1626ss15 Final

Information Collection Request Supporting Statement

Part A of the Supporting Statement

National Refrigerant Recycling and Emissions Reduction Program

1. Identification of the Information Collection

   1. Title and Number of the Information Collection

This information collection request (ICR) is titled “National Refrigerant Recycling and Emissions Reduction Program”, EPA ICR Number: 1626.15, Office of Management and Budget (OMB) Control Number: 2060-0256.

2. Characterization/Abstract

Section 608 of the Clean Air Act (CAA), also known as the National Recycling and Emission Reduction Program (the Program), directs the Environmental Protection Agency (EPA) to issue regulations governing the use of ozone-depleting substances (ODS), including chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs), during the maintenance, service, repair, or disposal of air-conditioning and refrigeration appliances.

The regulations require persons servicing refrigeration and air-conditioning appliances to observe certain service practices that reduce emissions of ozone depleting refrigerants. The regulations also establish certification programs for technicians, recovery/recycling equipment, and off-site refrigerant reclaimers. In addition, EPA requires that ozone-depleting refrigerants contained in appliances be removed prior to disposal of the appliances and that all refrigeration and air-conditioning appliances be provided with a servicing aperture that facilitates recovery of the refrigerant. The Agency requires that substantial refrigerant leaks in appliances be repaired when they are discovered. These regulations significantly reduce emissions of ozone-depleting refrigerants, and therefore aid U.S. and global efforts to minimize damage to the ozone layer and the environment as a whole.

To facilitate compliance with and enforcement of Section 608 regulations, EPA requires reporting and recordkeeping from; technician certification programs; equipment testing organizations; refrigerant wholesalers; refrigerant reclaimers; refrigeration and air-conditioning appliance owners; technicians; and other establishments that perform refrigerant removal, service, or disposal. OMB previously approved this collection under ICR Number 1626.12 through December 31, 2017. Specific reporting and recordkeeping requirements were initially published May 14, 1993 (58 FR 28660) and codified at 40 CFR part 82, subpart F (§82.150 et seq.).

EPA is updating the existing requirements under the Program as well as extending them to cover appliances containing hydrofluorocarbons (HFCs) and other non-exempt substitute refrigerants. New records that would be maintained as a result of the rule are: invoices for servicing events; results of verification tests; results of annual and quarterly leak inspections; records of the disposal of appliances containing 5 to 50 pounds of refrigerant; and self-sealing valve test results. New reporting requirements include: lists of refrigerant recovery/recycling equipment; lists of certified technicians; repair reports for appliances that leak 125 percent of their full charge in a calendar year; and expanded opportunity to request extensions to the appliance repair and the appliance retrofit/retirement requirements. The rule also removes outdated recordkeeping and reporting requirements.

EPA has estimated that there are 861,374 annual respondents consisting of representatives from the air-conditioning and refrigeration and small can manufacturing community. The annual cost for respondents for the collection and maintenance of records, as well as reports to EPA, is estimated to total $34,627,299.

2. Need for and Use of the Collection

   1. Need/Authority for the Collection

This information collection is authorized under Section 608(a) of the Clean Air Act. This section directs the Administrator to “promulgate regulations establishing standards and requirements regarding the use and disposal” of ozone-depleting substances and to implement Section 608(c) which contains a statutory prohibition against venting of ODS and substitute refrigerants. EPA requires reporting and recordkeeping to facilitate compliance with and enforcement of the Section 608 requirements. In addition, EPA’s authority for this rulemaking is supplemented by Section 114, which authorizes the EPA Administrator to require recordkeeping and reporting in carrying out any provision of the CAA.

2. Practical Utility/Users of the Data

The purpose of the collection request is to facilitate compliance with and enforcement of Section 608 of the CAA and to reduce emissions of class I and class II ozone-depleting refrigerants and their substitutes to the lowest achievable level during the maintenance, service, repair, and disposal of appliances. EPA has used and will continue to use these records and reports to ensure that refrigerant releases are minimized during the refrigerant recovery, recycling, and reclamation processes.

Some recordkeeping requirements are intended to facilitate information sharing between regulated entities to ensure compliance with Section 608 requirements. Owners/operators of appliances use the information provided by service technicians to ensure their systems are not leaking in violation of the regulations. Refrigerant wholesalers use the data provided by service technicians to ensure they are complying with the refrigerant sales restriction.

Most of the reporting requested from respondents under this ICR are to seek a benefit such as an extension to repairing or retrofitting an appliance leaking in violation of Section 608 requirements or to voluntarily become an organization to test and certify technicians or to test and certify recovery and recycling equipment.

3. Non-duplication, Consultations, and Other Collection Criteria

   1. Non-duplication

The specific information requested is not currently collected by any other EPA office or any other government agency.

2. Public Notice Required Prior to ICR Submission to OMB

The changes to the existing recordkeeping and reporting requirements covered by this ICR were proposed at 80 FR 69458, EPA–HQ–OAR–2015–0453; FRL–9933–48– OAR. EPA requested comment on this ICR in that proposed rulemaking.

3. Consultations

The burden calculations for this renewal were developed based on information from EPA’s consultations for the previous ICR. EPA previously consulted two refrigerant reclaimers, a refrigerant wholesaler, and two technician certification programs. EPA also consulted the California Air Resource Board (CARB), Autocare Association, and the Automotive Refrigeration Products Institute (ARPI) for the regulatory changes to Section 608 that are reflected in this ICR.

4. Effects of Less Frequent Collection

The information collection requirements are either one-time, annual, or occasional submissions. All of these reporting requirements are similar to those that exist for ODS refrigerants but would be new for non-exempt substitute refrigerants. Additionally, EPA is removing (1) the one-time certification from technicians that they own certified refrigerant recovery equipment, (2) the annual report from programs certifying recovery and/or recycling equipment concerning the equipment they approve, and (3) the requirement for refrigerant recovery/recycling equipment testing organizations to submit information to EPA within 30 days of certification of a new model line of refrigerant recovery/recycling equipment.

The one-time submissions (e.g., applications for approval of technician certification organizations) and annual submissions (e.g., reclaimer annual reports) are required for EPA to track changes in industry and for long-term management of the Program. Occasional submissions, such as requests for extensions to repair, retrofit, or retirement timelines, allow entities flexibility in meeting regulatory requirements. The removal of this reporting requirement may result in non-compliance or higher costs to the entity. The provision requiring that owners or operators of appliances that leak 125 percent of their full charge in a calendar year to submit a report to EPA detailing their repair efforts allows EPA to track efforts to repair chronically leaking appliances and allows owners and operators to avoid mandatory retirement or retrofitting of their appliance.

5. General Guidelines

The reporting and recordkeeping requirements do not violate the regulations established by OMB at 5 CFR part 1320.5(d)(2).

6. Confidentiality

EPA informs respondents that they may assert claims of business confidentiality for any of the information they submit. Information claimed 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 only if EPA determines that the information is not entitled to confidential treatment. If no claim of confidentiality is asserted when the information is received by EPA, it may be made available to the public without further notice to the respondents (40 CFR 2.203). The handling and confidentiality of the reporting requirements for assuring computer data security, preventing disclosure, proper storage, and proper disposal follow EPA's confidentiality regulations (40 CFR 2.201 et seq.).

7. Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.

