| National Refrigerant Recycling and Emissions Reduction Program, EPA ICR Number: 1626.12, OMB Control Number: 2060-0256 |
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| Annual Respondent Burden and Cost |
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| The following tables illustrate the calculations performed to calculate the annual respondent burden and cost for the National Refrigerant Recycling and Emissions Reduction Program. |
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| Assumptions |
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| Average Administrative Cost (Labor + Overhead) |
$44.31 |
EPA used the median hourly earnings of $21.10 for heating, air-conditioning, and refrigeration mechanics and installers from the Bureau of Labor Statistics (http://www.bls.gov/oes/current/oes499021.htm). EPA then multiplied this number by 110% for overhead ($21.10 x 1.10 = $23.21). |
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| Respondent Tally |
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| Reporting |
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| Activity |
Number of Respondents |
Number of Responses per Respondent |
Burden Hours (Time) per Response |
All Respondents |
Per Respondent |
Respondent |
| Annual Burden Hours |
Annual Labor Costs |
Number of Annual Responses |
Annual Burden Hours |
Annual Labor Cost |
| Refrigerant Recovery/ Recycling Equipment Testing Organizations - Submit reports on approved equipment (including new model lines and failed retests/inspections) |
2 |
1 |
4.00 |
8.00 |
$354.48 |
2 |
4.00 |
$177.24 |
Refrigerant Recovery/ Recycling Equipment Testing Organization |
| Certification by Owners of Refrigerant Recovery/ Recycling Equipment (or Service Established) that Change Ownership or Enter the Market Compile information, complete certification requirements |
2,250 |
1 |
1.00 |
2,250.00 |
$99,697.50 |
2,250 |
1.00 |
$44.31 |
Service Establishments |
| Certification by Disposal Establishments that change Ownership or Enter the Market |
375 |
1 |
1.00 |
375.00 |
$16,616.25 |
375 |
1.00 |
$44.31 |
Disposal Establishments |
| Certification by Refrigerant Reclaimers that Change Ownership or Enter the Market |
4 |
1 |
5.00 |
20.00 |
$886.20 |
4 |
5.00 |
$221.55 |
Refrigerant Reclaimers |
| Reclaimer Annual Activity Report |
60 |
1 |
5.00 |
300.00 |
$13,293.00 |
60 |
5.00 |
$221.55 |
Refrigerant Reclaimers |
| Technician Certification Programs Applying for Approval |
5 |
1 |
5.00 |
25.00 |
$1,107.75 |
5 |
5.00 |
$221.55 |
Technician Certification Programs |
| Biannual Reporting by Existing Technician Certification Programs |
91 |
2 |
1.00 |
182.00 |
$8,064.42 |
182 |
2.00 |
$88.62 |
Technician Certification Programs |
| Owners/operators of appliances w/charge sizes >50 lbs prepare & submit requests for extensions to 30-day repair timeline |
15 |
1 |
0.50 |
7.50 |
$332.33 |
15 |
0.50 |
$22.16 |
Owners |
| Owners/operators of appliances w/charge sizes >50 lbs prepare & submit requests for extensions to 1 yr retrofit/retire timeline |
5 |
1 |
0.50 |
2.50 |
$110.78 |
5 |
0.50 |
$22.16 |
Owners |
| SUBTOTAL |
2,807 |
varies |
varies |
3,170.00 |
$140,462.70 |
2,898 |
varies |
varies |
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| Recordkeeping |
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| Activity |
Number of Respondents |
Number of Responses per Respondent |
Burden Hours (Time) per Response |
All Respondents |
Per Respondent |
Respondent |
| Annual Burden Hours |
Annual Labor Costs |
Number of Annual Responses |
Annual Burden Hours |
Annual Labor Cost |
| Refrigerant Recovery/ Recycling Equipment Testing Organizations - Maintain records of refrigerant recovery/recycling equipment tested and its performance |
2 |
1 |
0.125 |
0.25 |
$11.08 |
2 |
0.125 |
$5.54 |
Refrigerant Recovery/ Recycling Equipment Testing Organization |
| Maintenance of copies of signed statements of previous refrigerant recovery by disposal establishments |
7,500 |
260 |
0.050 |
97,500.00 |
$4,320,225.00 |
1,950,000 |
13 |
$576.03 |
Disposal Establishments |
| Reclaimer recordkeeping |
60 |
50 |
0.125 |
375.00 |
$16,616.25 |
3,000 |
6.25 |
$276.94 |
Refrigerant Reclaimers |
| Refrigerant wholesalers recordkeeping for refrigerant sales, including maintenance of technician certification cards from purchasers employing at least one certified technician |
