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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*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** |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 (new in 2026, 2017-2025 existing systems in 2027) (50/50 direct and indirect ALD) |
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Assumptions |
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Median Wage (2023) |
Total (+ Overhead) |
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Overhead |
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110% |
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Assumed Entities (if needed) |
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NAICS Code |
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Ref/AC Technicians |
$27.55 |
$57.86 |
Median hourly earnings for heating, air-conditioning, and refrigeration mechanics and installers (49-9021) from the Bureau of Labor Statistics (https://www.bls.gov/oes/current/oes499021.htm). |
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65 |
Refrigerant reclaimers |
Materials Recovery Facilities |
562920 |
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Owners/Operators |
$49.85 |
$104.69 |
Median hourly earnings for health and safety engineers (17-2111) from the Bureau of Labor Statistics (https://www.bls.gov/oes/current/oes172111.htm). |
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484 |
Refrigerant wholesalers and distributors |
Refrigeration Equipment and Supplies Merchant Wholesalers |
423740 |
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Manager |
$56.19 |
$118.00 |
Median hourly earnings for management occupations (11-0000) from the Bureau of Labor Statistics (https://www.bls.gov/oes/current/oes110000.htm). |
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1,059 |
Refrigerant wholesalers and distributors |
Warm Air Heating and Air-Conditioning Equipment and Supplies Merchant Wholesalers |
423730 |
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Technician (Reclaimer) |
$38.48 |
$80.81 |
Median hourly earnings for chemical plant and system operators (51-8091) from the Bureau of Labor Statistics (https://www.bls.gov/oes/current/oes518091.htm) |
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2,905 |
Refrigerant wholesalers and distributors |
Other Chemical and Allied Products Merchant Wholesalers |
424690 |
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Refrigerant Wholesalers |
$31.56 |
$66.28 |
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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942 |
Disposal establishments |
Materials Recovery Facilities (Recyclers) |
562920 |
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Disposal Establishment |
$51.19 |
$107.50 |
Median hourly earnings for Administrative Services Managers (11-3012) from the Bureau of Labor Statistics (https://www.bls.gov/oes/current/oes113012.htm) |
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641 |
Disposal establishments |
Soldi Waste Landfill |
562212 |
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Lawyer |
$70.08 |
$147.17 |
Median hourly earnings for lawyers (23-1011) from the Bureau of Labor Statistics (https://www.bls.gov/oes/current/oes231011.htm). |
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Office Clerk, General Administration |
$19.46 |
$40.87 |
Median hourly earnings for office clerks, general (43-9061) from the Bureau of Labor Statistics (https://www.bls.gov/oes/current/oes439061.htm). |
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Marketing Manager |
$75.78 |
Garfinkel, Johanna:
Includes fringe rate of 31.1% - https://www.bls.gov/news.release/pdf/ecec.pdf (December 2023)
$208.63 |
Median hourly earnings for marketing managers (11-2021) from the Bureau of Labor Statistics (https://www.bls.gov/oes/current/oes112021.htm). |
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Graphic Designer |
$28.32 |
Garfinkel, Johanna:
Includes fringe rate of 31.1% - https://www.bls.gov/news.release/pdf/ecec.pdf (December 2023)
$77.97 |
Median hourly earnings for graphic designers (27-1024) from the Bureau of Labor Statistics (https://www.bls.gov/oes/current/oes271024.htm). |
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2026 |
2027 |
2028 |
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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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151,805 |
Total ODS equipment, VM, 2026 |
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Year 1 |
4,460,726 |
110,024 |
$10,023,511.19 |
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15-50 pounds (including school buses above 15 pounds) |
200,251 |
199,257 |
197,056 |
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1,307,585 |
Total HFC equipment, VM, 2026 |
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Year 2 |
4,825,378 |
191,681 |
$15,448,586.30 |
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50+ pounds |
154,496 |
155,492 |
156,203 |
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10% |
Proportion of ODS equipment, VM, 2026 |
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Year 3 |
5,130,565 |
365,099 |
$25,737,580.19 |
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50+ pound appliances with quarterly reporting |
19,234 |
19,078 |
18,384 |
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90% |
