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Subsection H Leak Repair, Inspection, ALD, and Reclamation Requirements |
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*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** |
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Leak repair 15+ pound threshold (plus school bus AC); ALD for 1500+ pound CR and IPR equipment (50/50 direct and indirect ALD) |
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Assumptions |
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Median Wage (2021) |
Total (+ Overhead) |
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Overhead |
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110% |
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Ref/AC Technicians |
$26.29 |
$55.21 |
Mean hourly earnings for heating, air-conditioning, and refrigeration mechanics and installers (49-9021) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2021/may/oes499021.htm). |
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Owners/Operators |
$47.93 |
$100.65 |
Mean hourly earnings for health and safety engineers (17-2111) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2021/may/oes172111.htm). |
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Manager |
$49.25 |
$103.43 |
Median hourly earnings for management occupations (11-0000) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2021/may/oes110000.htm). |
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Technician (Reclaimer) |
$46.55 |
$97.76 |
Median hourly earnings for environmental engineers (17-2081) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2021/may/oes172081.htm). |
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Lawyer |
$61.54 |
$129.23 |
Median hourly earnings for lawyers (23-1011) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2021/may/oes231011.htm). |
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Office Clerk, General Administration |
$17.81 |
$37.40 |
Median hourly earnings for office clerks, general (43-9061) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2021/may/oes439061.htm). |
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Marketing Manager |
$64.92 |
Garfinkel, Johanna:
Includes fringe rate of 31.2% - https://www.bls.gov/news.release/archives/ecec_06162022.pdf (June 2022)
$178.87 |
Median hourly earnings for marketing managers (11-2021) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2021/may/oes112021.htm). |
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Graphic Designer |
$24.38 |
Garfinkel, Johanna:
Includes fringe rate of 31.2% - https://www.bls.gov/news.release/archives/ecec_06162022.pdf (June 2022)
$67.17 |
Median hourly earnings for graphic designers (27-1024) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2021/may/oes271024.htm). |
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2025 |
2026 |
2027 |
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Year |
Total Responses |
Total Hours |
Total Costs |
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Affected Equipment (above LR threshold) |
Year 1 |
Year 2 |
Year 3 |
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245,340 |
Total ODS equipment, VM, 2025 |
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Year 1 |
8,739,279 |
166,538 |
$12,896,991.26 |
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15-50 pounds (including school buses above 15 pounds) |
201,123 |
205,737 |
210,324 |
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1,348,234 |
Total HFC equipment, VM, 2025 |
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Year 2 |
21,214,466 |
222,260 |
$15,740,028.39 |
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50+ pounds |
143,263 |
150,265 |
157,184 |
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15% |
Proportion of ODS equipment, VM, 2025 |
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Year 3 |
21,366,296 |
223,432 |
$15,966,834.14 |
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50+ pound appliances with quarterly reporting |
12,343 |
12,774 |
13,189 |
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85% |
Proportion of HFC equipment, VM, 2025 |
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Annual Average |
17,106,680 |
204,077 |
$14,867,951.26 |
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CR and IPR Appliances above LR with charge size > 1500 pounds (direct ALD) |
6,180 |
6,225 |
6,246 |
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15% |
15-50 (plus school buses above 15 pounds) Affected Equipment relative to total HFC equipment, VM, 2025 |
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CR and IPR Appliances above LR with charge size > 1500 pounds (indirect ALD) |
6,180 |
6,225 |
6,246 |
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11% |
50+ Affected Equipment relative to total HFC equipment, VM, 2025 |
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Assumed equipment per facility (from CARB data/2016 TSD) |
2.8 |
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New Equipment Installations |
Year 1 |
Year 2 |
Year 3 |
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15-50 pounds (including school buses above 15 pounds) |
51,283 |
52,280 |
53,140 |
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50+ pounds |
112,829 |
113,536 |
114,249 |
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CR and IPR Appliances with charge size > 1500 pounds (direct ALD) |
24,658 |
24,830 |
24,904 |
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CR and IPR Appliances with charge size > 1500 pounds (indirect ALD) |
24,658 |
24,830 |
24,904 |
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20.095209760689 |
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Existing Equipment Installations |
Year 1 |
Year 2 |
Year 3 |
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20.0952097606889 |
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15-50 pounds (including school buses above 15 pounds) |
764,439 |
784,495 |
804,633 |
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50+ pounds |
637,555 |
668,194 |
698,323 |
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RR TSD |
11,787,755 |
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12,199,756 |
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12,607,713 |
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Leak Repair Total |
11,787,755 |
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12,199,756 |
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12,607,713 |
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Requirement Type |
Respondent type |
Activity |
Reg Text Citation |
Affected Equipment |
Year 1 |
Year 2 |
Year 3 |
Number of Responses per Respondent |
Burden Hours (Time) per Response |
Labor Cost per Response |
Year 1 |
Year 1 |
Year 1 |
Year 2 |
Year 2 |
Year 2 |
Year 3 |
Year 3 |
Year 3 |
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Number of Respondents |
Number of Respondents |
Number of Respondents |
Annual Burden Hours |
Annual Labor Costs |
Number of Annual Responses |
Annual Burden Hours |
Annual Labor Costs |
Number of Annual Responses |
Annual Burden Hours |
Annual Labor Costs |
Number of Annual Responses |
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Year 1 |
Year 1 |
Year 1 |
Year 2 |
Year 2 |
Year 2 |
Year 3 |
Year 3 |
Year 3 |
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Average Annual |
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Schultz, Eric:
assumes Reclaimer Reporting and Recordkeeping is split between reporting and recordkeeping categories
Average Annual Per Category |
| Leak |
Reporting |
Owners/operators |
Prepare and submit requests for extensions to 30-day repair timeline |
84.106(m)(1) |
IPR, CC, and CR 15-50 pounds |
[Threaded comment]
Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924
Comment:
Proportionally increased current ICR assumption by ratio of ODS to HFC equipment assumed subject to leak repair requirements.
137 |
141 |
144 |
1.0 |
0.50 |
$50.33 |
68.7 |
$6,914.07 |
137 |
70.3 |
$7,073 |
141 |
71.8 |
$7,230 |
144 |
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Total/Yr All Respondents |
Responses |
Costs |
Hours |
Responses |
Costs |
Hours |
Responses |
Costs |
Hours |
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Total/Yr All Respondents |
Responses |
Costs |
Hours |
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Responses |
Costs |
Hours |
| Leak |
Reporting |
Owners/operators |
IPR, CC, and CR >50 pounds |
[Threaded comment]
Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924
Comment:
Proportionally increased current ICR assumption by ratio of ODS to HFC equipment assumed subject to leak repair requirements.