4. Respondents and Information Requested

   1. Respondents / North American Industry Classification System (NAICS) Codes

Table 1 lists the NAICS codes potentially affected by the information requirements covered under this ICR. These categories generally include owners/operators of industrial process refrigeration, commercial refrigeration, and comfort cooling appliances; plumbing, heating, and air-conditioning contractors; refrigerant wholesalers; manufacturers and distributors of small cans of automotive refrigerant; refrigerant reclaimers; disposers and recyclers of appliances; and testing and certifying organizations. These listings are not all-inclusive but are consistent with the types of organizations potentially impacted by this ICR.

Table 1: NAICS Codes of Potentially Affected Respondents

Industry Category	NAICS Code	NAICS Code Definition
Agriculture and Crop Support Services	115	Support Activities for Agriculture and Forestry
Arts, Entertainment, and Recreation	71	Arts, Entertainment, and Recreation
Beverage and Ice Manufacturing	312	Beverage Manufacturing
Durable Goods Wholesalers and Dealers	423	Merchant Wholesalers - Durable Goods
	441	Motor Vehicle and Parts Dealers
Educational Services	611	Educational Services
Food Manufacturing	311	Food Manufacturing
General Merchandise Stores	452	General Merchandise Stores
	453998	All Other Miscellaneous Store Retailers (except Tobacco Stores)
Grocery and Specialty Food Stores	4451	Grocery Stores
	4452	Specialty Food Stores
	72231	Food Service Contractors
Hospitals	622	Hospitals
Non-durable Goods Wholesalers and Dealers	424	Merchant Wholesalers – Non-durable Goods
Non-food Manufacturing	322	Paper Manufacturing
	323	Printing and Related Support Activities
	324	Petroleum Manufacturing
	325	Chemical Manufacturing
	326	Plastics and Rubber Manufacturing
	332	Metals Manufacturing
	333	Machinery Manufacturing
	334	Computer and Electronic Product Manufacturing
	336	Transportation Equipment Manufacturing
	3254	Pharmaceutical Manufacturing
	3391	Medical Equipment and Supplies Manufacturing
	339999	Miscellaneous Manufacturing
Office Buildings	92	Public Administration
	511	Publishing Industries (except Internet)
	512	Motion Picture and Video Industries
	515	Broadcasting
	517	Telecommunications
	518	Data Processing, Hosting, and Related Services
	519	Libraries and Archives
	522	Credit Intermediation and Related Activities
	524	Insurance Carriers
	531	Real Estate
	541	Professional, Scientific, and Technical Services
	551	Management of Companies and Enterprises
	561	Administrative and Support Services
	712	Museums, Historical Sites, and Similar Institutions
	721	Accommodation
	813	Religious, Grantmaking, Civic, Professional, and Similar Organizations
Other Warehousing, Storage, and Transportation	48	Transportation and Warehousing
	4931	Warehousing and Storage
Refrigerated Warehousing and Storage	49312	Refrigerated Warehousing and Storage
Research and Development	5417	Research and Development
Utilities	211	Oil and Gas Extraction
	221	Utilities
Warehouse Clubs and Supercenters	452910	Warehouse Clubs and Supercenters
Reclaimers	325120	Industrial Gas Manufacturing
	423930	Recyclable Material Merchant Wholesalers
	424690	Other Chemical and Allied Products Merchant Wholesalers
	562212	Solid Waste Landfill
	562920	Materials Recovery Facilities
Refrigerant Wholesalers	325120	Industrial Gas Manufacturing
	4237	Hardware and Plumbing and Heating Equipment and Supplies Merchant Wholesalers
	424690	Other Chemical and Allied Products Merchant Wholesalers
Service Technicians	238220	Plumbing, Heating, and Air-conditioning Contractors
Disposal Establishments	423990	Other Miscellaneous Durable Goods Merchant Wholesalers
	562212	Solid Waste Landfill
	562920	Materials Recovery Facilities
Service Establishments	811111	General Automotive Repair
	811310	Commercial Industrial Machinery and Equipment (not Automotive and Electronic) Repair and Maintenance
	811412	Appliance Repair and Maintenance
Small Can Manufacturers	325120	Industrial Gas Manufacturing
	441310	Automotive Parts and Accessories Stores
Certifying Organizations	541380	Environmental Test Laboratories and Services

2. Information Requested

All records pursuant to this ICR must be available onsite at the respondents' place of business for a minimum of three years. EPA encourages entities to submit reports electronically to [email protected]. Entities may also submit reports by mail to: Section 608 Program Manager; Stratospheric Protection Division; Mail Code: 6205T; U.S. Environmental Protection Agency; 1200 Pennsylvania Avenue, NW; Washington, DC 20460.

1. Refrigerant Recovery/Recycling Equipment Testing Organizations

The data items required by organizations that test and certify refrigerant recovery/recycling equipment are specified in 40 CFR 82.160(a), (b), and (e).

i) Data Items

• Application for approval by EPA to certify refrigerant recovery/recycling equipment (as applicable). Information includes:

  • List refrigerant recovery/recycling equipment present at the organization that will be used for testing;

  • Verification of expertise in refrigerant recovery/recycling equipment testing and the technical experience of the organization's personnel;

  • Verification of the organization’s knowledge of the standards and recordkeeping and reporting requirements in 40 CFR Part 82, Subpart F; and

  • Description of the organization’s program for verifying the performance of certified recycling and recovery equipment manufactured over the long term, specifying whether retests of equipment or inspections of equipment at manufacturing facilities will be used;

  • Verification that the organization has no conflict of interest and receives no direct or indirect financial benefit from the outcome of certification testing; and

  • Agreement to allow EPA access to records and personnel to verify the information contained in the application.

• Records of refrigerant recovery/recycling equipment testing and performance.

• List of certified refrigerant recovery/recycling equipment that includes the name of the manufacturer and the name or serial number of the model line.

• Notice of when a model of refrigerant recovery/recycling equipment fails a three-year recertification test.

ii) Respondent Activities

• Prepare a one-time application to become an approved refrigerant recovery/recycling equipment testing organization.

• Retain records of recovery/recycling equipment testing and performance and refrigerant recovery/recycling equipment.

• Notify EPA within 30 days of retesting or inspection if equipment previously certified fails the periodic re‑test required by the regulation.

• Publish online a list of all certified equipment and update the list annually.

2. Refrigerant Reclaimers

The data items required by reclaimers are specified in 40 CFR 82.164(d).

i) Data Items

• Application for reclaimer certification by EPA, including a certification that the reclaimer will:

  • Reclaim refrigerant to all the specifications in Appendix A of Subpart F that are applicable to that refrigerant;

  • Verify that each batch of refrigerant reclaimed meets these specifications using the analytical methodology prescribed in Appendix A;

  • Release no more than 1.5 percent of the refrigerant during the reclamation process;

  • Dispose of wastes from the reclamation process in accordance with all applicable laws and regulations; and

  • Maintain records and submit reports.

• Records of the analysis conducted to verify that each batch of reclaimed refrigerant meets the necessary specifications.

• Records on the quantity of ODS and substitute refrigerant (by ASHRAE type) sent for reclamation, the amount reclaimed, waste products from the reclamation process, and names and addresses of persons sending refrigerant for reclamation.

• Annual reports noting the total annual quantity of material (the combined mass of refrigerant and contaminants) by refrigerant type sent to them for reclamation, the mass of refrigerant reclaimed by refrigerant type, and the mass of waste products produced.

ii) Respondent Activities

• Prepare a one-time application to become a certified refrigerant reclaimer.

• Maintain records of analyses conducted to verify that reclaimed refrigerant meets the necessary specifications.