200,000 |
25 |
0.033 |
165,000 |
$7,311,150.00 |
5,000,000 |
0.825 |
$36.56 |
Refrigerant Wholesalers |
| Record keeping by Existing Technician Certification Programs |
91 |
1 |
5.000 |
455.00 |
$20,161.05 |
91 |
5 |
$221.55 |
Technician Certification Programs |
| Technicians Aquiring Certification Cards |
30,000 |
1 |
0.017 |
501.00 |
$22,199.31 |
30,000 |
0.0167 |
$0.74 |
Technicians |
| Technicians Maintaining Certification Cards |
300,000 |
1 |
0.017 |
5,010.00 |
$221,993.10 |
300,000 |
0.0167 |
$0.74 |
Technicians |
| Persons servicing appliances w/charge sizes >50 lbs provide invoices to appliance owners/operators |
20,500 |
1 |
0.025 |
512.50 |
$22,708.88 |
20,500 |
0.025 |
$1.11 |
Technicians |
| Owners/operators of appliances w/charge sizes >50 lbs maintain purchase and service records |
20,500 |
1 |
0.025 |
512.50 |
$22,708.88 |
20,500 |
0.025 |
$1.11 |
Owners |
| Owners/operators of appliances w/charge sizes >50 lbs - Maintain information on purged/destroyed refrigerant |
2 |
1 |
0.025 |
0.05 |
$2.22 |
2 |
0.025 |
$1.11 |
Owners |
| Owners/operators of appliances w/charge sizes >50 lbs - Develop/Maintain plan to retire/replace or retrofit equipment, as applicable |
5,000 |
1 |
8.000 |
40,000.00 |
$1,772,400.00 |
5,000 |
8 |
$354.48 |
Owners |
| Owners/operators of appliances w/charge sizes >50 lbs - Maintain information on the calculation of the full charge using a range, as applicable |
200,000 |
1 |
0.025 |
5,000.00 |
$221,550.00 |
200,000 |
0.025 |
$1.11 |
Owners |
| Owners/operators of appliances w/charge sizes >50 lbs - Maintain reports on the results of verification tests (IPR and in limited instances federally owned equipment) |
100,025 |
1 |
0.025 |
2,500.63 |
$110,802.69 |
100,025 |
0.025 |
$1.11 |
Owners |
| SUBTOTAL |
883,680 |
varies |
varies |
317,367 |
$14,062,528.45 |
7,629,120 |
varies |
varies |
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Total Number of Respondents |
Total Number of Annual Responses |
Total Annual Hour Burden |
Total Annual Labor Costs |
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883,680 |
7,632,018 |
320,537 |
$14,202,991 |
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| National Refrigerant Recycling and Emissions Reduction Program, EPA ICR Number: 1626.12, OMB Control Number: 2060-0256 |
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| Annual Agency Burden and Cost |
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| The following table illustrates the calculations performed to calculate the annual agency burden and cost for the National Refrigerant Recycling and Emissions Reduction Program. |
| Assumptions |
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| Agency Burden Cost |
$32.18 |
The hourly rate for EPA staff at the GS-9 Step 1 level is $20.11 per hour (see the GS salary schedule at http://www.opm.gov/oca). EPA then multiplied the hourly rate by the standard government benefits and overhead multiplication factor of 1.6 to estimate the annual Agency burden and cost ($20.11 x 1.6). |
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| Agency Tally |
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| Reviewing and Responding |
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| Activity |
Number of Respondents |
Number of Responses per Respondent |
Agency Burden Hours (Time) to Review each Response |
Total Annual Agency Hours |
Total Agency Labor Costs |
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| Refrigerant Recovery/ Recycling Equipment Testing Organizations - Submit reports on approved equipment (including new model lines and failed retests/inspections) |
2 |
1 |
0.5 |
1.0 |
$32.18 |
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| Certification by Owners of Refrigerant Recovery/ Recycling Equipment (or Service Established) that Change Ownership or Enter the Market Compile information, complete certification requirements |
2,250 |
1 |
0.25 |
562.5 |
$18,099.00 |
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| Certification by Disposal Establishments that change Ownership or Enter the Market |
375 |
1 |
0.25 |
93.75 |
$3,016.50 |
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| Certification by Refrigerant Reclaimers that Change Ownership or Enter the Market |
4 |
1 |
1.0 |
4.0 |
