_content/pdf/GROCES09.pdf . Accessed May 28,
2009. 

. Newly produced, not “used” refrigerant.

. It is standard practice that food retailers have corporate refrigerant
management plans which guide their decisions on when and how to upgrade
or replace their existing refrigeration equipment. These plans are often
formalized as official company strategies, but can also be a set of
informal practices the company’s employees customarily follow.
GreenChill Partners are not expected to develop new plans for managing
refrigerants; they will, however, be expected to describe their formal
or informal plans to EPA. 

.   HYPERLINK "http://www.bls.gov/oes/current/naics4_445100.htm" 
http://www.bls.gov/oes/current/naics4_445100.htm ;   HYPERLINK
"http://www.bls.gov/oes/current/naics4_541100.htm" 
http://www.bls.gov/oes/current/naics4_541100.htm ;   HYPERLINK
"http://www.bls.gov/oes/current/naics4_541600.htm#b11-0000" 
http://www.bls.gov/oes/current/naics4_541600.htm#b11-0000 . Accessed
5/28/2009.

. Salary Table 2008-DCB Incorporating the 2.50% General Schedule
Increase and a Locality Payment of 20.89% for the Locality Pay Area of
Washington-Baltimore-Northern Virginia, DC-MD-VA-WV-PA. 2008. Available:
  HYPERLINK "http://www.fedjobs.com/pay/washington.html" 
http://www.opm.gov/oca/08tables/html/dcb.asp . Accessed 6/5/2009.

. Note that numbers do not add correctly due to rounding. 

. Ibid. 

. Ibid.

January 6, 2010

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