1432ss31

Recordkeeping and Periodic Reporting of the Production, Import, Recycling, Destruction, Transhipment, and Feedstock Use of Ozone-Depleting Substances (Renewal)

PART A OF THE SUPPORTING STATEMENT

1. Identification of the Information Collection

(a) Title: Recordkeeping and Periodic Reporting of the Production, Import,

Recycling, Destruction, Transhipment, and Feedstock Use of Ozone-Depleting Substances (Renewal)

OMB Number: 2060-0170

EPA ICR Number: 1432.31

(b) Short Characterization

The Montreal Protocol on Substances that Deplete the Ozone Layer (Protocol) and Title VI of the Clean Air Act Amendments of 1990 (CAA) established limits on total U.S. production, import, and export of Class I and Class II controlled ozone depleting substances (ODSs). Under its Protocol commitments, the United States has been obligated to cease production and import of Class I controlled substances with exemptions for essential uses, critical uses, previously used material, and material that will be transformed, destroyed, or exported to developing countries. The Protocol also establishes limits and reduction schedules leading to the eventual phaseout of Class II controlled substances with similar exemptions beyond the phaseout. Additionally, the CAA has its own limits on production and consumption of controlled substances that EPA must adhere to and enforce.

To ensure the United States’ compliance with the limits and restrictions established by the Protocol and the CAA, the ODS phaseout regulations establish control measures for individual companies. EPA monitors compliance with the limits and restrictions for individual United States companies through the recordkeeping and reporting requirements established in the regulations at 40 CFR part 82, subpart A. To submit required information, regulated entities can download reporting forms from EPA’s stratospheric ozone web site (www.epa.gov/ozone/record/index.html), complete them, and then send them to EPA via mail, fax, or electronically. Upon receipt of the reports, EPA enters and stores the data in the ODS Tracking System. The Tracking System is a secure database that maintains all of the data that is submitted to EPA and allows the Agency to: (1) track over total production and consumption of controlled substances to satisfy conditions of the CAA and fulfill the United States obligations under the Protocol; (2) monitor compliance with limits and restrictions on production, imports, exports, and specific exemptions to the phaseout for individual U.S. companies; and (3) enforce against illegal imports and violations related to the control of Class I and Class II substances. Additionally, reporting on the exemptions allows an entity to retain the benefit of being able to produce or import a controlled Class I ODS beyond the date of complete phaseout.

Pursuant to regulations 40 CFR part 2, subpart B, reporting businesses are entitled to assert a business confidentiality claim covering any part of the submitted business information as defined in 40 CFR Part 2, Subpart B.

Detailed burden and costs calculations for respondents and the Agency are presented in Section 6 of this document. The burden estimates for respondents remain unchanged this ICR. Increases in the average hourly wage rate for industry contributed to higher respondent costs overall.

2. Need For, and Use Of, the Collection

(a) Authority for the Collection

This information collection is authorized under the Section 603(b) of the Clean Air Act and Article 7 of the Protocol. Section 603(b) of the Clean Air Act, “Production, import, and export level reports,” mandates that each person who produces, imports, or exports a Class I controlled substance file a report stating the amount of the substance that was produced, imported, and exported by that person during the preceding reporting period. Article 7 of the Protocol, “Reporting of data,” requires the United States to provide specific data annually on its production, imports, and exports of each controlled substance.

(b) Practical Utility/Users of the Data

The reporting and recordkeeping requirements for Class I ODS will enable EPA to:

1. Ensure compliance with the restrictions on production, import, and export of ozone-depleting substances;

2. Allow exempted production and import for certain uses and the consequent tracking of that production and import;

3. Address industry and Federal concerns regarding the illegal import of mislabeled used controlled substances;

4. Satisfy the United States’ obligations to report data under Article 7 of the Protocol;

5. Fulfill statutory obligations under Section 603(b) of the CAA for reporting and monitoring; and

6. Provide information to report to the U.S. Congress on the production, use, and consumption of Class I controlled substances as statutorily required in Section 603(d) of Title VI of the CAA.