$128.70 |
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| Reclaimer Annual Activity Report |
60 |
1 |
1.0 |
60.0 |
$1,930.56 |
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| Technician Certification Programs Applying for Approval |
5 |
1 |
2.0 |
10.0 |
$321.76 |
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| Biannual Reporting by Existing Technician Certification Programs |
91 |
2 |
1.0 |
182.0 |
$5,856.03 |
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| Owners/operators of appliances w/charge sizes >50 lbs prepare & submit requests for extensions to 30-day repair timeline |
15 |
1 |
0.5 |
7.5 |
$241.32 |
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| Owners/operators of appliances w/charge sizes >50 lbs prepare & submit requests for extensions to 1 yr retrofit/retire timeline |
5 |
1 |
1.0 |
5.0 |
$160.88 |
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| SUBTOTAL |
2,807 |
10 |
7.5 |
925.75 |
$29,786.93 |
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| National Refrigerant Recycling and Emissions Reduction Program, EPA ICR Number: 1626.12, OMB Control Number: 2060-0256 |
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| Summary of Annual Respondent Burden and Cost By Respondent |
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| The following tables summarize the total annual burden hours and cost by respondent type. Table 1 provides a summary for all respondents and Table 2 provides a summary on a per respondent basis. |
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| Table 1. Total Annual Burden Hours and Costs (All Respondents) |
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| Repondent |
Reporting (Hours) |
Recordkeeping (Hours) |
Total Hours |
Total Cost |
| Refrigerant Recovery/ Recycling Equipment Testing Organization |
8.00 |
0.25 |
8.25 |
$365.56 |
| Service Establishments |
2,250.00 |
- |
2,250.00 |
$99,697.50 |
| Disposal Establishments |
375.00 |
97,500.00 |
97,875.00 |
$4,336,841.25 |
| Refrigerant Reclaimers |
320.00 |
375.00 |
695.00 |
$30,795.45 |
| Technician Certification Programs |
207.00 |
455.00 |
662.00 |
$29,333.22 |
| Technicians |
- |
6,023.50 |
6,023.50 |
$266,901.29 |
| Owners |
10.00 |
48,013.18 |
48,023.18 |
$2,127,906.88 |
| Refrigerant Wholesalers |
- |
165,000.00 |
165,000.00 |
$7,311,150.00 |
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| Table 2. Total Annual Burden Hours and Costs (Per Respondent) |
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| Repondent |
Reporting (Hours) |
Recordkeeping (Hours) |
Total Hours |
Total Cost |
| Refrigerant Recovery/ Recycling Equipment Testing Organization |
4.00 |
0.13 |
4.13 |
$182.78 |
| Service Establishments |
1.00 |
- |
1.00 |
$44.31 |
| Disposal Establishments |
1.00 |
13.00 |
14.00 |
$620.34 |
| Refrigerant Reclaimers |
10.00 |
6.25 |
16.25 |
$720.04 |
| Technician Certification Programs |
7.00 |
5.00 |
12.00 |
$531.72 |
| Technicians |
- |
0.06 |
0.06 |
$2.59 |
| Owners |
1.00 |
8.10 |
9.10 |
$403.22 |
| Refrigerant Wholesalers |
- |
0.83 |
0.83 |
$36.56 |
| Change in Annual Respondent Burden and Cost |
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| The following table illustrates the change in annual burden between the 2011 and 2014 ICR values. |
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Activity |
2014 ICR Renewal |
2011 ICR |
Burden Change |
Notes |
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Annual Burden Hours |
Annual Labor Costs |
Annual Burden Hours |
Annual Labor Costs |
Burden Hours |
Labor Costs |
| Reporting |
Refrigerant Recovery/ Recycling Equipment Testing Organizations - Submit reports on approved equipment (including new model lines and failed retests/inspections) |
8.00 |
$354.48 |
8.00 |
$320.56 |
- |
$33.92 |
Due to updated labor rates. |
| Certification by Owners of Refrigerant Recovery/ Recycling Equipment (or Service Established) that Change Ownership or Enter the Market Compile information, complete certification requirements |
2,250.00 |
$99,697.50 |
2,250.00 |
$90,157.50 |
- |
$9,540.00 |
Due to updated labor rates. |
| Certification by Disposal Establishments that change Ownership or Enter the Market |
375.00 |
$16,616.25 |
375.00 |
$15,026.25 |
- |
$1,590.00 |
Due to updated labor rates. |
| Certification by Refrigerant Reclaimers that Change Ownership or Enter the Market |