• Maintain records of the names and addresses of persons sending material for reclamation and the quantity of the material (the combined mass of refrigerant and contaminants) by refrigerant type sent to them for reclamation.

• Prepare and submit to EPA annual reports detailing the quantity of each refrigerant sent for reclamation (the combined mass of refrigerant and contaminants), the mass of each refrigerant reclaimed, and the mass of waste products.

• Notify EPA within 30 days of a change in business management, location, or contact information.

3. Refrigerant Wholesalers

The data items required by refrigerant wholesalers are specified in 40 CFR 82.154(c)(3).

i) Data Item

• Refrigerant sales records that indicate the name of the purchaser, the date of sale, and the quantity purchased as well as records indicating that the purchaser is a certified technician (as applicable).

ii) Respondent Activities

• Retain invoices from refrigerant sales.

4. Technician Certification Programs

The data items required by technician certification programs are specified in 40 CFR 82.161(b) and 40 CFR Part 82, Subpart F, Appendix D.

i) Data Items

• Prepare a one-time application to become an approved technician certification program. The application will verify:

  • Ability to produce multiple versions of examinations for each test site;

  • Sufficient internal capacity to process the scoring and the accompanying documentation; and

  • Ability to ensure the confidentiality and security of test questions and answers.

• Records of the names and addresses of all individuals taking the tests, the scores of all certification tests administered, and the dates and locations of all testing administered. These records must be retained indefinitely.

• List of technicians certified through the program, including:

  • First name, middle initial, and last name of the technician;

  • Technician’s city of residence when taking the test;

  • Type(s) of certification received; and

  • Date each certification was completed.

• Biannual (2x/year) reports on pass/fail rates.

ii) Respondent Activities

• Prepare and submit application to become a technician certification organization.

• Maintain records of testing events, scores of certification tests, and the dates and locations of tests.

• Maintain and publish online lists of technicians certified through programs after January 1, 2017.¹

• Prepare and submit reports to EPA every six months on the pass/fail rate and testing schedules.

• Organizations that stop certifying technicians must transfer their records to another certifying program or EPA. Organizations that receive those records must inform EPA within 30 days.

5. Disposal Establishments

The data items required by disposal establishments are specified in 40 CFR 82.155(c).

i) Data Item

• Copies of signed statements attesting that refrigerant has been recovered prior to the disposal of each appliance or copies of a contract from a supplier of multiple appliances that refrigerant will be recovered prior to delivery at the disposal establishment.

ii) Respondent Activities

• Retain copies of signed statements or contracts for each piece of disposed appliance with the name and address of the person who recovered the refrigerant and the date the refrigerant was recovered.

6. Technicians

The data items required by technicians are specified in various provisions of subpart F as listed.

i) Data Items

• Proof of technician certification (40 CFR 82.161(a)(4)).

• Records of leak inspections and verification tests (40 CFR 82.157(l)).

• Service invoices to owners/operators with information on the identity and location of the appliance, the date and type of service performed, and the quantity and type of refrigerant added. (40 CFR 82.157(l)).

• Records for the disposal of appliances with charges between 5 and 50 pounds which include:

  • Company name, location of equipment, date of recovery, and types of refrigerant recovered for each appliance;

  • Quantity of refrigerant recovered from such appliances each calendar month; and

  • Quantity and types of refrigerant ultimately transferred for reclamation or destruction.

ii) Respondent Activities

• Successfully complete a certification test.

• Maintain a copy of certification at their place of business.

• Prepare and provide service invoices to owners/operators with each servicing event of an appliance containing 50 or more pounds of refrigerant.

• Prepare and provide records of leak inspections and verification tests on appliances containing 50 or more pounds of refrigerant (only for appliances exceeding the threshold leak rate).

• Prepare and maintain the appropriate records when disposing of appliances with charges between 5 and 50 pounds.

7. Owners/Operators of Appliances with Charge Sizes of 50 or More Pounds

The final rule phases in the requirements over a few years. Until January 1, 2019, the existing recordkeeping and reporting provisions previously approved under this ICR will apply. The data items required by owners/operators of appliances containing 50 or more pounds of refrigerant are specified in 40 CFR 82.166. After January 1, 2019, the revised reporting and recordkeeping provisions at 40 CFR 82.157(l) and (m) (as presented below) will apply.

i) Data Items

• Records related to determining the full charge of an appliance, including: the identification of the owner or operator of the appliance; the address where the appliance is located; the full charge of the appliance and the method for how the full charge was determined; if using an established range for determining full charge, records must include the range for the full charge of the appliance, its midpoint, and how the range was determined; and any revisions of the full charge, how they were determined, and the dates such revisions occurred.

• Service invoices with information on the identity and location of the appliance, the date and type of service performed, the name of the person performing the service, the quantity and type of refrigerant added and the full charge of the system.

• Records indicating the leak rate of the appliance, generated every time refrigerant is added to the appliance.

• For appliances that have been found to be above the threshold leak rate, records of:

  • Quarterly or annual leak inspections (or installation of an automatic leak detection system, annual inspections and recalibrations of the system, and a record of each date the system detected a leak and the location of the leak); and

  • Verification tests on repairs.

• Requests for extensions to the 30-day repair timeline or the one-year retrofit/retire timeline (as applicable). Submissions include the following information:

  • Date of notification to EPA;

  • Identification of the appliance;

  • Name of the owner or operator;

  • Leak rate;

  • Method used to determine the leak rate and full charge;

  • Date a leak rate above the applicable allowable rate was discovered;

  • Location of leaks(s) to the extent determined to date;

  • Any repair work that has been finished thus far, including the date that work was finished;

  • Plan to finish the retrofit or retirement of the system (as applicable);

  • Reasons why more than one year is necessary to retrofit or retire the system (as applicable); and

  • Estimate of when retrofit or retirement work will be finished (as applicable).

• Plans to retire/replace or retrofit appliances (as applicable). Plans must include:

  • Identification and location of the appliance;

  • Type and full charge of the refrigerant used in the appliance;

  • Type and full charge of the refrigerant to which the appliance will be converted, if retrofitted;

  • Itemized procedure for converting the appliance to a different refrigerant, including changes required for compatibility with the new substitute, if retrofitted;

  • Plan for the disposition of recovered refrigerant;

  • Plan for the disposition of the appliance, if retired; and

  • One-year schedule for completion of the appliance retrofit or retirement.

• Requests to cease a retrofit/retirement if all leaks are repaired.

• Records on mothballed appliances, including the date when a system that is leaking in excess of the leak rate is mothballed and the date when refrigerant is later added back into the system.

• Records on purged or destroyed refrigerant, including information on flow rate, quantity or concentration of the refrigerant in the vent stream; and periods of purge flow.

ii) Respondent Activities

• Retain service invoices containing the information described above.

• Retain documentation from leak inspections or on leak detection systems.

• Retain documentation on verification tests for repairs when the leak rate is exceeded.

• Notify EPA when seeking an extension of time to complete repairs.

• Notify EPA when an appliance loses more than 125 percent of its total charge within a calendar year, including a description of repairs to the appliance.

• Prepare and maintain a plan to retire/replace or retrofit leaking appliances (as applicable).

• Prepare and submit to EPA requests for extensions to the 30-day repair timeline or the one-year retrofit/retire timeline (as applicable).

• Prepare and maintain a copy of requests for extensions to the 30-day repair timeline or the one-year retrofit/retire timeline.

• Prepare and submit requests to cease a retrofit/retirement if all leaks are repaired.

• Prepare and maintain records on mothballed appliances.