137 |
144 |
151 |
1.0 |
0.50 |
$50.33 |
68.7 |
$6,914.07 |
137 |
72.0 |
$7,252 |
144 |
75.4 |
$7,586 |
151 |
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Reporting |
Leak Repair/Inspection Reporting |
875 |
$62,044.29 |
616 |
905 |
$64,173.17 |
638 |
935 |
$66,281.44 |
659 |
Reporting |
Leak Repair/Inspection Reporting |
905 |
$64,166.30 |
638 |
Reporting |
12,386,590 |
2,607,224 |
54,046 |
| Leak |
Reporting |
Owners/operators |
Prepare and submit requests for extensions to 1 yr retrofit/retire timeline |
84.106(m)(3) |
IPR, CC, and CR 15-50 pounds |
[Threaded comment]
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Comment:
Proportionally increased current ICR assumption by ratio of ODS to HFC equipment assumed subject to leak repair requirements.
27 |
28 |
29 |
1.0 |
0.50 |
$50.33 |
13.74 |
$1,382.81 |
27 |
14.05 |
$1,415 |
28 |
14.37 |
$1,446 |
29 |
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Recordkeeping |
Leak Repair/Inspection Recordkeeping |
2,469,079 |
$8,511,847.30 |
84,566 |
2,558,100 |
$8,810,726.71 |
87,536 |
2,646,228 |
$9,106,662.38 |
90,476 |
Recordkeeping |
Leak Repair/Inspection Recordkeeping |
2,557,802 |
$8,809,745.46 |
87,526 |
Recordkeeping |
2,558,069 |
8,843,650 |
88,584 |
| Leak |
Reporting |
Owners/operators |
IPR, CC, and CR >50 pounds |
[Threaded comment]
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Comment:
Proportionally increased current ICR assumption by ratio of ODS to HFC equipment assumed subject to leak repair requirements.
27 |
29 |
30 |
1.0 |
0.50 |
$50.33 |
13.7 |
$1,382.81 |
27 |
14.4 |
$1,450 |
29 |
15.1 |
$1,517 |
30 |
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Third-party Reporting |
Leak Repair/Inspection Third-party Reporting |
2,090,767 |
$3,213,863.39 |
58,213 |
2,162,695 |
$3,324,856.28 |
60,223 |
2,233,926 |
$3,434,769.53 |
62,214 |
Third-party Reporting |
Leak Repair/Inspection Third-party Reporting |
2,162,463 |
$3,324,496.40 |
60,217 |
Third-party Reporting |
2,162,473 |
3,328,954 |
60,310 |
| Leak |
Reporting |
Owners/operators |
Prepare and submit request to cease a retrofit if all leaks are repaired |
84.106(m)(2) |
IPR, CC, and CR 15-50 pounds |
[Threaded comment]
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Comment:
Assumes 5% of planned requests are able to repair leaks
101 |
103 |
105 |
1.0 |
0.5 |
$50.33 |
50.3 |
$5,061 |
101 |
51.4 |
$5,177 |
103 |
52.6 |
$5,292 |
105 |
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Reporting |
Fire Suppression Reporting |
20 |
$9,010.84 |
188 |
20 |
$9,010.84 |
188 |
20 |
$9,010.84 |
188 |
Reporting |
Fire Suppression Reporting |
20 |
$9,010.84 |
188 |
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17,107,132 |
14,779,827 |
202,939 |
| Leak |
Reporting |
Owners/operators |
IPR, CC, and CR >50 pounds |
[Threaded comment]
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Comment:
Assumes 5% of planned requests are able to repair leaks
72 |
75 |
79 |
1.0 |
0.5 |
$50.33 |
35.8 |
$3,605 |
72 |
37.6 |
$3,781 |
75 |
39.3 |
$3,955 |
79 |
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Recordkeeping |
Fire Suppression Recordkeeping |
20 |
$38,344.00 |
800 |
20 |
$38,344.00 |
800 |
20 |
$38,344.00 |
800 |
Recordkeeping |
Fire Suppression Recordkeeping |
20 |
$38,344.00 |
800 |
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| Leak |
Reporting |
Owners/operators |
Prepare and submit a report to EPA if appliance leaks 125% or more of the full charge in a 365 day period to describe efforts to identify leaks and repair the appliance |
84.106(m)(4) |
IPR, CC, and CR 15-50 pounds |
[Threaded comment]
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Comment:
Estimated number of "worst leakers" of affected HFC equipment
213 |
218 |
223 |
1.0 |
1.00 |
$100.65 |
213 |
$21,471.37 |
213 |
218 |
$21,964 |
218 |
223 |
$22,454 |
223 |
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Reporting |
Cylinder Tracking |
4,178,488 |
$1,048,508.96 |
21,876 |
16,492,695 |
$3,433,484.19 |
71,635 |
16,485,136 |
$3,252,332.75 |
67,856 |
Reporting |
Cylinder Tracking |
12,385,440 |
$2,578,108.63 |
53,789 |
|
|
|
|
| Leak |
Reporting |
Owners/operators |
IPR, CC, and CR >50 pounds |
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Comment:
Estimated number of "worst leakers" of affected HFC equipment
152 |
159 |
167 |
1.0 |
1.00 |
$100.65 |
152 |
$15,294.42 |
152 |
159 |
$16,042 |
159 |
167 |
$16,780 |
167 |
|
Third-party Reporting |
Reclamation |
31 |
$13,372.47 |
279 |
- |
$0.00 |
- |
- |
$0.00 |
- |
Third-party Reporting |
Reclamation |
10 |
$4,457.49 |
93 |
|
|
|
|
| Leak |
Reporting |
Owners/operators |
Prepare and submit a report to EPA if excluding purged refrigerants that are destroyed from annual leak rate calculations for the first time |
84.106(m)(5) |
IPR, CC, and CR 15-50 pounds |
4 |
4 |
4 |
1.0 |
0.03 |
$2.52 |
0.094 |
$9.43 |
4 |
0.096 |
$10 |
4 |
0.098 |
$10 |
4 |
|
Recordkeeping |
Reclamation |
- |
$0.00 |
- |
31 |
$59,433.20 |
1,240 |
31 |
$59,433.20 |
1,240 |
Recordkeeping |
Reclamation |
21 |
$39,622.13 |
827 |
|
|
|
|
| Leak |
Reporting |
Owners/operators |
IPR, CC, and CR >50 pounds |
4 |
4 |
4 |
1.0 |
0.03 |
$2.52 |
0.094 |
$9.43 |
4 |
0.098 |
$10 |
4 |
0.103 |
$10 |
4 |
|
|
Total Reporting and Recordkeeping Recordkeeping |
8,739,279 |
$12,896,991.26 |
166,538 |
21,214,466 |
$15,740,028.39 |
222,260 |
21,366,296 |
$15,966,834.14 |
223,432 |
|
Total Reporting and Recordkeeping Recordkeeping |
17,106,680 |
$14,867,951.26 |
204,077 |
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
Maintain purchase and service records. For each refrigerant addition, equipment owner has to have records of:
(i) The identity and location of the appliance;
(ii) The date of the installation, service, repair, or disposal performed;
(iii) The part(s) of the appliance being serviced, repaired, or disposed;
(iv) The type of service, repair, or disposal performed for each part;
(v) The name of the person performing the installation, service, repair, or disposal;
(vi) The amount and type of refrigerant added to, or in the case of disposal removed from, the appliance;