EPA stores and analyzes the information to ensure that companies do not exceed their allowances. Information collected on the production, import, and export of controlled Class I substances is also used to develop the reports provided to the Ozone Secretariat .

Industry representatives and EPA are concerned about claims of fraudulent imports of controlled substances that are mislabeled as used, recycled, or reclaimed. EPA established a petition process to provide information for controlling the import of these materials and act as a deterrent to fraud. Under 40 CFR 82.13(g)(2), companies wanting to import used, recycled, or reclaimed controlled substances must provide detailed information in a petition about the previous and future intended use of the substance.

3. Non duplication, Consultation, and Other Collection Criteria

(a) Non duplication

All information requested from respondents under this ICR is required by statute (CAA §603(b)), and is unavailable from other sources because it is proprietary

(b) Public Notice Required Prior to ICR submission to OMB

A request for public comment for the renewal of this ICR was published in the Federal Register on May 1, 2015 (80 FR 24917). EPA received no comments by the June 30, 2015 deadline.

(c) Consultations

Recordkeeping and reporting requirements were established in the original publication of the CFC phaseout and methyl bromide rules. This ICR (number 1432.31) does not add new recordkeeping or reporting requirements. To assess the current burden, EPA consulted with three stakeholders, all of whom confirmed our burden calculations.

(d) Effects of Less Frequent Collection

Less frequent collection of data would compromise EPA’s ability to meet statutory requirements under Section 603 of the CAA to monitor production, import, and export levels. Further, less frequent collection of information would hinder EPA’s ability to identify regulation violations.

Less frequent collection of data would also potentially place the United States in a non-compliance status under the Protocol. Quarterly reporting provides EPA with the necessary time to take action if an individual reporting person or the United States as a whole were to begin to exceed the Protocol’s production, import, or export limits or the limits established in Section 604 of the CAA.

(e) General Guidelines

This rule does not exceed any of the OMB guidelines found at 5 CFR 1320.5(d)(2).

(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, and will be disclosed to the extent, and by means of procedures, set forth in Subpart B. If no claim of confidentiality is asserted when the information is received by EPA, it may be made available to the public without further notice to the respondents (40 CFR 2.203).

(g) Sensitive Questions

This section is not applicable because this ICR does not involve matters of sensitive nature.

4. The Respondents and the Information Request

(a) Respondents/SIC Codes

The appropriate North American Industry Classification System (NAICS) for potentially affected entities are listed below in Table I¹.

Table I. NAICS Classification of Regulated Entities

Category	NAICS Code
Chemical Producers, Importers, and Exporters (CFCs)	3251- Basic Chemical Manufacturing
Research and Development (Laboratories)	541710- Research and Development in the Physical, Engineering, and Life Sciences
MeBr Producers, Importers, Exporters, Distributors, and Applicators	325320- Pesticide and Other Agricultural Chemical Manufacturing

(b) Information Requested

(i) Data items, including recordkeeping requirements

For the exempted production and import of Class I controlled substances (e.g., essential uses, quarantine and preshipment uses), EPA requires reporting and recordkeeping. All producers, importers, exporters, distributors, applicators, and others identified in 40 CFR 82.13 must record and/or report the following either on a quarterly or annual basis as applicable (note, a comprehensive listing of recordkeeping and reporting requirements is listed in 40 CFR 82.13):

I. Producers:

• production of each controlled substance, including the quantity produced for uses resulting in its transformation and/or destruction by the producer;

• production of each controlled substance under the exemptions for export to Article 5 countries and essential uses;

• the amount of controlled substance sold or transferred during the quarter to a person other than the producer for use in processes resulting in its transformation or eventual destruction;

• for controlled substances provided to another entity for transformation, a copy of an IRS certification or intent to transform the same controlled substance for a particular transformer and a list of additional quantities shipped to that same transformer for the quarter;

• for controlled substances provided to another entity for destruction, a copy of a destruction verification from that entity and a list of quantities shipped to that entity for the quarter;

• a list of U.S. purchasers of controlled substances that exported to an Article 5 country in cases when Article 5 allowances were expended during production;