• Notify EPA when excluding purged refrigerants that are destroyed from annual leak rate calculations.

• Prepare and maintain records on purged or destroyed refrigerant.

8. Small Can Manufacturers

The data items for small can manufacturers are specified in 40 CFR 82.154(c)(2) and in 40 CFR Part 82, Subpart F, Appendix E.

i) Data Item

• Log forms of results from self-sealing valve testing.

ii) Respondent Activities

• Prepare and retain records of results from self-sealing valve tests.

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

   1. Agency Activities

EPA activities associated with the review of the reports consist of reviewing the following:

• Applications to become an independent refrigerant recovery/recycling equipment certifying organization.

• Applications to become a certified refrigerant reclaimer.

• Annual reports from reclaimers on their activities.

• Certification notices by refrigerant reclaimers that change ownership or enter the market.

• Applications to become a technician certification program.

• Records from technician certifying programs exiting the market.

• Reports submitted by approved technician certification programs.

• Extension requests from owners/operators of commercial refrigeration, comfort cooling, and industrial process refrigeration appliances.

• Reports from owners/operators of appliances that leak 125% or more of their full charge in a calendar year.

• Requests from owners/operators to cease retrofit/retirement plans.

2. Collection Methodology and Management

Reclaimers are required to report annually on activities using EPA Form 5900-404. Small can manufacturers can use EPA’s sample form 5900-405 to facilitate recordkeeping. Entities are encouraged to submit the required information in an electronic format to [email protected]. The information submitted by each member of the regulated community will be stored at EPA headquarters for review and reference.

3. Small Entity Flexibility

Several of the recordkeeping and reporting requirements of the rule are intended to permit entities greater flexibility in complying with the regulation.

Technicians who work on small appliances may take a take-home test rather than a proctored test. This provision was implemented in recognition that (1) entities servicing small appliances are often small businesses, (2) many of these entities only rarely perform service on the refrigerant circuit of small appliances, and (3) the quantity of refrigerant in small appliances is less than five pounds. For similar reasons, individuals who recover refrigerant from small appliances and motor vehicle air conditioners when they are disposed of are not required to be certified and are not required to use certified refrigerant recovery/recycling equipment.

Final persons in the disposal process for small appliances and MVACs may elect not to recover refrigerant themselves so long as they obtain a signed statement from persons upstream in the disposal process that the refrigerant has been removed already. The signed statement permits the final disposer to delegate responsibility for refrigerant removal.

Owners of appliances that leak above a certain level may elect to retrofit or replace their appliances rather than repair them so long as they develop a retrofit or retirement plan. Owners/operators may take longer than 30 days to complete repairs or longer than one year to retrofit or replace appliances so long as they submit documentation to EPA explaining their need for additional time.

4. Collection Schedule

EPA requires maintenance of records for a minimum of three years. The following information is required on a specific collection schedule:

• Approved equipment testing organizations must notify EPA if a previously certified model line fails to meet EPA requirements within 30 days of the failed retest or inspection.

• On a transactional basis, reclaimers must maintain records of the quantity of each refrigerant sent to them for reclamation (the combined mass of refrigerant and contaminants), the mass of each refrigerant reclaimed, and the mass of waste products. Reclaimers must report the aggregated information by refrigerant type to EPA within 30 days of the end of the calendar year. The extension of the reporting requirements to substitute refrigerants will become effective January 1, 2018.

• Effective January 1, 2018, programs certifying technicians, excluding federally-run programs, must publish a list of technicians they have certified after January 1, 2017. Technicians can opt out of having their names published.

• If a refrigerant reclaimer changes ownership, the new owner must certify with EPA within 30 days of the change of ownership.

• Owners/operators must prepare a retrofit or retirement plan within 30 days of:

  • Discovering a leak greater than the threshold leak rate; or

  • An appliance continues to leak, even after making good faith efforts to repair leaks.

• Owners/operators choosing to request an extension to the retrofit/retirement timeline must do so within seven months of discovering that the leak rate exceeded the applicable leak rate.

• Owners/operators who exclude purged refrigerants that are destroyed from annual leak rate calculations must submit information to EPA within 60 days of the first time the exclusion is used by the facility where the appliance is located.

• Owners/operators whose appliances leak more than 125 percent if their full charge in one calendar year must submit a report to EPA detailing repair efforts. Reports must be submitted by March 1 the year following the exceedance.

6. Estimating the Burden and Cost of the Collection

This section contains tables that provide the numerical basis for the annual burden and cost of this ICR by detailing the following:

• EPA’s rationale in preparing respondent burden and cost tables.

• Estimated respondent and Agency burden (hours to complete required activities).

• Estimated respondent and Agency labor costs and capital costs associated with those activities.

• Universe of estimates.

• Calculated burden and cost totals.

The collection activities in Sections 4 and 5 are referenced to develop these estimates. The activities for which EPA estimated burden and cost correspond directly with the activities listed in Sections 4 and 5.

1. Estimating Respondent Burden

Estimates of respondent burden and cost for the Program are presented below. All hour estimates are based on EPA's experience implementing this Program and on EPA’s best professional judgment. All burden hours and costs presented here are annual.

2. Estimating Respondent Costs

EPA has estimated the total cost per respondent required to complete each activity. The total cost for each respondent activity is comprised of the following:

• Labor Cost (for legal, managerial, technical, clerical, and other employees).

• Operating and Maintenance (O&M) Cost (for labor and equipment needed over time as well as for the purchase of services).

None of the reporting or recordkeeping requirements is expected to have associated capital costs.

1. Estimating Labor Costs

The labor costs reflect the total cost to employ an individual and include estimates of salaries and overhead costs. EPA estimates the average annual respondent hourly cost (labor plus overhead) for all affected entities. In deriving these costs, EPA identified applicable standard occupational classification for each respondent and used the 2015 median hourly rate from the Bureau of Labor Statistics.² EPA then increased these numbers by 110% for overhead. Previously, EPA used only the rate for Heating, Air-Conditioning, and Refrigeration Mechanics and Installers for all recordkeeping and reporting activities associated with this ICR. EPA has revised this ICR to more accurately reflect the various types of entities conducting the activities and their associated costs. The resulting costs outlined in Table 2 are the average hourly administrative cost of labor plus overhead for private firms.

Table 2: Labor Costs for Affect Entities

Respondent	Bureau of Labor Statistics Information			Total
	Standard Occupational Classification	Occupational Title	Median Wage
Refrigerant Recovery/Recycling Equipment Testing Organization	17-2081	Environmental Engineers	$40.65	$85.37
Refrigerant Reclaimers	51-8091	Chemical Plant and Systems Operators	$28.52	$59.89
Refrigerant Wholesalers	41-4012	Sales Representatives, Wholesale	$26.79	$56.26
Technician Certification Programs	25-9031	Instructional Coordinators	$29.94	$62.87
Disposal Establishments	49-9021	Heating, Air-Conditioning, and Refrigeration Mechanics and Installers	$21.69	$45.55
Technicians
Owners/Operators	17-2111	Health and Safety Engineers	$42.21	$88.64
Small Can Manufacturers	43-5111	Weighers, Measurers, Checkers, and Samplers	$13.80	$28.98

2. Estimating Capital Costs and Operations and Maintenance Costs

According to the 1995 PRA, burden is 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.” Any activity that is not usual and customary is considered a burden. As part of the submission to OMB, EPA has estimated all costs for respondents to comply with required Agency activities that are not incurred by persons in their normal course of activities. This estimate includes the time needed to review instructions, maintain records, complete paperwork, gather information, and report information.