Proportion of HFC equipment, VM, 2026 |
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Annual Average |
4,805,557 |
222,268 |
$17,069,892.56 |
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CR and IPR Appliances above LR with charge size > 1500 pounds (direct ALD) |
5,392 |
14,483 |
14,124 |
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15% |
15-50 (plus school buses above 15 pounds) Affected Equipment relative to total HFC equipment, VM, 2026 |
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CR and IPR Appliances above LR with charge size > 1500 pounds (indirect ALD) |
5,392 |
14,483 |
14,124 |
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12% |
50+ Affected Equipment relative to total HFC equipment, VM, 2026 |
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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) |
24,850 |
25,240 |
25,600 |
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50+ pounds |
13,735 |
13,614 |
13,632 |
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CR and IPR Appliances with charge size > 1500 pounds (direct ALD) |
147 |
11,049 |
67 |
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CR and IPR Appliances with charge size > 1500 pounds (indirect ALD) |
147 |
11,049 |
67 |
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Existing Equipment Installations |
Year 1 |
Year 2 |
Year 3 |
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15-50 pounds (including school buses above 15 pounds) |
757,062 |
749,300 |
735,387 |
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50+ pounds |
587,210 |
592,867 |
597,781 |
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Estimated HFC and HFC Cylinders sold per year |
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4,455,000 |
Assumed cylinders sold per year |
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Year 1 |
Year 2 |
Year 3 |
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% Cylinders with HFCs or HFC/HFO blends |
78% |
77% |
76% |
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Leak Repair Total |
$12,009,042 |
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$12,031,407 |
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$11,966,249 |
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HFC Cylinders sold per year |
3,463,870 |
3,418,197 |
3,370,585 |
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Fire Suppression |
$103,429 |
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$103,429 |
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$103,429 |
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Cylinder Cert. |
$0 |
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$0 |
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$10,354,152 |
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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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Reclaim Use |
$42,884 |
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$5,445,595 |
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$5,445,595 |
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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 |
Labor Cost per Resp. per Year |
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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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Leak Repair/Inspection |
Fire Suppression |
Reclamation |
Cylinder Heels |
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| 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.
215 |
214 |
212 |
1.0 |
0.50 |
$52.34 |
107.7 |
$11,271 |
215 |
107.1 |
$11,216 |
214 |
106.0 |
$11,092 |
212 |
$52.34 |
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Total/Yr All Respondents |
Responses |
Costs |
Hours |
Responses |
Costs |
Hours |
Responses |
Costs |
Hours |
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Average Hours per Year |
83,395 |
988 |
54,628 |
58,049 |
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| 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.
215 |
217 |
218 |
1.0 |
0.50 |
$52.34 |
107.7 |
$11,271 |
215 |
108.4 |
$11,344 |
217 |
108.9 |
$11,396 |
218 |
$52.34 |
Reporting |
Leak Repair/Inspection Reporting |
1,090 |
$76,968.62 |
735 |
1,090 |
$76,989.06 |
735 |
1,086 |
$76,692.89 |
733 |
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Average Cost per Year |
$8,730,206.04 |
$103,428.78 |
$3,644,691.35 |
$3,451,383.95 |
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| 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 |
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Comment:
Proportionally increased current ICR assumption by ratio of ODS to HFC equipment assumed subject to leak repair requirements.
43 |
43 |
42 |
1.0 |
0.50 |
$52.34 |
21.53 |
$2,254 |
43 |
21.43 |
$2,243 |
43 |
21.19 |
$2,218 |
42 |
$52.34 |
Recordkeeping |
Leak Repair/Inspection Recordkeeping |
2,390,449 |
$8,655,516.90 |
82,682 |
2,403,210 |
$8,677,799.31 |
82,894 |
2,384,705 |
$8,626,651.33 |
82,406 |
|
Reporting Average Cost |
$76,883.52 |
$19,680.78 |
$3,550,666.11 |
$0.00 |
$3,647,230.42 |
|
|
|
|
| Leak |
Reporting |
Owners/operators |
IPR, CC, and CR >50 pounds |
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Comment:
Proportionally increased current ICR assumption by ratio of ODS to HFC equipment assumed subject to leak repair requirements.