• a list of the essential-use allowance holders, distributors of laboratory supplies and laboratory customers from whom orders were placed and the quantity of specific essential-use controlled substances requested and produced;

• certifications from essential use allowance holders stating that the controlled substances were purchased solely for specified essential uses and will not be resold or used in any other manufacturing process;

• in the case of laboratory essential uses, certification from distributors of laboratory supplies that controlled substances were purchased for sale to laboratory customers who certify that the substances will only be used for essential laboratory and analytical uses, and will not be resold or used in manufacturing; or, if sales are made directly to laboratories that the controlled substances will only be used for essential laboratory and analytical uses and will not be resold or used in manufacturing.

II. Importers:

• the quantity of each controlled substance imported, either alone or in mixtures, including the percentage of each mixture that consists of a controlled substance;

• the quantity of each controlled substance imported that is used (including recycled or reclaimed) and the information provided in the petition required to import used quantities of Class I controlled substances;

• the quantities of each controlled substance other than transhipments or used, recycled or reclaimed substances imported for use in their transformation or destruction, and the quantity sold for use in processes that result in their destruction or transformation;

• the quantities of controlled substances imported for approved essential or critical uses;

• the amount of controlled substances sold or transferred during the quarter to each person for use in processes resulting in their transformation or eventual destruction;

• for each quantity of a controlled substance imported: the date on which the controlled substance was imported; the port through which it passed; the country from which it was imported; the commodity code for the shipment; the importer number for the shipment; a copy of the bill of lading for the import; the invoice for the import; and the U.S. Customs entry form;

• dated records documenting the sale or transfer of the controlled substance for use in processes resulting in transformation or destruction;

• copies of IRS certifications that the controlled substance will be transformed or destruction verifications that it will be destroyed;

• dated records of the quantity of controlled substances being purchased for essential and laboratory uses or for eventual sale to laboratories that certify that controlled substances are for essential laboratory and analytical uses;

• the amount of controlled substances sold or transferred during the quarter to each person for an essential use;

• certifications from essential-use allowance holders stating that the controlled substances were purchased solely for specified essential uses and will not be resold or used in manufacturing; and the certifications from distributors of laboratory supplies that the controlled substances were purchased solely for eventual sale to laboratories that certify the controlled substances are for essential laboratory and analytical uses, or if sales are made directly to laboratories, verifications from laboratories that the controlled substances will only be used for essential laboratory and analytical uses and will not be resold or used in manufacturing;

• in the case of laboratory essential uses, a certification from distributors of laboratory supplies that controlled substances were purchased for sale to laboratory customers who certify that the substances will only be used for laboratory applications and will not be resold or uses in manufacturing;

• in the case of importing a container with a heel, the amount brought into the United States with a certification that the residual amount in each shipment is less than 10 percent of the volume of the container and the fate of the container; a report indicating the final disposition of each shipment must also be submitted;

• in the case of importing a used substance, a copy of the petition submitted, the EPA non-objection notice, and the bill of lading for the import.

III. Exporters:

• names and addresses of the exporter and the recipient of the exports;

• the exporter’s Employer Identification Number;

• for each export: the type and quantity of each controlled substance exported and what percentage, if any, of the controlled substance is used, recycled or reclaimed; the date on which, and the port from which, the controlled substances were exported to the United States or its territories; the country to which the controlled substances were exported; the amount exported to each Article 5 country, and the commodity code of the controlled substance shipped;

• the invoice or sales agreement containing language similar to the Internal Revenue Service Certificate that the purchaser or recipient of imported controlled substances, or destruction verifications that the purchaser or recipient intends to destroy the controlled substances, or the certification that the purchaser or recipient and the eventual applicator will only us the material for QPS applications.

IV. Persons that destroy Class I controlled substances:

• a one time report stating the destruction unit’s efficiency and the methods used to record the volume destroyed and those used to determine destruction efficiency and the name of other relevant federal or state regulations that may apply to the destruction process.