There are two types of non-labor costs – capital/start-up costs and O&M costs. One-time capital/start-up costs include any produced physical good needed to provide the necessary information. Start-up capital must be purchased for the specific purpose of satisfying EPA’s reporting or recordkeeping requirements. Capital goods include computers, machinery, or equipment. Start-up capital costs are incurred at the beginning of an information collection period and are incurred only once. In addition to the acquisition of start-up capital, one-time activities associated with the production of capital have also been evaluated. EPA has considered capital/start-up costs and O&M costs in determining that there are no non-labor related costs associated with this ICR. O&M costs are those costs associated with a paperwork requirement incurred continuously over the life of the ICR. They are defined by the PRA as “the recurring dollar amount of cost associated with O&M or purchasing services.”

The following tables summarize the annual respondent burden and cost by respondent type and reporting and recordkeeping requirement.

1. Refrigerant Recovery/Recycling Equipment Testing Organization

Annual Respondent Burden
Collection Activities	Burden Hours	Labor Costs/Entity
Equipment testing organization applying for approval	8.0	$682.92
Maintain records of refrigerant recovery/recycling equipment tested and its performance	0.5	$42.68
Providing notice when equipment fails recertification	0.5	$42.68
Publish list of all certified equipment that includes the name of the manufacturer and the name or serial number of the model line online3	0.5	$42.68

Organizations that intend to test and certify refrigerant recovery/recycling equipment need to apply for approval from EPA. EPA estimates that an organization would need 8 hours to complete the application process. The number of refrigerant recovery/recycling equipment testing organizations has remained unchanged since 1993, however, and thus no burden is included in this ICR analysis.

Each of the two refrigerant recovery/recycling equipment testing and certifying organizations approved by EPA are estimated to spend 30 minutes each year on: maintaining records of refrigerant recovery/recycling equipment tested and its performance; providing notice when equipment fails recertification; and publishing a list of all certified equipment online.

2. Refrigerant Reclaimers

Annual Respondent Burden
Collection Activities	Burden Hours	Labor Costs/Entity
Certification by refrigerant reclaimers that change ownership or enter the market	5.0	$299.46
Maintain records of the analyses conducted to verify that reclaimed refrigerant meets the necessary specifications	4.3	$259.53
Reclaimer recordkeeping	11.7	$701.42
Annual activity report	9.4	$561.14

Based on experience from previous years, EPA estimates that four entities will submit one-time applications to become certified refrigerant reclaimers. Each submission is estimated to take 5 hours.

Reclaimers must maintain records of analyses conducted to verify that reclaimed refrigerant meets the necessary specifications. EPA estimates that each reclaimer will spend approximately 1 minute per day maintaining records, for a total of 4.3 hours annually.

Reclaimers must also maintain records of refrigerant sales transactions. EPA estimates that each reclaimer will spend approximately 14 minutes per recordkeeping event with a total of 50 events per year.⁴ Therefore, each reclaimer will spend 11.7 hours maintaining records annually.

Reclaimers must maintain records and report annually on the quantity of material sent to them for reclamation, the amount reclaimed, waste products from the reclamation process, and customer and sales records. Compiling this information, preparing it for EPA, and submitting it to EPA is estimated to take approximately 9.4 hours per year for ODS, HFC, and other non-exempt substitute refrigerants.⁵

2. Refrigerant Wholesalers

Annual Respondent Burden
Collection Activities	Burden Hours	Labor Costs/Entity
Recordkeeping for refrigerant sales, including maintenance of technician certification cards from purchasers employing at least one certified technician	8.7	$487.58

EPA estimates that each refrigerant wholesaler must spend approximately 2 minutes each day maintaining invoices that indicate the name of the purchaser, the date of sale, the quantity, and verification that the purchaser is a certified technician (as applicable). This results in an annual burden of 8.7 hours.

2. Technician Certification Programs

Annual Respondent Burden
Collection Activities	Burden Hours	Labor Costs/Entity
Technician certification programs applying for approval	5.0	$314.37
Recordkeeping by existing certification programs	5.0	$314.37
Maintain list of technicians certified	0.17	$10.48
Biannual reporting by existing certification programs	2.0	$125.75
Transfer of records when no longer operational	8.0	$502.99

EPA estimates that it will take 5 hours for new organizations to compile the necessary information to apply for the certification program approval. EPA also estimates that existing technician certification program spend 5 hours annually maintaining records on technicians certified through their programs.

Technician certification programs are required to publish online a list documenting who they have certified and what type of certification each individual received. Each of the testing organizations are also required to submit biannual reports summarizing the numbers of previously certified individuals, individuals taking the tests, scores of all certification tests, and the dates and locations of all tests administered. EPA estimates that technician certification programs spend 5 minutes publishing online lists and 1 hour completing each report. EPA expects programs to publish lists and complete reports twice a year. Organizations that stop certifying technicians must transfer their records to another certifying program or EPA. Organizations that receive those records must inform EPA within 30 days. EPA assumes that 5 programs a year will spend 8 hours transferring records and reporting to EPA.

2. Disposal Establishments

Annual Respondent Burden
Collection Activities	Burden Hours	Labor Costs/Entity
Maintenance of copies of signed statements or contracts of previous refrigerant recovery by disposal establishments	15.2	$690.83

Disposal establishments spend an estimated 3.5 minutes per business day (260 events per year) collecting and maintaining copies of signed statements verifying that refrigerant has been removed from appliances before they are accepted for disposal.⁶

2. Technicians

Annual Respondent Burden - Certification
Collection Activities	Burden Hours	Labor Costs/Entity
Maintain certification cards	0.017	$0.76
Acquire certification cards	0.017	$0.76

Technicians are expected to spend 1 minute each year maintaining their certification cards. EPA estimates that approximately 10 percent of the estimated 300,000 technician labor force turns over each year, necessitating certification. EPA estimates that each new technician will spend 1 minute acquiring a certification card.

Annual Respondent Burden - Preparing and Maintaining Records
Collection Activities	Burden Hours	Labor Costs/Entity
Provide invoices for serviced appliances with charge sizes 50 to 500 lbs.	0.14	$6.42
Provide invoices for serviced appliances with charge sizes >500 lbs.	0.12	$5.54
Provide leak inspection and verification test records	0.02	$0.97
Maintain disposal records for appliances with charge sizes of 5 - 50 lbs.	0.2	$9.11

Technicians servicing ODS, HFC, and other non-exempt substitute refrigerant-containing appliances with charge sizes of 50 or more pounds are required to provide records of the following: the identity and location of the appliance, the date and type of service performed, and the quantity and type of refrigerant added. EPA estimates that each technician will spend two minutes preparing and one minute maintaining each record.⁷ The annual burden hours per respondent was determined by dividing the total invoice burden for all serviced appliances across the universe of technicians. EPA estimates that appliances containing 50 to 500 pounds of refrigerant will be serviced annually, requiring 1 invoice, and that appliances with 500 or more pounds will be serviced quarterly, requiring 4 invoices.

Technicians conducting leak inspections or verification tests on appliances containing 50 to 500 pounds of refrigerant that had been found leaking above the threshold rate must prepare and provide records to the owner/operator of that appliance. EPA estimates that each technician will spend 1 minute providing each record.

Technicians disposing of appliances with charge sizes between 5 and 50 pounds are also required to maintain records on: the quantity and types of refrigerant recovered in each calendar month; the quantity and type of refrigerant transferred for reclamation or destruction; the company name; and date. EPA estimates that technicians spend 1 minute per month to maintain these records.