(vii) The full charge of the appliance; and
(viii) The leak rate and the method used to determine the leak rate (not applicable when disposing of the appliance, following a retrofit, installing a new appliance, or if the refrigerant addition qualifies as a seasonal variance). |
84.106(l)(2); 84.106(l)(11) |
IPR, CC, and CR 15-50 pounds |
268,969 |
275,140 |
281,274 |
2.8 |
0.025 |
$2.516 |
19,111 |
$1,923,576.20 |
764,439 |
19,549 |
$1,967,706 |
781,976 |
19,985 |
$2,011,573 |
799,409 |
|
|
Reclaimer Reporting and Recordkeeping |
452 |
(88,124) |
(1,138) |
452 |
(88,124) |
(1,138) |
452 |
(88,124) |
(1,138) |
|
Reclaimer Reporting and Recordkeeping |
452 |
$(88,124.09) |
(1,138) |
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
224,325 |
235,288 |
246,121 |
2.8 |
0.025 |
$2.516 |
15,939 |
$1,604,294.96 |
637,555 |
16,718 |
$1,682,701 |
668,714 |
17,488 |
$1,760,174 |
699,502 |
|
|
Total with Avoided Costs |
8,739,731 |
$12,808,867.17 |
165,400 |
21,214,918 |
$15,651,904.30 |
221,122 |
21,366,748 |
$15,878,710.06 |
222,294 |
|
Total with Avoided Costs |
17,107,132 |
$14,779,827.18 |
202,939 |
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
Maintain equipment installation records:
(i) The identification of the owner or operator of the appliance;
(ii) The address where the appliance is located;
(iii) The full charge of the appliance and the method for how the full charge was determined;
(iv) If using method 4 (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;
(v) Any revisions of the full charge, how they were determined, and the dates such revisions occurred; and
(vi) The date of installation. |
84.106(l)(1) |
IPR, CC, and CR 15-50 pounds |
51,283 |
52,460 |
53,629 |
1.0 |
0.025 |
$2.516 |
1,282 |
$129,045.53 |
51,283 |
1,311 |
$132,006 |
52,460 |
1,341 |
$134,949 |
53,629 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
112,829 |
118,343 |
123,792 |
1.0 |
0.025 |
$2.516 |
2,821 |
$283,913.97 |
112,829 |
2,959 |
$297,790 |
118,343 |
3,095 |
$311,500 |
123,792 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
Maintain retrofit and/or retirement plans |
84.106(l)(7) |
IPR, CC, and CR 15-50 pounds |
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Comment:
Analysis assumes 1% of equipment experiences retrofit outcome
2,011 |
2,057 |
2,103 |
1.0 |
8.00 |
$805.22 |
16,090 |
$1,619,492.42 |
2,011 |
16,459 |
$1,656,646 |
2,057 |
16,826 |
$1,693,578 |
2,103 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
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Comment:
Analysis assumes 1% of equipment experiences retrofit outcome
1,433 |
1,503 |
1,572 |
1.0 |
8.00 |
$805.22 |
11,461 |
$1,153,591.97 |
1,433 |
12,021 |
$1,209,971 |
1,503 |
12,575 |
$1,265,679 |
1,572 |
|
|
Total Annual Responses: |
Year 1 |
Year 1 |
Year 2 |
Year 2 |
Year 3 |
Year 3 |
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
Maintain records documenting when the system was mothballed and when it was brought back on-line (i.e., when refrigerant was added back into the appliance or isolated component of the appliance) |
84.106(l)(9) |
IPR, CC, and CR 15-50 pounds |
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Comment:
Assumed 2% of systems with retire/replace or retrofit plan
40 |
41 |
42 |
1.0 |
0.025 |
$2.52 |
1.01 |
$101.22 |
40 |
1.03 |
$104 |
41 |
1.05 |
$106 |
42 |
|
|
Burden Per Response |
Hours Per Response |
Cost Per Response (including non-labor) |
Hours Per Response |
Cost Per Response (including non-labor) |
Hours Per Response |
Cost Per Response (including non-labor) |
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
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Comment:
Assumed 2% of systems with retire/replace or retrofit plan
29 |
30 |
31 |
1.0 |
0.025 |
$2.52 |
0.72 |
$72.10 |
29 |
0.75 |
$76 |
30 |
0.79 |
$79 |
31 |
|
Reporting |
Leak Repair/Inspection Reporting |
0.70 |
$70.93 |
0.70 |
$70.92 |
0.70 |
$70.90 |
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
Maintain records of purged and destroyed refrigerant if excluding such refrigerant from the leak rate |
84.106(l)(10) |
IPR, CC, and CR 15-50 pounds |
4 |
4 |
4 |
1.0 |
0.025 |
$2.52 |
0.09 |
$9 |
4 |
0.10 |
$10 |
4 |
0.10 |
$10 |
4 |
|
Recordkeeping |
Leak Repair/Inspection Recordkeeping |
0.03 |
$3.45 |
0.03 |
$3.44 |
0.03 |
$3.44 |
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
4 |
4 |
4 |
1.0 |
0.025 |
$2.52 |
0.09 |
$9 |
4 |
0.10 |
$10 |
4 |
0.10 |
$10 |
4 |
|
Third-party Reporting |
Leak Repair/Inspection Third-party Reporting |
0.03 |
$1.54 |
0.03 |
$1.54 |
0.03 |
$1.54 |
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
Maintain reports on the results of verification tests any time leak rate threshold is exceeded |
84.106(l)(6) |
IPR, CC, and CR 15-50 pounds |
201,123 |
205,737 |
210,324 |
1.0 |
0.03 |
$2.52 |
5,028 |
$506,091.38 |
201,123 |
5,143 |
$517,702 |
205,737 |
5,258 |
$529,243 |
210,324 |
|
Reporting |
Fire Suppression Reporting |
9.40 |
$450.54 |
9.40 |
$450.54 |
9.40 |
$450.54 |
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
143,263 |
150,265 |
157,184 |
1.0 |
0.03 |
$2.52 |
3,582 |
$360,497.49 |
143,263 |
3,757 |
$378,116 |
150,265 |
3,930 |
$395,525 |
157,184 |
|
Recordkeeping |
Fire Suppression Recordkeeping |
40.00 |
$1,917.20 |
40.00 |
$1,917.20 |
40.00 |
$1,917.20 |
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
Maintain quarterly leak inspection records |
84.106(l)(4) |
IPR and CR >500 pounds |
49,373 |
51,786 |
54,170 |
4.0 |
0.02 |
$1.68 |
3,292 |
$331,300 |
197,490 |
3,452 |
$347,491 |
207,142 |
3,611 |
$363,490 |
216,679 |
|
Reporting |
Cylinder Tracking |
0.01 |
$0.25 |
0.00 |
$0.21 |
0.00 |
$0.20 |
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
Maintain annual leak inspection records |
84.106(l)(4) |
IPR, CC, and CR 15-50 pounds |
201,123 |
205,737 |
210,324 |
1.0 |
0.02 |
$1.68 |
3,352 |
$337,394.26 |
201,123 |
3,429 |
$345,135 |
205,737 |
3,505 |
$352,829 |
210,324 |
|
Third-party Reporting |
Reclamation |
9.00 |
$431.37 |
0.00 |
$0.00 |
0.00 |
$0.00 |
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