V. Persons that purchase/receive and subsequently destroy Class I substances that were originally produced without expending allowances:

• a destruction verification (to the producer or importer) containing the following:

• the identity and address of the person intending to destroy controlled substances;

• indications of whether those controlled substances will be completely destroyed, or less than completely destroyed, in which case the destruction efficiency at which such substances will be destroyed must be included;

• period of time over which the person intends to destroy controlled substances;

• signature of the verifying person;

• the name and quantities of Class I controlled substances that were destroyed at the end of the control period.

VI. Persons that transform Class I controlled substances:

• the name and quantities of Class I controlled substances transformed at the end of the control period;

• in cases where Class I controlled substances are purchased for transformation, the person who transforms the substances is to provide the producer or importer with an IRS certification that the controlled substances are to be used in processes resulting in their transformation.

VII. Persons that transship Class I substances:

• records that indicate that the shipment originated in a foreign country destined for another foreign country, and does not enter interstate commerce with the United States.

VIII. Persons allocated essential-use allowances:

• quantities of each controlled substance received from each producer and/or each importer during that quarter and the country from which the controlled substance was imported;

IX. Distributors of laboratory supplies receiving controlled substances under the global laboratory essential use exemption:

• quantities received of each controlled substance from each producer or importer;

• quantities of each controlled substance purchased by each laboratory customer whose certification was previously provided to the distributor;

• in cases where the distributor sells the Class I controlled substances as reference standards for calibrating equipment, the distributor must submit the quantity of each controlled substance purchased by each laboratory customer whose certification was previously provided to the distributor.

X. Persons that distribute quarantine and preshipment methyl bromide:

• certifications provided to the producer or importer that quantities received that were produced or imported solely for QPS applications under the exemptions will be used only for quarantine applications or preshipment applications;

• certifications from applicators, prior to delivery of the quantity, that the quantity of methyl bromide ordered will be used solely for QPS applications;

• the total quantity delivered to applicators in which certifications were received that state the methyl bromide would be use solely for QPS applications.

XI. Persons that apply quarantine and preshipment methyl bromide:

• a document from the commodity owner, shipper or their agent requesting the use of methyl bromide citing the regulatory requirement that justifies its use;

• a copy of the certification (provided to the distributor before a shipment) that the quantity of controlled substances will be used only for QPS applications.

XII. QPS commodity owner, shipper, or their agent:

• records for each request, certifying knowledge of the requirements associated with the exemption for QPS applications; the record must include the certifying language listed in the regulation.

XIII. Transfers of allowances for Class I controlled substances:

• in cases of transfers of essential-use CFCs:

• the specific MDI products that the transferee plans to produce with the transferred CFCs;

• the country(ies) where the CFC MDI produced with the transferred essential-use CFCs will be sold if other than in the United States;

• certification that the essential-use CFCs will be used in the production of essential MDIs; if the MDIs are to be sold in the United States, the certification must state that MDIs produced with the transferred essential-use CFCs are listed as essential and were approved by the Food and Drug Administration before December 31, 2000; if the MDIs produced with the essential-use CFCs are to be sold outside the United States, the transferee must verify that the MDIs produced with the essential-use CFCs are considered essential by the importing country;

• a letter from the transferor stating that it concurs with the terms of the transfer as requested by the transferee;

• in cases where the trade is international:

• a signed document from the principal diplomatic representative in the Party’s embassy in the United States stating that the appropriate authority within the nation has approved the transfer of the essential-use CFCs.

XIV. Persons wanting to import used Class I controlled substance

• a petition containing:

• name and quantity in kilograms of the used controlled substance to be imported;

• name and address of the importer, the importer ID number, the contact person, and the phone number;

• name, address, contact person, phone number and fax number of all previous source facilities from which the used controlled substance was recovered;

• a detailed description of the previous use of the controlled substance at each source facility and a best estimate of when the specific controlled substance was put into the equipment at each source facility, and, when possible documents indicating the date the material was put into the equipment;

• a list of the name, make and model number of the equipment from which the material was recovered at each source facility;

• name, address, contact person, phone number and fax number of the exporter and of all persons to whom the material was transferred or sold after it was recovered from the source facility;