2. Owners/Operators

Annual Respondent Burden - Reporting
Collection Activities	Burden Hours	Labor Costs/Entity
Prepare and submit requests for extension to 30-day repair timeline	0.5	$44.32
Prepare and submit requests for extension to 1-year retrofit/retire timeline	0.5	$44.32
Prepare and submit requests to cease a retrofit/retirement if all leaks are repaired	0.5	$44.32
Prepare and submit report on efforts to repair chronically leaking appliances	1.0	$88.64

Owners/operators of IPR, comfort cooling, or commercial refrigeration appliances that contain more than 50 lbs. of ODS or HFC refrigerant may apply to EPA for an extension to the leak repair and appliance retrofit/retire timeframe. EPA estimates that each request will take 30 minutes to complete.

Owners/operators may prepare and submit requests to cease a retrofit/retirement if they are able to repair all leaks. EPA estimates an average burden of 30 minutes per request.

Owners/operators of IPR, comfort cooling, or commercial refrigeration appliances that leak 125 percent or more of the full refrigerant charge in a calendar year are required to submit a report to EPA about efforts to identify leaks and repair the appliance. EPA estimates an average burden of 1 hour per owner/operator with an affected piece of equipment.

Annual Respondent Burden - Recordkeeping
Collection Activities	Burden Hours	Labor Costs/Entity
Maintain records of the full charge of an appliance	0.025	$2.22
Maintain records of the leak rate calculation	0.039	$3.47
Maintain purchase and service records	0.11	$4.91
Maintain leak inspection records	0.046	$2.05
Maintain reports on the results of verification tests for repairs to systems that exceed the leak rate threshold	0.025	$2.22
Develop/maintain plan to retire/replace or retrofit appliances	8.0	$360.53
Maintain records on mothballed equipment	0.025	$2.22
Maintain information on purged/destroyed refrigerant	0.025	$1.13

EPA estimates that owners/operators of appliances will spend 1.5 minutes per year maintaining records on the full charge of an appliance. EPA estimates that owners/operators will spend 1 minute per servicing event maintaining records on leak rate calculations, for an average of slightly more than 2 minutes per year (0.039 hours).⁸

Owners/operators of ODS, HFC, and other non-exempt substitute refrigerant-containing appliances with charge sizes of 50 or more pounds are also required to maintain records for each service or maintenance event. EPA estimates that maintaining these records takes 1.5 minutes per servicing event, for an average annual burden of approximately 3.5 minutes per owner/operator.⁹

Owners/operators are required to maintain reports on quarterly and annual inspections and on the results of verification tests and leak inspections any time the leak rate threshold is exceeded. EPA estimates that maintaining leak inspection records requires one minute of burden, for an average annual burden of approximately 3 minutes per owner/operator.¹⁰ EPA estimates that 1.5 minutes is required to maintain reports on the results of verification tests any time the leak threshold is exceeded.

Owners/ operators planning to retire/replace or retrofit appliances spend 8 hours on developing or maintaining a plan. EPA estimates that one percent of HFC appliances will necessitate a plan. EPA has adjusted the number of expected retirements to account for more extensions to the repair timeline.

Owners/operators must prepare and maintain records of mothballed appliances. EPA estimates a burden of 1.5 minutes to prepare and maintain records. EPA also estimates that owners/operators of appliances normally containing 50 or more pounds of refrigerant spend 1.5 minutes maintaining information on purged and destroyed refrigerant.

2. Small Can Manufacturers

Annual Respondent Burden - Reporting
Collection Activities	Burden Hours	Labor Costs/Entity
Maintain records of self-sealing valve test data and log forms for 3 years	0.30	$8.69

Manufacturer of small cans of refrigerant are required to conduct tests to verify that self-sealing valves function and maintain logs of test results. EPA estimates that manufacturers will require 1.5 minutes to document each test result and that tests will occur monthly.

3. Estimating the Respondent Universe and Total Burden and Costs

The respondent universe as well as the frequency of reporting is defined in 40 CFR, Part 82, Subpart F, and includes refrigerant recovery/recycling equipment testing organizations; averages for the number of service establishments, disposers, and refrigerant reclaimers that enter the market or change ownership; refrigerant wholesalers; technician certification programs; technicians acquiring certification and maintaining certification cards; technicians servicing refrigeration and air-conditioning appliances; owners of refrigeration and air-conditioning appliances; owners of industrial process refrigeration appliances; and small can manufacturers.

EPA used past experience, previously reported data, modeling, and estimates from the affected community to determine the number of respondents (or the respondent universe). The estimates are based upon EPA's experience in implementing the Program since 1993 and analysis conducted in the Technical Support Document that accompanies this rulemaking.¹¹ A listing of these entities follows:

• Refrigerant/Recycling Equipment Testing Organizations: Testing organizations for refrigerant recovery/recycling equipment have remained at two organizations since inception of the program in 1993. Based on past experience, EPA does not anticipate that additional entities will apply to become approved refrigerant recovery/recycling equipment testing organizations.

• Refrigerant Reclaimers: EPA currently has 61 certified refrigerant reclaimers who must submit annual activity reports. Based on EPA's experience, EPA estimates four reclaimers per year will submit one-time applications to EPA to be certified.

• Refrigerant Wholesalers: EPA assumes that the number of wholesalers is 11,000. This is based on publicly available data on the number of hardware, and plumbing and heating equipment and supplies merchants (NAICS code 4237).

• Technician Certifying Programs: EPA currently has 72 certified technician certifying programs. Based on EPA's experience, EPA estimates 5 new organizations per year will submit materials to EPA requesting that they be authorized to test and certify technicians. EPA assumes that, on average, 5 technician certifying programs will exit the market and need to transfer records to EPA or another certifying program.

• Technicians: EPA assumes that the number of technicians entering the workplace has remained constant with those that who have left the workforce. This ICR assumes that the number of technicians has remained constant at 300,000. EPA assumes that 10 percent of the technician labor force turns over each year (i.e., 30,000 technicians), necessitating certification.

• Disposal Establishments: EPA assumes that the number of disposal establishments (7,500) has not changed since the previous ICR.

• Owners/Operators:¹²

  • Based on actual submissions to EPA, the Agency estimates that 4 owners/operators of comfort cooling, commercial refrigeration, and industrial process refrigeration appliances with charge sizes greater than 50 lbs. will choose to exclude the amount of purged and destroyed refrigerant from their leak rate calculations.

  • EPA allows owners/operators of industrial process refrigeration, comfort cooling, and commercial refrigeration appliances with a charge size of 50 or more pounds to submit a written request for an extension to leak repair requirements. The number of extensions is estimated partly based on the number of actual extensions filed for ODS industrial process refrigeration appliances in previous years. EPA also expects additional requests from owners/operators of comfort cooling and commercial refrigeration appliances due to the new extensions for such appliances as well as requests from HFC-containing appliances. EPA estimates that 4,556 owners/ operators of ODS and HFC appliances will prepare and submit request for extensions each year.

  • 61 owners/operators of appliances with a charge size of 50 or more pounds are expected to prepare and submit requests for extensions to the one year retrofit/retire timeline. This estimate is based on the number of IPR and federally-owned appliances that historically sought extensions. The number of extensions for IPR is scaled up to account for extensions requested for comfort cooling and commercial refrigeration (ODS and HFC appliances), and IPR (HFC appliances).

  • EPA estimates that 4,092 owners/operators will develop and maintain the required appliance retrofit/retirement report at their place of business. EPA assumes that fewer retrofits/ retirements will now occur due to the availability of extensions.