130,920 |
137,319 |
143,641 |
1.0 |
0.02 |
$1.68 |
2,182 |
$219,625.43 |
130,920 |
2,289 |
$230,359 |
137,319 |
2,394 |
$240,965 |
143,641 |
|
Recordkeeping |
Reclamation |
0.00 |
$0.00 |
40.00 |
$1,917.20 |
40.00 |
$1,917.20 |
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
Maintain copies of any reports submitted to EPA under the proposed reporting requirements in this action |
84.106(l)(8);84.106(l)(12) |
IPR, CC, and CR 15-50 pounds |
482 |
494 |
505 |
1.0 |
0.02 |
$1.68 |
8 |
$809.40 |
482 |
8 |
$828 |
494 |
8 |
$846 |
505 |
|
|
Average for Reporting and Recordkeeping |
0.02 |
1.48 |
0.01 |
0.74 |
0.01 |
0.75 |
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
392 |
411 |
430 |
1.0 |
0.02 |
$1.68 |
7 |
$657.92 |
392 |
7 |
$690 |
411 |
7 |
$722 |
430 |
|
|
Reclaimer Reporting and Recordkeeping |
-2.52 |
-$194.96 |
-2.52 |
-$194.96 |
-2.52 |
-$194.96 |
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
Maintain records regarding the installation and annual calibration or audit of the ALD system, a record of each date the monitoring system identified a leak, and the location of the leak. Records must be maintained each time an ALD system detects a leak, whether that be based on the applicable ppm threshold for a direct ALD system or the indicated loss of refrigerant measured in an indirect ALD system. |
84.106(l)(5); 84.108(j) |
IPR and CR >1500 pounds with indirect ALD |
24,658 |
25,863 |
27,054 |
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Comment:
Assuming 50% of ALD systems are direct with leak calculation and data storage capabilities, so burden only assumed for equipment with indirect ALD.
1.0 |
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Comment:
Assuming 50% of ALD systems are direct with leak calculation and data storage capabilities, so burden only assumed for equipment with indirect ALD.
0.02 |
$1.68 |
411 |
$41,364.51 |
24,658 |
431 |
$43,386 |
25,863 |
451 |
$45,384 |
27,054 |
|
|
Overall Average (including avoided Reclaimer) |
0.02 |
$1.47 |
0.01 |
$0.74 |
0.01 |
$0.74 |
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Third-party Reporting |
Tehnicians |
Persons servicing HFC appliances provide leak inspection records to owners/operators |
84.106(l)(4) |
IPR, CC, and CR 15-50 pounds |
300,000 |
306,882 |
313,724 |
0.67 |
0.017 |
$0.92 |
3,352 |
$185,063.53 |
201,123 |
3,429 |
$189,309 |
205,737 |
3,505 |
$193,529 |
210,324 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Third-party Reporting |
Tehnicians |
IPR, CC, and CR >50 pounds |
300,000 |
314,662 |
329,149 |
0.48 |
0.017 |
$0.92 |
2,388 |
$131,823.90 |
143,263 |
2,504 |
$138,267 |
150,265 |
2,620 |
$144,632 |
157,184 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Third-party Reporting |
Tehnicians |
Persons servicing HFC appliances provide reports on the results of verification tests any time leak rate threshold is exceeded to owners/operators |
84.106(l)(6) |
IPR, CC, and CR 15-50 pounds |
300,000 |
306,882 |
313,724 |
0.67 |
0.017 |
$0.92 |
3,352 |
$185,063.53 |
201,123 |
3,429 |
$189,309 |
205,737 |
3,505 |
$193,529 |
210,324 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Third-party Reporting |
Tehnicians |
IPR, CC, and CR >50 pounds |
300,000 |
314,662 |
329,149 |
0.48 |
0.017 |
$0.92 |
2,388 |
$131,823.90 |
143,263 |
2,504 |
$138,267 |
150,265 |
2,620 |
$144,632 |
157,184 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Third-party Reporting |
Technicians |
Persons servicing appliances w/charge sizes >15 lbs provide invoices to appliance owners/operators containing the following information:
(i) The identity and location of the appliance;
(ii) The date of the installation, service, repair, or disposal performed;
(iii) The part(s) of the appliance being serviced, repaired, or disposed;
(iv) The type of service, repair, or disposal performed for each part;
(v) The name of the person performing the installation, service, repair, or disposal;
(vi) The amount and type of refrigerant added to, or in the case of disposal removed from, the appliance;
(vii) The full charge of the appliance; and
(viii) The leak rate and the method used to determine the leak rate (not applicable when disposing of the appliance, following a retrofit, installing a new appliance, or if the refrigerant addition qualifies as a seasonal variance). |
84.106(l)(3) |
IPR, CC, and CR 15-50 pounds |
300,000 |
306,882 |
313,724 |
2.55 |
0.033 |
$1.840 |
25,481 |
$1,406,797 |
764,439 |
26,066 |
$1,439,071 |
781,976 |
26,647 |
$1,471,152 |
799,409 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Third-party Reporting |
Technicians |
IPR, CC, and CR >50 pounds |
300,000 |
314,662 |
329,149 |
2.13 |
0.033 |
$1.840 |
21,252 |
$1,173,292.01 |
637,555 |
22,290 |
$1,230,634 |
668,714 |
23,317 |
$1,287,294 |
699,502 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Fire |
Reporting |
Fire Suppression System OEMs/Servicers/Recyclers |
Must report annually:
(i) The quantity of material (combined mass of regulated substance and contaminants) by regulated substance sold, recovered, recycled, and virgin for the purpose of installation of new equipment and servicing of fire suppression equipment
(ii) The total mass of each regulated substance sold, recovered, recycled, and virgin and;
(iii) The total mass of waste products sent for disposal, along with information about the disposal facility if waste is not processed by the reporting entity |
84.110(g) |
HFC Fire Suppression Equipment |
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Comment:
15 HEEP reporters + 5 additional companies that do not have to report to HEEP (e.g., OEMs that do not also refill equipment)
20 |
20 |
20 |
1 |
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Comment:
Based off 2024 Allocation Rule assumption for quarterly report - assumed that the amount of time will be the same because they'll already have the data
9.40 |
$946.14 |
188 |
$9,010.84 |
20 |
188 |
$9,011 |
20 |
188 |
$9,011 |
20 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Fire |
Recordkeeping |
Fire Suppression System OEMs/Servicers/Recyclers |