• the U.S. port of entry for the import, the expected date of shipment and the vessel transporting the chemical; if at the time of submitting a petition the importer does not know the U.S. port of entry, the expected date of shipment and the vessel transporting the chemical, and the importer receives a non-objection notice for the individual shipment in the petition, the importer is required to notify the Administrator of this information prior to the actual U.S. Customs entry of the individual shipment;

• a description of the intended of the used controlled substance, and, when, possible, the name, address, contact person, phone number and fax number of the ultimate purchaser in the United States;

• name, address, contact person, phone number and fax number of the U.S. reclamation facility, where applicable; if someone at the source facility recovered the controlled substance from the equipment, the name and phone and fax numbers of that person;

• if the imported controlled substance was reclaimed in a foreign Party, the name, address, contact person and fax number of any or all foreign reclamation facility(ies) responsible for reclaiming the cited shipment;

• an export license from the appropriate government agency in the country of export and, if recovered in another country, the export license from the appropriate government agency in that country;

• if the imported used controlled substance is intended to be sold as a refrigerant in the U.S., the name and address of the U.S. reclaimer who will bring the material to the standard required under Section 608 of the CAA, if not already reclaimed to those specifications;

• a certification of accuracy of the information submitted in the petition.

In addition, all entities may be required to provide other such information that the Administrator may reasonably require to comply with requests from the Ozone Secretariat seeking information required by decisions taken by the Parties to the Montreal Protocol. All records and reports must comply with requirements for Class I controlled substances in Subpart A of the regulations. Reports and records associated with the reports listed above must be kept for three years. All amounts must be reported in kilograms. These recordkeeping requirements pertain to original documents that are held by companies in the normal course of conducting business such as Customs entry forms, accounts of daily production runs, sales invoices, and bills of lading. Information from these recordkeeping documents is summarized in reports. Recordkeeping requirements are designed to aid EPA in compliance monitoring, site inspection, and enforcement actions.

(ii) Respondent Activities

Persons that produce, import, export, distribute, supply, transform, destroy, and apply controlled Class I ODS are to maintain records and report to EPA or persons involved in transactions on a quarterly, annual, or transactional basis as mandated by applicable sections of the regulations. All records and reports must comply with applicable requirements specified in: §82.12(d) (“Transfers of essential-use CFCs”), §82.13 (“Recordkeeping and reporting requirements for Class I controlled substances.”). These records and copies of reports are to be maintained for three years.

5. The Information Collected - Agency Activities, Collection Methodology, and Information Management

(a) Agency Activities

• Enter, maintain, and manage information submitted from companies in the ODS Tracking System;

• Respond to companies submitting tracking/monitored information to confirm transactions and provide allowance balances;

• Review and respond to petitions submitted to import used Class I controlled substances;

• Review information and conduct compliance monitoring activities related to restrictions on production, import, export, transformation, and destruction of Class I controlled substances for individual companies by comparing data with other sources of information;

• Inspect records maintained by producers, importers, exporters, transformers, and destroyers of ODS;

• Review information in the Tracking System to ensure that the United States is not exceeding its obligations under the Montreal Protocol which limits production and consumption of controlled ODS;

• Review information in the Tracking System to ensure exempted production and imports do not exceed limits statutorily set in Section 604 of the CAA;

• Compile reports mandated by United States obligations under the Montreal Protocol and the CAA, including reports to Congress and the Ozone Secretariat.

(b) Collection Methods

EPA provides reporting forms for regulated participants to use to report the required information. Reporting forms for Class I controlled substances, as well as guidance on completing the forms, are available on EPA’s website at http://epa.gov/ozone/record/classone.html. Reporting forms can be sent to EPA in hard copy form. EPA also provides the option for some reports to be submitted electronically and is expanding electronic reporting opportunities. While the use of the reporting forms is voluntary, they are used by most reporters.