  • EPA estimates that 5 percent of owners/operators, or 205 entities, that develop retrofit/retire plans will submit a request to cease retrofit/retirement.

  • Owners/operators must prepare and maintain records of mothballed appliances. EPA estimates that 2 percent of owners/operators, or 82 entities, will need to maintain these records.

  • EPA estimates that 542,729 owners/operators of appliances with charge sizes of 50 or more pounds would need to maintain annual or quarterly service invoices. The number of owners/ operators is estimated based on the total number of appliances and the average number of appliances per model facility in the Technical Support Document associated with this rule.

  • EPA estimates that there are 281,746 events that would exceed the leak rate threshold in IPR, comfort cooling, and commercial refrigeration appliances. For the purposes of this analysis, EPA assumes that the number of leak events is equivalent to the number of owners/operators that would need to keep records on the results of the verification tests when those thresholds are exceeded.

  • EPA estimates that there are 1,425 events where IPR, comfort cooling, and commercial refrigeration appliances would leak 125 percent or more of the full charge in a calendar year. For the purposes of this analysis, EPA assumes that the number of events is equivalent to the number of owners/operators that would need to report on leak and repair efforts to EPA.

• Small Can Manufacturers: EPA estimates there are 10 manufacturers of small cans of refrigerant that need to comply with the self-sealing valve requirements.

For the entities that may be subject to these regulatory actions, an estimated 854,580 are small businesses. Additional information on small business impacts can be found in the Technical Support Document.¹³

4. Estimating Agency Burden and Cost

The hourly rate for EPA staff at the GS-13 Step 1 level is $35.38 per hour. This hourly basic rate is from the 2016 GS salary schedule listed in the Federal Wage Page of the Office of Personnel Management website http://www.opm.gov/oca. EPA then multiplied the hourly rate by the standard government benefits and overhead multiplication factor of 1.6. The resulting rate that was used in estimating annual Agency burden and cost is $56.61 ($35.38 × 1.6).

EPA has used past experience, reporting data, and estimates from the affected community in determining the number of responses that the Agency would review. The following paragraphs describe the amount and degree of burden.

• Refrigerant Reclaimers: 61 certified refrigerant reclaimers must submit annual activity reports. EPA will spend one hour reviewing each of the annual reports for a total of 61 hours per year.

Based on EPA's experience, it is assumed that 4 new refrigerant reclaimers per year will submit one-time applications to EPA to be certified. EPA spends one hour reviewing and approving each certification for a total of four hours per year.

• Technician Certifying Programs: 72 certified technician certifying programs must submit biannual activity reports to EPA. EPA will spend one hour reviewing each biannual activity report, for a total of 144 hours per year.

Based on EPA's experience, the Agency expects to certify 5 new technician certification organizations per year. EPA expects to spend two hours reviewing and approving each application, for a total of 10 hours per year. EPA assumes an equal number of technician certifying programs will exit the market and need to transfer records to EPA or another entity. EPA assumes 1 hour for processing these records.

• Owners/Operators: EPA estimates that it takes 15 minutes to review and make a determination on each of the anticipated 4,556 requests from owner/operators of industrial process refrigeration, comfort cooling, and commercial refrigeration appliances for an extension to the 30‑day repair requirement for mandatory leak repair, for a total of 1,139 hours per year.

EPA estimates one hour to review and make a determination on anticipated 61 requests from the owner/operator of industrial process refrigeration, comfort cooling, and commercial refrigeration appliances for an extension to the one‑year retrofit requirement under the leak repair requirements, for a total of 61 hours a year.

EPA estimates that it takes 10 minutes to review each of the anticipated 1,425 reports on IPR, comfort cooling, and commercial refrigeration appliances that leak 125 percent or more of the full charge in a calendar year, for a total of 238.5 hours per year.

EPA estimates that it will take 5 minutes to review each of the anticipated 205 requests to cease retrofit/retirement.

5. Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for respondents and the Agency are summarized below for all activities.

1. Respondent Tally

Table 2 and Table 3 summarize total annual respondent burden and cost by respondent type and activity.

Table 3: Annual Respondent Burden and Cost

Respondent Type	Activity	Number of Respondents	Number of Responses per Respondent	Burden Hours per Response	Annual Burden Hours	Hourly Labor Costs	Annual Labor Costs
Refrigerant Recovery/ Recycling Equipment Testing Organizations	Equipment testing organization applying for approval	0	1	8.0	0	$85.37	$0
	Maintain records of refrigerant recovery/recycling equipment tested and its performance	2	1	0.5	1		$85.37
	Providing notice when equipment fails recertification		1	0.5	1		$85.37
	Publish online a list of all certified equipment		1	0.5	1		$85.37
Refrigerant Reclaimers	Certification by refrigerant reclaimers that change ownership or enter the market	4	1	5.0	20	$59.89	$1,198
	Maintain records of analysis conducted to verify that reclaimed refrigerant meets the necessary specifications	61	260	0.017	264		$15,831
	Reclaimer recordkeeping		50	0.23	714		$42,787
	Annual activity report		1	9.37	572		$34,229
Refrigerant Wholesalers	Recordkeeping for refrigerant sales, including maintenance of technician certification cards from purchasers employing at least one certified technician	11,000	260	0.033	95,333	$56.26	$5,363,358
Technician Certifying Programs	Apply for approval	5	1	5.0	25	$62.87	$1,572
	Recordkeeping by existing technician certification programs	72	1	5.0	360		$22,635
	Maintain list of technicians certified		2	0.08	12		$754
	Biannual reporting by existing technician certification programs		2	1.0	144		$9,054
	Transfer of records when no longer operational	5	1	8.0	40		$2,515
Disposal Establishments	Maintain copies of signed statements of previous refrigerant recovery by disposal establishments	7,500	260	0.058	113,750	$45.55	$5,181,199
Technicians	Technicians acquire certification cards	30,000	1	0.017	501	$45.55	$22,820
	Technicians maintain certification cards	300,000	1	0.017	5,010		$228,200
	Provide invoices for serviced appliances with charge sizes 50 to 500 lbs.		4.23	0.03	42,298		$1,926,615
	Provide invoices for serviced appliances with charge sizes >500 lbs.		3.65	0.03	36,475		$1,661,413
	Provide leak inspection and verification test records		1.28	0.017	6,384		$290,774
	Maintain disposal records for appliances with charge sizes of 5 - 50 lbs.		12	0.017	60,000		$2,732,940
Owners/ Operators of Appliances with Charge Sizes of 50 or More Pounds	Prepare and submit requests for extensions to 30-day repair timeline	4,556	1	0.50	2,278	$88.64	$201,930
	Prepare and submit requests for extensions to 1-year retrofit/retire timeline	61	1	0.5	30		$2,687
	Prepare and submit requests to cease a retrofit/retirement if all leaks are repaired	205	1	0.5	102.3		$9,069
	Prepare and submit report on efforts to repair chronically leaking appliances	1,425	1	1.0	1,425		$126,336
	Maintain records of the full charge of an appliance	542,729	2	0.025	27,136		$2,405,404
	Maintain records of the leak rate calculation		6.25	0.017	56,570		$5,014,420
	Maintain purchase and service records		6.25	0.025	84,855		$5,236,883
	Maintain leak inspection records	281,746	2.73	0.017	6,384		$565,863
	Maintain reports on the results of verification tests any time the leak rate threshold is exceeded	1,425	1	0.025	7,044		$624,357
	Develop/maintain plan to retire/replace or retrofit appliances, as applicable	4,092	1	8.00	32,738		$2,901,923
	Maintain records on mothballed equipment	82	1	0.025	2.05		$181.37
	Maintain information on purged/destroyed refrigerant	4	1	0.025	0.1		$3.75
Small Can Manufacturers	Maintain records of self-sealing valve test data and log forms for 3 years	10	12	0.025	3	$28.98	$87

Table 4: Total Annual Respondent Burden

Number of Respondents	Number of Responses	Hour Burden	Labor Costs
861,374	20,054,738	580,473	$34,627,299

2. The Agency Tally

Table 4 and Table 5 summarize total annual agency burden and cost by and activity.