Maintain records on:
- Data submitted to EPA annually
- Fire suppression technican training provided to personnel
- HFCs recovered from fire suppression equipment before it's sent for disposal (i.e., recovering themselves or leaving HFC in and sending to disposal facility) |
84.110(g)(1)-(3) |
HFC Fire Suppression Equipment |
20 |
20 |
20 |
1 |
40 |
$4,026.12 |
800 |
$38,344.00 |
20 |
800 |
$38,344 |
20 |
800 |
$38,344 |
20 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Reclamation |
Third-party Reporting |
HFC Reclaimers |
One-time label redesign |
84.112(c) |
Cylinders |
31 |
0 |
0 |
1 |
9.00 |
Garfinkel, Johanna:
Assumed 3.5 hours for administrative activities (marketing managers) and 5.5 hours for graphic design
$995.48 |
279 |
$13,372.47 |
31 |
- |
$- |
- |
- |
$- |
- |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Reclamation |
Recordkeeping |
HFC Reclaimers |
Maintain records on:
- the name, address, contact person, email address, and phone number of the certified reclaimer,
- the date the container was filled with reclaimed HFCs, the amount and name of the HFC(s) in the container,
- percent of virgin HFCs in the container,
- certification that the contents do not exceed 15 percent virgin HFCs,
- the serial number of the container, and
- identification of the batch of reclaimed HFCs used to fill the container |
84.112(d)(3) |
Cylinders |
0 |
31 |
31 |
1 |
40.00 |
$1,496.04 |
- |
$- |
- |
1,240 |
$59,433 |
31 |
1,240 |
$59,433 |
31 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| QR |
Reporting |
Fire Suppression Agent Recyclers |
Register with tracking ID system |
84.118(d)(5) |
Cylinders |
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Comment:
Assumed that 25% of respondents start registering and reporting before the required start date
1 |
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Comment:
Assumptions based on 2024 HFC Allocation Rule
3 |
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Comment:
Assumptions based on 2024 HFC Allocation Rule
1 |
1 |
0.50 |
Garfinkel, Johanna:
Assumed burden for "environmental engineers" for tracking ID system activities
$48.88 |
1 |
$23.97 |
1 |
2 |
$72 |
3 |
1 |
$24 |
1 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| QR |
Reporting |
Fire Suppression Agent Recyclers |
Enter data into tracking ID system |
84.118(d)(3) |
Cylinders |
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Comment:
Assumed that 25% of respondents start registering and reporting before the required start date
1 |
4 |
4 |
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Comment:
Assumes fire suppression agent recyclers scan cylinders upon return also (2X)
105882 |
0.006 |
$0.54 |
588 |
$28,194.02 |
105,882 |
2,353 |
$112,776 |
423,528 |
2,353 |
$112,776 |
423,528 |
|
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|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| QR |
Reporting |
HFC Producers |
Register with tracking ID system |
84.118(d)(5) |
Cylinders |
10 |
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Comment:
Assumptions based on 2024 HFC Allocation Rule
1 |
1 |
1 |
0.50 |
$48.88 |
5 |
$239.65 |
10 |
1 |
$24 |
1 |
1 |
$24 |
1 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| QR |
Reporting |
HFC Producers |
Enter data into tracking ID system |
84.118(d)(4) |
Cylinders |
10 |
10 |
10 |
26 |
2.000 |
$195.51 |
520 |
$24,923.60 |
260 |
520 |
$24,924 |
260 |
520 |
$24,924 |
260 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| QR |
Reporting |
HFC Importers |
Register with tracking ID system |
84.118(d)(5) |
Cylinders |
75 |
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Comment:
Assumptions based on 2024 HFC Allocation Rule
1 |
1 |
1 |
0.50 |
$48.88 |
38 |
$1,797.38 |
75 |
1 |
$24 |
1 |
1 |
$24 |
1 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| QR |
Reporting |
HFC Importers |
Enter data into tracking ID system |
84.118(d)(1) |
Cylinders |
75 |
75 |
75 |
26 |
2.000 |
$195.51 |
3,900 |
$186,927.00 |
1,950 |
3,900 |
$186,927 |
1,950 |
3,900 |
$186,927 |
1,950 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| QR |
Reporting |
HFC Fillers and Packagers |
Register with tracking ID system |
84.118(d)(5) |
Cylinders |
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Comment:
Assumed that 25% of respondents start registering and reporting before the required start date
13 |
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Comment:
Assumptions based on 2024 HFC Allocation Rule
37 |
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Comment:
Assumptions based on 2024 HFC Allocation Rule
1 |
1 |
0.50 |
$48.88 |
7 |
$311.55 |
13 |
19 |
$887 |
37 |
1 |
$24 |
1 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| QR |
Reporting |
HFC Fillers and Packagers |
Enter data into tracking ID system |
84.118(d)(4) |
Cylinders |
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Comment:
Assumed that 25% of respondents start registering and reporting before the required start date
13 |
50 |
50 |
52941 |
0.006 |
$0.54 |
3,824 |
$183,261.15 |
688,233 |
14,706 |
$704,851 |
2,647,050 |
14,706 |
$704,851 |
2,647,050 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| QR |
Reporting |
HFC Suppliers |
Register with tracking ID system |
84.118(d)(6) |
Cylinders |
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Comment:
Assumed that 25% of respondents start registering and reporting before the required start date
2,500 |
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Comment:
Assumptions based on 2024 HFC Allocation Rule
7,500 |
1 |
1 |
0.500 |
$48.88 |
1,250 |
$59,912.50 |
2,500 |
3,750 |
$179,738 |
7,500 |
1 |
$24 |
1 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| QR |
Reporting |
HFC Suppliers |
Enter data into tracking ID system |
84.118(c)(4) |
Cylinders |
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Comment:
Assumed that 25% of respondents start registering and reporting before the required start date
2,500 |
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Comment:
Assumptions based on 2024 HFC Allocation Rule
10,000 |
10,000 |
