This ICR is disapproved. This collection request is intended to measure the effects of the Responsible Appliance Disposal Program, including the effects on ozone depleting substance emission avoided, greenhouse gas emission avoided, energy savings realized and consumer savings realized. The method proposed for this collection is not appropriate or sound. In particular, the method fails to address: (1) the establishment of appropriate baseline; (2) whether appropriate entity boundary is used; (3) whether the reported emissions avoided, savings realized and other reductions from individual respondents can be added to produce aggregate estimates for the program. Given these methodological limitations, any data collected under this information collection request would not have practical utility.
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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 other substances that may be harmful to the environment if not properly treated at equipment end of life, including 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. Currently, no Federal or State laws require that ODS foam blowing agent 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; 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. 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. Program participation 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 individuacomponents. 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.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Form 5900-32 Responsible Appliance Disposal Program
2254ss01.doc
Responsible Appliance Disposal Program