43 |
43 |
44 |
1.0 |
0.50 |
$52.34 |
21.5 |
$2,254 |
43 |
21.7 |
$2,269 |
43 |
21.8 |
$2,279 |
44 |
$52.34 |
Third-party Reporting |
Leak Repair/Inspection Third-party Reporting |
2,053,765 |
$3,276,556.96 |
56,634 |
2,053,799 |
$3,276,618.23 |
56,635 |
2,045,198 |
$3,262,904.42 |
56,398 |
|
Recordkeeping Average Cost |
$8,653,322.51 |
$83,748.00 |
$79,730.56 |
$201,296.98 |
$9,018,098.05 |
|
|
|
|
| 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 |
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Comment:
Assumes 5% of planned requests are able to repair leaks
100 |
100 |
99 |
1.0 |
0.5 |
$52.34 |
50.1 |
$5,241 |
100 |
49.8 |
$5,215 |
100 |
49.3 |
$5,157 |
99 |
$52.34 |
Reporting |
Fire Suppression Reporting |
20 |
$19,680.78 |
188 |
20 |
$19,680.78 |
188 |
20 |
$19,680.78 |
188 |
|
|
|
|
|
|
Total Hours |
Reclaimer Reporting Average Hours (RCRA) |
Reclaimer Recordkeeping Average Hours (RCRA) |
Reclaimer Third party reporting hours (RCRA) |
Total hours with avoided reclaimer removed |
| Leak |
Reporting |
Owners/operators |
IPR, CC, and CR >50 pounds |
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Comment:
Assumes 5% of planned requests are able to repair leaks
77 |
78 |
78 |
1.0 |
0.5 |
$52.34 |
38.6 |
$4,043 |
77 |
38.9 |
$4,069 |
78 |
39.1 |
$4,088 |
78 |
$52.34 |
Recordkeeping |
Fire Suppression Recordkeeping |
20 |
$83,748.00 |
800 |
20 |
$83,748.00 |
800 |
20 |
$83,748.00 |
800 |
|
Reporting Average Hours |
734 |
188 |
53,531 |
0 |
54,453 |
0 |
|
|
54,453 |
| 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 |
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Comment:
Estimated number of "worst leakers" of affected HFC equipment
219 |
218 |
216 |
1.0 |
1.00 |
$104.69 |
219 |
$22,926 |
219 |
218 |
$22,812 |
218 |
216 |
$22,560 |
216 |
$104.69 |
Third-party Reporting |
Cylinder Heel Recovery Certifications |
- |
$0.00 |
- |
341,820 |
$0.00 |
- |
337,059 |
$9,750,260.92 |
168,529 |
|
Recordkeeping Average Hours |
82,661 |
800 |
987 |
1,873 |
86,320 |
|
(31275.00) |
|
55,045 |
| Leak |
Reporting |
Owners/operators |
IPR, CC, and CR >50 pounds |
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Comment:
Estimated number of "worst leakers" of affected HFC equipment
169 |
170 |
171 |
1.0 |
1.00 |
$104.69 |
169 |
$17,688 |
169 |
170 |
$17,802 |
170 |
171 |
$17,883 |
171 |
$104.69 |
Recordkeeping |
Cylinder Heel Recovery Certifications |
- |
$0.00 |
- |
- |
$0.00 |
- |
337,059 |
$603,890.93 |
5,618 |
|
Third party reporting hours |
56,556 |
0 |
111 |
56,176 |
112,843 |
|
|
(73.00) |
112,770 |
| 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 |
$2.62 |
0.094 |
$10 |
4 |
0.093 |
$10 |
4 |
0.092 |
$10 |
4 |
$2.62 |
Reporting |
Reclamation |
- |
$0.00 |
- |
10,037 |
$5,325,999.17 |
80,296 |
10,037 |
$5,325,999.17 |
80,296 |
|
|
|
|
|
|
|
|
|
TOTAL |
222,268 |
| Leak |
Reporting |
Owners/operators |
IPR, CC, and CR >50 pounds |
4 |
4 |
4 |
1.0 |
0.03 |
$2.62 |
0.094 |
$10 |
4 |
0.094 |
$10 |
4 |
0.095 |
$10 |
4 |
$2.62 |
Third-party Reporting |
Reclamation |
37 |
$42,884.02 |
333 |
- |
$0.00 |
- |
- |
$0.00 |
- |
|
|
|
|
|
|
|
|
|
|
|
| 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 |
266,374 |
265,052 |
262,124 |
2.8 |
0.025 |
$2.62 |
18,927 |
$1,981,325 |
757,062 |
18,833 |
$1,971,496 |
753,306 |
18,625 |
$1,949,714 |
744,983 |
$7.44 |
Recordkeeping |
Reclamation |
- |
$0.00 |
- |
37 |
$119,595.84 |
1,480 |
37 |
$119,595.84 |
1,480 |
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
206,611 |
207,943 |
208,893 |
2.8 |
0.025 |
$2.62 |
14,680 |
$1,536,802 |
587,210 |
14,775 |
$1,546,708 |
590,995 |
14,842 |
$1,553,779 |
593,697 |
$7.44 |
|
Total Reporting and Recordkeeping Recordkeeping |
4,445,381 |
$12,155,355 |
141,372 |
4,810,033 |
$17,580,430 |
223,029 |
5,115,220 |
$27,869,424 |
396,447 |
|
|
|
|
|
|
|
|
|
|
|
| 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 |