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Comment:
Assumes suppliers receive and scan half cylinders upon return also (1.5X)
1013 |
0.003 |
$0.27 |
7,035 |
$337,174.24 |
2,532,500 |
28,139 |
$1,348,697 |
10,130,000 |
28,139 |
$1,348,697 |
10,130,000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| QR |
Reporting |
HFC Reclaimers |
Register with tracking ID system |
84.118(d)(5) |
Cylinders |
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Comment:
Assumed that 25% of respondents start registering and reporting before the required start date
8 |
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Comment:
Assumptions based on 2024 HFC Allocation Rule
23 |
1 |
1 |
0.50 |
$48.88 |
4 |
$191.72 |
8 |
11.5 |
$551 |
23 |
1 |
$24 |
1 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| QR |
Reporting |
HFC Reclaimers |
Enter data into tracking ID system |
84.118(d)(2) |
Cylinders |
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Comment:
Assumed that 25% of respondents start registering and reporting before the required start date
8 |
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Comment:
Assumptions based on 2024 HFC Allocation Rule
31 |
31 |
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Comment:
Assumes reclaimers scan cylinders upon return also (2X)
105882 |
0.006 |
$0.54 |
4,706 |
$225,552.19 |
847,056 |
18,235 |
$874,015 |
3,282,342 |
18,235 |
$874,015 |
3,282,342 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
ANNUAL TOTAL |
|
|
3,218,421 |
3,345,826 |
3,452,004 |
265,822 |
127 |
|
166,538 |
$12,896,991 |
8,739,279 |
222,260 |
$15,740,028 |
21,214,466 |
223,432 |
$15,966,834 |
21,366,296 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
3 YEAR TOTAL |
|
|
10,016,251 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
ANNUAL AVERAGE |
|
|
3,338,750 |
|
|
|
Average Labor Costs |
Average Number of Responses |
Average Burden Hours |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Unique Respondents |
|
|
795,920 |
824,996 |
851,304 |
|
|
|
$14,867,951 |
17,106,680 |
204,077 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
- |
- |
- |
- |
- |
- |
- |
- |
- |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Requirement Type |
Respondent type |
Activity |
AVOIDED Hours per Activity per Respondent and Loaded Hourly Wages |
Burden Hours/Activity |
AVOIDED Labor Costs/Activity |
AVOIDED Capital Costs |
AVOIDED O&M Costs |
Total Hours and Costs |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Legal |
Manager |
Technical |
Clerical |
Number of Respondents/Activity |
Annual Burden Hours |
Total Cost/Year |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
$129.23 |
$103.43 |
$97.76 |
$37.40 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Contingency Planning |
Reclaimer |
Collect data required in contingency plan |
0.00 |
0.00 |
(3.35) |
(1.65) |
(5.00) |
$(389.19) |
$- |
$- |
63.00 |
(315.00) |
$(24,519) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Document whether authorities decline arrangement |
0.00 |
0.00 |
0.00 |
(0.50) |
(0.50) |
$(18.70) |
$- |
$- |
63.00 |
(31.50) |
$(1,178) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Write contingency plan |
0.00 |
0.00 |
(7.50) |
(2.50) |
(10.00) |
$(826.67) |
$- |
$- |
63.00 |
(630.00) |
$(52,080) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Maintain contingency plan |
0.00 |
0.00 |
0.00 |
(1.00) |
(1.00) |
$(37.40) |
$- |
$- |
63.00 |
(63.00) |
$(2,356) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Submit contingency plan to relevant emergency centers |
0.00 |
0.00 |
0.00 |
(0.50) |
(0.50) |
$(18.70) |
$- |
$(4.87) |
63.00 |
(31.50) |
$(1,485) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Amend contingency plan when appropriate |
0.00 |
0.00 |
(5.00) |
0.00 |
(5.00) |
$(488.78) |
$- |
$(0.10) |
6.00 |
(30.00) |
$(2,933) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Emergency Procedures |
Reclaimer |
Collect information |
0.00 |
0.00 |
(0.22) |
(1.50) |
(1.72) |
$(77.61) |
$- |
$- |
1.00 |
(1.72) |
$(78) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Emergency reporting |
(1.28) |
0.00 |
(0.90) |
0.00 |
(2.18) |
$(253.40) |
$- |
$- |
1.00 |
(2.18) |
$(253) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Notifying/coordination with authorities |
0.00 |
(0.10) |
(0.90) |
0.00 |
(1.00) |
$(98.32) |
$- |
$(11.35) |
1.00 |
(1.00) |
$(110) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Personnel Training |
Reclaimer |
Collect job-related data |
0.00 |
0.00 |
(0.50) |
0.00 |
(0.50) |
$(48.88) |
$- |
$- |
1.00 |
(0.50) |
$(49) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Maintain information at facility |
0.00 |
0.00 |
0.00 |
(0.10) |
(0.10) |
$(3.74) |
$- |
$- |
1.00 |
(0.10) |
$(4) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Emergency Procedures |
Reclaimer |
Observe scene of hazardous waste discharge |
0.00 |
0.00 |
(0.50) |
0.00 |
(0.50) |
$(48.88) |
$- |
$- |
0.00 |
0.00 |
$- |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Report by phone requested data items to NRC |
0.00 |
0.00 |
(0.50) |
0.00 |
(0.50) |
$(48.88) |
$- |
$(5.29) |
0.00 |
0.00 |
$- |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Document that local officials decline to enter into arrangements for coordinating response |
0.00 |
0.00 |
(0.10) |
0.00 |
(0.10) |
$(9.78) |
$- |
$- |
0.00 |
0.00 |
$- |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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|
|
|
|
|
|
Reclaimer |
Post emergency information by phone |
0.00 |
0.00 |
0.00 |
(0.10) |
(0.10) |
$(3.74) |
$- |
$- |
0.00 |
0.00 |
$- |
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No Speculative Accumulation 40 CFR 266.602(a)(2) and (b)(3) |
Reclaimer |
Label containers in accumulation area with start date |
0.00 |
0.00 |
(0.25) |
0.00 |
(0.25) |
$(24.44) |
$- |
$- |
63.00 |
(15.75) |
$(1,540) |
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Reclaimer |
Inventory logs must demonstrate that at least 75% by weight or volume of material being recycled is transferred to a different site for recycling in a calendar year. |