(c) Small Entity Flexibility

Much of this information collection is required by statute. Additional information collection is undertaken to support the United States’ reporting obligations under the Protocol. The information collection is required to 1) ensure essential-use material is available to stakeholders, 2) develop these nationally and internationally mandated reports, and 3) maintain compliance with Sections 604 and 606 of the CAA.

The burden on all affected entities, and especially the burden on small entities, has been reduced to every extent possible. Laboratories, the only small entities required to submit information, are required to certify purchases of exempted Class I controlled substances once per year, indicating that they will only be used for laboratory or analytical purposes and not be resold, and identifying the specific use to which the substances will be put. This requirement is to ensure proper use of exempted production and import and to allow the United Sates to report specific information to the Secretariat to the Protocol regarding the use of ODS for laboratory purposes as required under Annex II of Decision VI/9. All other respondents to the program are large companies.

(d) Collection Schedule

• Producers, importers, exporters of methyl bromide, laboratory suppliers, and distributors of QPS methyl bromide report to EPA quarterly (45 days after the end of each quarter);

• Exporters of non-methyl bromide Class I controlled substances, and persons that destroy and transform Class I controlled substances (including methyl bromide), report to EPA annually (45 days after the end of the control period);

• Persons trading essential use CFCs or importing used Class I controlled substances via petition submit reports to EPA on a transactional basis.

• All entities may be required to provide other such information that the Administrator may reasonably require. The Agency anticipates this to occur less than annually per prospective respondent.

• There will also be infrequent requests from EPA to implement the program or address compliance issues.

6. Estimating the Burden and Cost of Collection

(a) Estimating Respondent Burden

The basis of the analysis is the identification of the principal steps involved in complying with EPA recordkeeping and reporting requirements and the estimated burden associated with each step. EPA identified 18 reporting activities which contain all information mandated by EPA’s regulations (see Table II. Respondent Burden for details). EPA estimated the number of respondents per reporting activity based on the quantity of respondents that submitted reports over the last several years. The number of reports submitted per year is either four (quarterly), one (annually), or other (per transaction). EPA estimated the amount of time for data compilation and report preparation by analyzing past reporting practices and consultation with the regulated communities.

Table II. Respondent Burden

Collection Activity: Recordkeeping and Reporting	A	B	C	D	E	F	G
	Number of Respondents	Responses per respondent per control period	Total Responses (A x B)	Data Compilation (hours per response)	Report Preparation (hours per response)	Hours per Response (D + E)	Total Hours per year (C x F)
Producer's Report	7	4	28	2	0.5	2.5	70
Importer's Report	5	4	20	4	0.5	4.5	90
Exporter's Report	13	1	13	4	0.5	4.5	58.5
Destruction	7	1	7	4	0.5	4.5	31.5
Transformation	8	1	8	4	0.5	4.5	36
Essential Use Allowance Holders	0	4	0	4	0.5	4.5	0
Laboratory Supply/Distribution	8	4	32	4	0.5	4.5	144
Transfers of substances (int'l and domestic)	1	1	1	4	0.5	4.5	4.5
Transfers of allowances (int'l and domestic)	0	0	0	4	0.5	4.5	0
QPS MeBr Distributor Report	15	4	60	4	0.5	4.5	270
Petitions for used imports (for destruction)	3	11	33	1	0.5	1.5	49.5
Petitions for used imports (for reuse)	3	7	21	4	0.5	4.5	94.5
SUBTOTAL (REPORTING TO EPA)	70	NA	223	NA	NA	NA	848.5
QPS MeBr Applicator Certification	15	6	90	0.5	0.5	1	90
Commodity Owner, Shipper or Agent Recordkeeping (MeBr)	50	10	500	0.5	0.5	1	500
Lab Certification	1,000	1	1000	0.5	0.5	1	1000
SUBTOTAL (CERTIFICATIONS)	1,065	NA	1,590	NA	NA	NA	1,590
TOTAL	1,135	NA	1,813	NA	NA	NA	2,439
BURDEN HOURS PER YEAR/ RESPONDENT							2.1