20.00 |
$886.20 |
20.00 |
$801.40 |
- |
$84.80 |
Due to updated labor rates. |
| Reclaimer Annual Activity Report |
300.00 |
$13,293.00 |
245.00 |
$9,817.15 |
55.00 |
$3,475.85 |
The number of reclaimers increased from 49 to 60. |
| Technician Certification Programs Applying for Approval |
25.00 |
$1,107.75 |
25.00 |
$1,001.75 |
- |
$106.00 |
Due to updated labor rates. |
| Biannual Reporting by Existing Technician Certification Programs |
182.00 |
$8,064.42 |
182.00 |
$7,292.74 |
- |
$771.68 |
Due to updated labor rates. |
| Owners/operators of appliances w/charge sizes >50 lbs prepare & submit requests for extensions to 30-day repair timeline |
7.50 |
$332.33 |
10.00 |
$400.70 |
(2.50) |
-$68.38 |
Adjustment of figures to match assumptions described on page 28 of ICR ("EPA estimates the breakdown to be for 15 owners/operators seeking extensions to the 30-day leak repair requirement"). |
| Owners/operators of appliances w/charge sizes >50 lbs prepare & submit requests for extensions to 1 yr retrofit/retire timeline |
2.50 |
$110.78 |
0.50 |
$20.04 |
2.00 |
$90.74 |
Adjustment of figures to match assumptions described on page 28 of ICR ("EPA estimates the breakdown to be … 5 owners/operators seeking extensions to the one-year retrofit requirement"). |
| Recordkeeping |
Refrigerant Recovery/ Recycling Equipment Testing Organizations - Maintain records of refrigerant recovery/recycling equipment tested and its performance |
0.25 |
$11.08 |
0.25 |
$10.02 |
- |
$1.06 |
Due to updated labor rates. |
| Maintenance of copies of signed statements of previous refrigerant recovery by disposal establishments |
97,500.00 |
$4,320,225.00 |
97,500.00 |
$3,906,825.00 |
- |
$413,400.00 |
Due to updated labor rates. |
| Reclaimer recordkeeping |
375.00 |
$16,616.25 |
306.25 |
$12,271.44 |
68.75 |
$4,344.81 |
The number of reclaimers increased from 49 to 60. |
| Refrigerant wholesalers recordkeeping for refrigerant sales, including maintenance of technician certification cards from purchasers employing at least one certified technician |
165,000.00 |
$7,311,150.00 |
165,000.00 |
$6,611,550.00 |
- |
$699,600.00 |
Due to updated labor rates. |
| Record keeping by Existing Technician Certification Programs |
455.00 |
$20,161.05 |
455.00 |
$18,231.85 |
- |
$1,929.20 |
Due to updated labor rates. |
| Technicians Aquiring Certification Cards |
501.00 |
$22,199.31 |
- |
$0.00 |
501.00 |
$22,199.31 |
Activity was previously omitted in 2011 ICR and added to 2014 for completeness. |
| Technicians Maintaining Certification Cards |
5,010.00 |
$221,993.10 |
5,010.00 |
$200,750.70 |
- |
$21,242.40 |
Due to updated labor rates. |
| Persons servicing appliances w/charge sizes >50 lbs provide invoices to appliance owners/operators |
512.50 |
$22,708.88 |
512.50 |
$20,535.88 |
- |
$2,173.00 |
Due to updated labor rates. |
| Owners/operators of appliances w/charge sizes >50 lbs maintain purchase and service records |
512.50 |
$22,708.88 |
512.50 |
$20,535.88 |
- |
$2,173.00 |
Due to updated labor rates. |
| Owners/operators of appliances w/charge sizes >50 lbs - Maintain information on purged/destroyed refrigerant |
0.05 |
$2.22 |
0.05 |
$2.00 |
- |
$0.22 |
Due to updated labor rates. |
| Owners/operators of appliances w/charge sizes >50 lbs - Develop/Maintain plan to retire/replace or retrofit equipment, as applicable |
40,000.00 |
$1,772,400.00 |
40,000.00 |
$1,602,800.00 |
- |
$169,600.00 |
Due to updated labor rates. |
| Owners/operators of appliances w/charge sizes >50 lbs - Maintain information on the calculation of the full charge using a range, as applicable |
5,000.00 |
$221,550.00 |
5,000.00 |
$200,350.00 |
- |
$21,200.00 |
Due to updated labor rates. |
| Owners/operators of appliances w/charge sizes >50 lbs - Maintain reports on the results of verification tests (IPR and in limited instances federally owned equipment) |
2,500.63 |
$110,802.69 |
2,500.63 |
$100,200.04 |
- |
$10,602.65 |
Due to updated labor rates. |
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Total |
320,536.93 |
$14,202,991.15 |
319,912.68 |
$12,818,900.90 |
624.25 |
$1,384,090.25 |
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Percent Change |
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0.20% |
10.80% |
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