24,850 |
24,727 |
24,454 |
1.0 |
0.025 |
$2.62 |
621 |
$65,036 |
24,850 |
618 |
$64,713 |
24,727 |
611 |
$63,998 |
24,454 |
$2.62 |
|
Reclaimer Reporting and Recordkeeping |
15,345 |
$(2,131,844.09) |
(31,348) |
15,345 |
$(2,131,844.09) |
(31,348) |
15,345 |
$(2,131,844.09) |
(31,348) |
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
13,735 |
13,823 |
13,886 |
1.0 |
0.025 |
$2.62 |
343 |
$35,945 |
13,735 |
346 |
$36,177 |
13,823 |
347 |
$36,342 |
13,886 |
$2.62 |
|
Total with Avoided Costs |
4,460,726 |
$10,023,511.19 |
110,024 |
4,825,378 |
$15,448,586.30 |
191,681 |
5,130,565 |
$25,737,580.19 |
365,099 |
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
Owners or operators must maintain records of changes to the leak rate calculation method after a change in ownership. Records must include:
(i) Basic identification information (i.e., owner name or operator, facility name, facility address where appliance is located, and appliance ID or description);
(ii) The date an operating facility was purchased;
(iii)The leak rates for all refrigerant-containing appliances at the operating facility when both leak rate calculation methods are applied;
(iv) The date a new leak rate calculation method is adopted; and
(v) The leak rate calculation method the owner or operator is using after the change. |
|
IPR, CC, and CR 15-50 pounds |
2,664 |
2,651 |
2,621 |
1.0 |
0.025 |
$2.62 |
67 |
$6,971 |
2,664 |
66 |
$6,937 |
2,651 |
66 |
$6,860 |
2,621 |
$2.62 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
|
IPR, CC, and CR >50 pounds |
2,066 |
2,079 |
2,089 |
1.0 |
0.025 |
$2.62 |
52 |
$5,407 |
2,066 |
52 |
$5,442 |
2,079 |
52 |
$5,467 |
2,089 |
$2.62 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 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
2,003 |
1,993 |
1,971 |
1.0 |
8.00 |
$837.48 |
16,020 |
$1,677,059 |
2,003 |
15,941 |
$1,668,739 |
1,993 |
15,764 |
$1,650,302 |
1,971 |
$837.48 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
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Comment:
Analysis assumes 1% of equipment experiences retrofit outcome
1,545 |
1,555 |
1,562 |
1.0 |
8.00 |
$837.48 |
12,360 |
$1,293,875 |
1,545 |
12,439 |
$1,302,215 |
1,555 |
12,496 |
$1,308,169 |
1,562 |
$837.48 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 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 |
40 |
39 |
1.0 |
0.025 |
$2.62 |
1.00 |
$105 |
40 |
1.00 |
$104 |
40 |
0.99 |
$103 |
39 |
$2.62 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 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
31 |
31 |
31 |
1.0 |
0.025 |
$2.62 |
0.77 |
$81 |
31 |
0.78 |
$81 |
31 |
0.78 |
$82 |
31 |
$2.62 |
|
Total Annual Responses: |
Year 1 |
Year 1 |
Year 2 |
Year 2 |
Year 3 |
Year 3 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 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 |
$2.62 |
0.09 |
$10 |
4 |
0.09 |
$10 |
4 |
0.09 |
$10 |
4 |
$2.62 |
|
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 |
4 |
4 |
4 |
1.0 |
0.025 |
$2.62 |
0.09 |
$10 |
4 |
0.09 |
$10 |
4 |
0.09 |
$10 |
4 |
$2.62 |
Reporting |
Leak Repair/Inspection Reporting |
0.67 |
$70.64 |
0.67 |
$70.63 |
0.67 |
$70.62 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 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 |
200,251 |
199,257 |
197,056 |
1.0 |
0.025 |
$2.62 |
5,006 |
$524,081 |
200,251 |
4,981 |
$521,481 |
199,257 |
4,926 |
$515,720 |
197,056 |
$2.62 |
Recordkeeping |
Leak Repair/Inspection Recordkeeping |
0.03 |
$3.62 |
0.03 |
$3.61 |
0.03 |
$3.62 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
154,496 |
155,492 |
156,203 |
1.0 |
0.025 |
$2.62 |
3,862 |
$404,336 |
154,496 |
3,887 |
$406,942 |
155,492 |
3,905 |
$408,803 |
156,203 |
$2.62 |
Third-party Reporting |
Leak Repair/Inspection Third-party Reporting |
0.03 |
$1.60 |
0.03 |
$1.60 |
0.03 |
$1.60 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