0.00 |
0.00 |
(0.25) |
0.00 |
(0.25) |
$(24.44) |
$- |
$- |
63.00 |
(15.75) |
$(1,540) |
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-21.61 |
452 |
-1138 |
$(88,124) |
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| Section 608 ICR assumptions used as the basis for burden estimates for R&R associated with leak repair and leak inspection under Subsection H |
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*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** |
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| National Refrigerant Recycling and Emissions Reduction Program, EPA ICR Number: 1626.18, OMB Control Number: 2060-0256 |
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| Annual Respondent Burden and Cost |
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| Assumptions |
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Median Wage (2021) |
Total (+ Overhead) |
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110% |
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| Refrigerant Recovery/Recycling Equipment Testing Organization |
$48.18 |
$101.18 |
Median hourly earnings for environmental engineers (17-2081) from the Bureau of Labor Statistics (http://www.bls.gov/oes/current/oes172081.htm) |
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| Refrigerant Reclaimers |
$33.18 |
$69.68 |
Median hourly earnings for chemical plant and system operators (51-8091) from the Bureau of Labor Statistics (http://www.bls.gov/oes/current/oes518091.htm) |
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| Refrigerant Wholesalers |
$34.81 |
$73.10 |
Median hourly earnings for sales representatives, wholesale (41-4012) from the Bureau of Labor Statistics (http://www.bls.gov/oes/current/oes414012.htm) |
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| Technician Certification Programs |
$33.92 |
$71.23 |
Median hourly earnings for instructional coordinators (25-9031) from the Bureau of Labor Statistics (http://www.bls.gov/oes/current/oes259031.htm). |
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| Disposal Establishments |
$26.29 |
$55.21 |
Assumes a technician is needed for disposal of equipment. Median hourly earnings for heating, air-conditioning, and refrigeration mechanics and installers from the Bureau of Labor Statistics (http://www.bls.gov/oes/current/oes499021.htm). |
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| Technicians |
$26.29 |
$55.21 |
Median hourly earnings for heating, air-conditioning, and refrigeration mechanics and installers from the Bureau of Labor Statistics (http://www.bls.gov/oes/current/oes499021.htm). |
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| Owners/Operators |
$47.93 |
$100.65 |
Median hourly earnings for health and safety engineers (17-2111) from the Bureau of Labor Statistics (http://www.bls.gov/oes/current/oes172111.htm). |
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| Small Can Manufacturers |
$19.01 |
$39.92 |
Median hourly earnings for Weighers, Measurers, Checkers, and Samplers, Recordkeeping occupational workers from the Bureau of Labor Statistics (http://www.bls.gov/oes/current/oes435111.htm). |
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| Respondent Tally |
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| Respondent |
Activity |
Number of Respondents |
Number of Responses per Respondent |
Burden Hours (Time) per Response |
Per Respondent |
All Respondents |
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| Annual Burden Hours |
Annual Labor Cost |
Annual Burden Hours |
Annual Labor Costs |
Number of Annual Responses |
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| Refrigerant Recovery/ Recycling Equipment Testing Organization |
Apply for approval |
- |
1 |
8.00 |
8.0 |
$809.42 |
- |
$0 |
- |
1 |
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| Provide notice when equipment fails recertification |
2 |
1 |
0.50 |
0.5 |
$50.59 |
1 |
$101 |
2 |
1 |
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Total/Yr All Respondents |
Responses |
Costs |
Hours |
| Publish online list of all certified equipment |
2 |
1 |
0.50 |
0.5 |
$50.59 |
1.00 |
$101 |
2 |
3 |
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Reporting |
372.00 |
$63,879.84 |
849.17 |
| Maintain records of equipment tested and its performance |
2 |
1 |
0.50 |
0.5 |
$50.59 |
1.000 |
$101 |
2 |
2 |
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Recordkeeping |
12,248,596.94 |
$28,881,883.45 |
379,615.17 |
| Refrigerant Reclaimers |
Submit annual activity report |
Golla, Emily:
Updated to reflect 2021 report submissions and new reporters expected for 2022
56 |
1 |
9.37 |
9.4 |
$652.82 |
525 |
$36,558 |
56 |
1 |
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Third Party |
1,449,543.99 |
$2,487,182.87 |
45,049.48 |
| Provide certification when changing ownership or entering the market |
Golla, Emily:
Updated based on input from EPA
2 |
1 |
5.00 |
5.0 |
$348.39 |
10 |
$697 |
2 |
1 |
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Total |
13,698,513 |
31,432,946 |
425,513.83 |
| Maintain records of refrigerant sales transactions |
56 |
50 |
0.23 |
11.7 |
$812.91 |
653 |
$45,523 |
2,800 |
2 |
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- |
- |
- |
| Maintain records that analysis conducted to verify that reclaimed refrigerant meets the necessary specifications |
56 |
260 |
0.02 |
4.3 |
$301.94 |
243 |
$16,909 |
14,560 |
2 |
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|
Total Annual Responses: |
13,698,513 |
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| Refrigerant Wholesalers |
Maintain records for refrigerant sales, including technician certification cards from purchasers employing at least one certified technician |
Golla, Emily:
Based on data on the number of wholesaler locations from Heating, Air-conditioning & Refrigeration Distributors International (HARDI) and consistent with assumptions used in the HFC Allocation Rule ICR (Recordkeeping and Reporting of the Hydrofluorocarbon Allowance Allocation and Trading Program).