Table 5: Annual Agency Burden and Cost

Activity	Number of Respondents	Number of Responses per Respondent	Burden Hours to Review each Response	Total Annual Agency Hours	Total Agency Labor Costs
Reclaimer annual activity report	61	1	1.0	61	$3,453
Certification by refrigerant reclaimers that change ownership or enter the market	4	1	1.0	4	$226
Biannual reporting by existing technician certification programs	72	2	1.0	144	$8,152
Technician certification programs applying for approval	5	1	2.0	10	$566
Technician certification programs transferring records	5	1	1.0	5	$283
Owners/operators of appliances w/charge sizes of 50 or more lbs prepare & submit requests for extensions to the 30-day repair timeline	4,556	1	0.25	1,139	$64,478
Owners/operators of appliances w/charge sizes of 50 or more lbs prepare & submit requests for extensions to 1 year retrofit/retire timeline	61	1	1.0	61	$3, 432
Owners/operators of w/charge sizes of 50 or more lbs prepare & submit requests to cease a retrofit/retirement if all leaks are repaired	205	1	0.08	17.1	$965
Owners/operators of appliances that leak 125 percent or more of the full charge in a calendar year to submit report on leak and intended repair	1,431	1	0.17	238.5	$13,501
SUBTOTAL	6,401	varies	varies	1,679	$95,057

Table 6: Total Annual Agency Burden

Number of Respondents	Number of Responses	Hour Burden for Review	Labor Costs
6,401	6,461	1,679	$95,057

Variations in the Annual Bottom Line

EPA anticipates a significant variation (>25%) in the annual respondent reporting /recordkeeping burden or cost over the course of the clearance period. Likewise, the government burdens and costs are anticipated to vary significantly. The rule updating the 40 CFR Part 82, Subpart F regulations has staggered compliance dates that affect the recordkeeping and reporting. Therefore, the burden and cost are expected to increase throughout the course of the clearance period.

Recordkeeping or reporting requirements that do not have a delayed compliance date include the sales restriction, technician certification requirements, and safe disposal requirements (all with respect to ODS).

Many reporting or recordkeeping requirements are newly applicable to substitute refrigerants as of January 1, 2018. These include the sales restriction, technician certification requirements, safe disposal requirements, and reclaimer recordkeeping and reporting. This rule also establishes a compliance date of January 1, 2018, for the new recordkeeping requirements associated with the 1) the disposal of appliances containing more than 5 and less than 50 pounds of refrigerant, and 2) the testing of small cans of substitute refrigerant.

Lastly, this rule establishes a compliance date of January 1, 2019, for the revised leak repair provisions, regardless of whether the appliance contains an ODS or a non-exempt substitute refrigerant.

6. Reasons for Change in Burden

EPA has finalized several regulatory changes to the refrigerant management requirements under Section 608 of the CAA, since the previous renewal of this ICR. The overall reporting and recordkeeping burden as a result of the rule is higher compared to previous ICRs because 1) the universe has expanded to include owners/operators and technicians who service equipment containing HFC- and other non-exempt substitute refrigerant-containing appliances; 2) new requirements to document the disposal of mid-sized comfort cooling and commercial refrigeration appliances; 3) new requirements related to leak inspection, disposal, and self-sealing valves; and 4) EPA has also applied more appropriate labor categories and updated the labor rates. 

EPA has also removed the following recordkeeping and reporting requirements: 1) a one-time certification from new servicing establishments on the quantity and type of recovery equipment owned; and 2) the requirement for refrigerant recovery/recycling equipment testing organizations to submit annual reports.

The net result is an increase in the time and burden associated with to submitting reports and maintaining records in this ICR.

7. Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to range from 1 minute to 9.4 hours per response. The average reporting and recordkeeping burden for this collection is 1.35 hours per response. This estimate includes time for preparing and submitting reports and maintaining records on-site at the respondents’ places of business.

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-2015-0453, which is available for online viewing at www.regulations.gov, or in person 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 OAR Docket is (202) 566-1742. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No. EPA-HQ-OAR-2015-0453 and OMB control number 2060-0256 in any correspondence.

1 Technicians may opt out of this requirement.

2 Bureau of Labor Statistics, U.S. Department of Labor. May 2015 National Occupational Employment and Wage Estimates United States. Available at http://www.bls.gov/oes/current/oes_nat.htm (visited June 30, 2016).

3 In the previous ICR, the burden for preparing the annual activity report was 8.0 hours for submitting the data to EPA. The burden was reduced because the reporting requirement has been replaced with a requirement to post the information online, which is already standard practice for testing organizations.

4 In the previous ICR, the burden for maintaining records was 0.125 hours for ODS appliances only. The recordkeeping burden was scaled upward to include appliances containing HFCs and other non-exempt refrigerants based on the current inventory of ODS versus HFC equipment.

5 In the previous ICR, the burden for preparing the annual activity report was 5.0 hours for ODS appliances only. The recordkeeping burden was scaled upward to include appliances containing HFCs and other non-exempt refrigerants based on the current inventory of ODS versus HFC equipment.

6 In the previous ICR, the burden for collecting and maintaining copies of signed statements or contracts was 3 minutes for ODS appliances only. The recordkeeping burden was scaled upward to include recordkeeping requirements for appliances containing HFCs and other non-exempt refrigerants based on the current inventory of ODS versus HFC equipment.

7 In the previous ICR, EPA had assumed a burden of 1.5 minutes to provide invoices. In this ICR, EPA assumes an additional burden of 0.5 minutes for documenting the additional information required.

8 As noted above, EPA estimates that appliances containing 50 to 500 pounds of refrigerant will be serviced annually, requiring 1 leak rate record, and that appliances with 500 or more pounds will be serviced quarterly, requiring 4 leak rate records.

9 The number of records is based on the total number of equipment and an assumption that appliances containing 50 to 500 pounds of refrigerant will be serviced annually, requiring 1 invoice, and that appliances with 500 or more pounds will be serviced quarterly, requiring 4 invoices.

10 This is calculated based on the total number of appliances that have been found to be above the threshold leak rate, and thus require quarterly or annual leak inspections.

11 See Technical Support Document: Analysis of the Economic Impact and Benefits of Final Revisions to the National Recycling and Emission Reduction Program. September 2, 2016. Available at: https://www.regulations.gov/document?D=EPA-HQ-OAR-2015-0453-0225.

12 All of the following assumptions about the number of owners/operators of comfort cooling, commercial refrigeration, and industrial process refrigeration appliances were developed in the Technical Support Document that accompanies this rulemaking.

13 See Technical Support Document: Analysis of the Economic Impact and Benefits of Final Revisions to the National Recycling and Emission Reduction Program. September 2, 2016. Available at: https://www.regulations.gov/document?D=EPA-HQ-OAR-2015-0453-0225.

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