(b) Estimating Respondent Costs

(i). Estimating Labor Costs

Table III. Yearly Respondent Costs Calculations

Industry Wage (includes overhead and fringe)	Total Burden Hours	Total Yearly Costs
$106.30	2,439	$259,213
Industry Wage (includes overhead and fringe)	Total Burden Hours/Respondent	Total Yearly Respondent Costs/Respondent
$106.30	2.1	$228

(ii). Estimating Capital and Operations and Management Costs

Operation and maintenance costs include expenses such as photocopying, packaging, and postage. Although variations may occur based on the quantity of the data submitted to EPA as well as the method in which the respondent submits the data (i.e. regular post or express mail), $3.00 was estimated to be the cost per respondent per report. To determine the total capital and operations and management costs, 1,845 (total responses) was multiplied by $3.00 and equaled $5,535.

(iii). Capital and Start-up Costs

Capital and start-up costs were estimated to be $0 because new recordkeeping or reporting requirements have not been added to this ICR. Persons that are required to maintain records and report information have participated in the program for several years.

(iv). Annualizing Capital Costs

Capital/start-up costs were estimated to be $0.

(c) Estimating Agency Burden and Costs

Table IV. Agency Burden and Cost

Agency Activity	Number of Reports per Year	Managerial Hours	Technical Hours	Extramural Hours	Total Hours per Year	Total Costs per Year
		$96.78	$69.63	$105.00
1. Receive and enter data;	223	0	1	0	223	$15,527.49
			$69.63
2. Review data entries;	223	0.2	1	0	267.6	$19,843.88
		$19.36	$69.63
3. Prepare and review company data balance statements;	223	0.2	1	0	267.6	$19,843.88
		$19.36	$68.26
4. Maintain ODS tracking system and reports	NA	20	150	200	370	$33,380.10
		$1,935.60	$10, 444.50	$21,000.00
Grand Total Per Year					1,128	$88,595.35

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

The values for respondent universe and total burden and costs are based on estimates of the number of respondents and hours to compile data and prepare reports. Historical data from reports submitted over the last several years and consultations with stakeholders were used to develop estimates. Costs associated with compliance for EPA and respondents are averages and were estimated from publicly available data sources. The total burden hours for respondents decreased in this ICR because it refines the hourly burden estimates for certifying the Quarantine and Preshipment use of methyl bromide and laboratory use of all ozone depleting substances. Increases in the average hourly wage rate for industry also contributed to higher respondent costs. Additionally, estimates were refined based on historical information. The total also reflects Agency practice of periodically seeking necessary information from the regulated community through the use of its authority under Section 114 of the Clean Air Act. No new recordkeeping and reporting requirements were added.

(e) Bottom Line Burden Hours and Cost Tables

(i) Respondent Tally

To determine bottom line burden hours and costs for respondents, EPA estimated the total number of responses per control period. The total number of responses for all respondents was calculated to be 2,439 hours. Therefore, over the three year span of this ICR, the total hours estimated for compliance for respondents is estimated to be 7,317 hours (2,439 x 3 years).

(ii) The Agency Tally

EPA estimated the amount of time required to complete each of the three main activities associated with the reports. In addition, hours and costs for maintaining the Tracking System and reporting forms were determined. Therefore, over the three year span of this ICR, the total Agency cost is estimated to be $265,786 ($88,595 x 3 years).

(f) Reasons for Change in Burden

There is a slight decrease in burden due to a decrease in the number of estimated respondents.

Table V. Burden Summary

	1432.30	1432.31
	(ICR Renewal)	(ICR Renewal)
Respondents annual burden hours	2,583	2,439
Respondents annual labor costs	$271,550	$259,213
Respondent capital/start-up costs	$0	$0
Respondents O&M costs	$5,535	$5,535
Agency’s annual burden hours	932	1,128
Agency’s annual labor costs	$93,033	$88,595

(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 2 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 15.

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 No. EPA-HQ-OAR-2011-0891, which is available for public viewing at the Air and Radiation Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., 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 and Radiation Docket and Information Center 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, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No. EPA-HQ-OAR-2011-0891 and OMB control number 2060-0170 in any correspondence.

1 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.

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