10,000 |
260 |
0.03 |
8.7 |
$633.54 |
86,667 |
$6,335,420 |
2,600,000 |
2 |
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Burden Per Response |
Hours Per Response |
Cost Per Response (including non-labor) |
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| Technician Certification Programs |
Apply for approval |
3 |
1 |
5.00 |
5.0 |
$356.16 |
15 |
$1,068 |
3 |
1 |
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Reporting |
2.28 |
$171.72 |
|
| Maintain list/database of technicians certified |
Golla, Emily:
Updated to reflect 2021 report submissions
74 |
2 |
0.08 |
0.2 |
$11.87 |
12 |
$879 |
148 |
2 |
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Recordkeeping |
0.03 |
$2.36 |
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| Submit biannual report |
Golla, Emily:
Updated to reflect 2021 report submissions
74 |
2 |
1.00 |
2.0 |
$142.46 |
148 |
$10,542 |
148 |
1 |
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Third Party |
0.03 |
$1.72 |
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| Transfer records when no longer operational |
1 |
1 |
8.00 |
8.0 |
$569.86 |
8 |
$570 |
1 |
1 |
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Average |
0.03 |
$2.29 |
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| Recordkeeping by existing Technician Certification Programs |
74 |
1 |
5.00 |
5.0 |
$356.16 |
370 |
$26,356 |
74 |
2 |
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| Disposal Establishments |
Maintain copies of signed statements of previous refrigerant recovery by disposal establishments |
7,500 |
260 |
0.06 |
15.2 |
$837.34 |
113,750 |
$6,280,024 |
1,950,000 |
2 |
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Annual Burden |
Annual Time Burden (Hours) |
Annual non-labor costs |
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| Technicians |
Acquire certification cards |
30,000 |
1 |
0.02 |
0.02 |
$0.92 |
500 |
$27,605 |
30,000 |
3 |
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Reporting |
849 |
N/A |
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| Maintain certification cards |
300,000 |
1 |
0.02 |
0.02 |
$0.92 |
5,000 |
$276,045 |
300,000 |
2 |
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Recordkeeping |
379,615 |
N/A |
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| Provide invoices for serviced ODS appliances with charge sizes 50 to 500 lbs. |
300,000 |
Golla, Emily:
Based on # of ODS equipment needing general servicing (i.e., topups) from 2016. Assumes 1 invoices.
2.2 |
0.03 |
0.1 |
$4.06 |
22,079 |
$1,218,954 |
662,367 |
3 |
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Third Party |
45,049 |
N/A |
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| Provide invoices for serviced ODS appliances with charge sizes >500 lbs. |
300,000 |
Golla, Emily:
Based on # of ODS equipment needing general servicing (i.e., topups) from 2016. Assumes 4 invoices.
2.0 |
0.03 |
0.1 |
$3.63 |
19,700 |
$1,087,617 |
591,000 |
3 |
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| Provide leak inspection records to owner/operator |
300,000 |
0.55 |
0.02 |
0.0 |
$0.51 |
2,770 |
$152,906 |
166,175 |
3 |
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| Maintain disposal records for appliances with charge sizes of 5 - 50 lbs. |
300,000 |
12 |
0.02 |
0.2 |
$11.04 |
60,000 |
$3,312,540 |
3,600,000 |
2 |
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| Owners/Operators |
Prepare and submit requests for extensions to 30-day repair timeline |
Golla, Emily:
Updated based on input from EPA on the number received annually
25 |
1 |
0.50 |
0.5 |
$50.33 |
13 |
$1,258 |
25 |
1 |
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| Prepare & submit requests for extensions to 1 yr retrofit/retire timeline |
Golla, Emily:
Updated based on input from EPA on the number received annually
5 |
1 |
0.50 |
0.5 |
$50.33 |
3 |
$252 |
5 |
1 |
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| Prepare and submit request to cease a retrofit/retirement if all leaks are repaired |
Golla, Emily:
Updated based on input from EPA on the number received annually
5 |
1 |
0.50 |
0.5 |
$50.33 |
3 |
$252 |
5 |
1 |
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| Prepare and submit report on efforts to repair chronically leaking appliances |
Golla, Emily:
based on 2019 and 2020 reports
125 |
1 |
1.00 |
1.0 |
$100.65 |
125 |
$12,582 |
125 |
1 |
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| Maintain records of the full charge of an appliance |
255,083 |
1 |
0.05 |
0.1 |
$5.03 |
12,754 |
$1,283,743 |
255,083 |
2 |
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| Maintain records of the leak rate calculation |
255,083 |
6.25 |
0.02 |
0.1 |
$10.49 |
26,588 |
$2,676,154 |
1,595,275 |
2 |
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| Maintain purchase and service records |
255,083 |
6.25 |
0.03 |
0.2 |
$15.74 |
39,882 |
$5,236,883 |
1,595,275 |
2 |
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| Maintain leak inspection records |
166,175 |
2.73 |
0.02 |
0.05 |
$4.59 |
7,574 |
$762,319 |
166,175 |
2 |
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| Maintain reports on the results of verification tests |
166,175 |
1 |
0.03 |
0.03 |
$2.52 |
4,154 |
$418,150 |
166,175 |
2 |
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| Develop/maintain plan to retire/replace or retrofit equipment, as applicable |
2,745 |
1 |
8.00 |
8.0 |
$805.22 |
21,960.0 |
$2,210,340 |
2,745 |
2 |
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| Maintain records on mothballed equipment |
137 |
1 |
0.03 |
0.03 |
$2.52 |
3 |
$345 |
137 |
2 |
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| Maintain information on purged/destroyed refrigerant |
4 |
1 |
0.03 |
0.03 |
$2.52 |
0.1 |
$9 |
4 |
2 |
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| Small Can Manufacturers |
Maintain records of self-sealing valve test data and log forms for 3 years |
Golla, Emily:
This number is assumed to include: IDQ, FLC, Inc., A-Gas Americas, National Refrigerants Inc., Car Quest (Advance Auto Parts Inc.), DuPont, Johnsen’s, USA Refrigerants, TSI Supercool, Honeywell, Chemours, and Icool USA.
This assumption is based on the following source: ReferenceUSA. ReferenceUSA Online Database. Retrieved May 27, 2015 from
http://www.referenceusa.com.
Updated in 2022 to include Chemours, and Icool USA based on additional research online.
12 |
12 |
0.03 |
0.3 |
$11.98 |
4 |
$144 |
144 |
2 |
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| SUBTOTAL |
|
572,727 |
varies |
varies |
varies |
varies |
425,514 |
$31,432,946 |
13,698,513 |
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Total Number of Respondents |
Total Number of Annual Responses |
Total Annual Hour Burden |
Total Annual Labor Costs |
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572,727 |
13,698,513 |
425,514 |
$31,432,946 |
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0 |
1 |
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9.4 |
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