Maintain quarterly leak inspection records |
84.106(l)(4) |
IPR and CR >500 pounds |
76,935 |
77,431 |
77,785 |
4.0 |
0.017 |
$1.74 |
5,129 |
$536,930 |
307,741 |
5,162 |
$540,391 |
309,724 |
5,186 |
$542,862 |
311,140 |
$6.98 |
Reporting |
Fire Suppression Reporting |
9.40 |
$984.04 |
9.40 |
$984.04 |
9.40 |
$984.04 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
Maintain annual leak inspection records |
84.106(l)(4) |
IPR, CC, and CR 15-50 pounds |
200,251 |
199,257 |
197,056 |
1.0 |
0.017 |
$1.74 |
3,338 |
$349,387 |
200,251 |
3,321 |
$347,654 |
199,257 |
3,284 |
$343,813 |
197,056 |
$1.74 |
Recordkeeping |
Fire Suppression Recordkeeping |
40.00 |
$4,187.40 |
40.00 |
$4,187.40 |
40.00 |
$4,187.40 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
135,262 |
136,134 |
136,757 |
1.0 |
0.017 |
$1.74 |
2,254 |
$235,999 |
135,262 |
2,269 |
$237,520 |
136,134 |
2,279 |
$238,606 |
136,757 |
$1.74 |
Third-party Reporting |
Reclamation |
9.00 |
$1,159.03 |
0.00 |
$0.00 |
0.00 |
$0.00 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 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 |
581 |
578 |
572 |
1.0 |
0.017 |
$1.74 |
10 |
$1,014 |
581 |
10 |
$1,009 |
578 |
10 |
$998 |
572 |
$1.74 |
Recordkeeping |
Reclamation |
0.00 |
$0.00 |
40.00 |
$3,232.32 |
40.00 |
$3,232.32 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leak |
Recordkeeping |
Owners/operators |
IPR, CC, and CR >50 pounds |
508 |
512 |
514 |
1.0 |
0.017 |
$1.74 |
8 |
$887 |
508 |
9 |
$893 |
512 |
9 |
$897 |
514 |
$1.74 |
|
Average for Reporting and Recordkeeping |
0.03 |
2.73 |
0.05 |
3.65 |
0.08 |
5.45 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 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 |
147 |
11,049 |
67 |
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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.
0.017 |
$1.74 |
2 |
$257 |
147 |
184 |
$19,277 |
11,049 |
1 |
$116 |
67 |
$1.74 |
|
Reclaimer Reporting and Recordkeeping |
-2.04 |
-$138.93 |
-2.04 |
-$138.93 |
-2.04 |
-$138.93 |
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| 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 |
298,512 |
295,214 |
0.67 |
0.017 |
$0.96 |
3,338 |
$193,092 |
200,251 |
3,321 |
$192,134 |
199,257 |
3,284 |
$190,011 |
197,056 |
$0.64 |
|
Overall Average (including avoided Reclaimer) |
0.02 |
$2.25 |
0.04 |
$3.20 |
0.07 |
$5.02 |
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| Leak |
Third-party Reporting |
Tehnicians |
IPR, CC, and CR >50 pounds |
300,000 |
301,934 |
303,314 |
0.51 |
0.017 |
$0.96 |
2,575 |
$148,973 |
154,496 |
2,592 |
$149,933 |
155,492 |
2,603 |
$150,619 |
156,203 |
$0.50 |
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| 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 |
298,512 |
295,214 |
0.67 |
0.017 |
$0.96 |
3,338 |
$193,092 |
200,251 |
3,321 |
$192,134 |
199,257 |
3,284 |
$190,011 |
197,056 |
$0.64 |
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| Leak |
Third-party Reporting |
Tehnicians |
IPR, CC, and CR >50 pounds |
300,000 |
301,934 |
303,314 |
0.51 |
0.017 |
$0.96 |
2,575 |
$148,973 |
154,496 |
2,592 |
$149,933 |
155,492 |
2,603 |
$150,619 |
156,203 |
$0.50 |
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| 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 |
298,512 |
295,214 |
2.52 |
0.033 |
$1.93 |
25,235 |
$1,459,993 |
757,062 |
25,110 |
$1,452,751 |
753,306 |
24,833 |
$1,436,700 |
744,983 |
$4.87 |
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| Leak |
Third-party Reporting |
Technicians |
IPR, CC, and CR >50 pounds |
300,000 |
301,934 |
303,314 |
1.96 |
0.033 |
$1.93 |
19,574 |
$1,132,434 |
587,210 |
19,700 |
$1,139,734 |
590,995 |
19,790 |
$1,144,945 |
593,697 |
$3.77 |
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| 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 |
$984.04 |
188 |
$19,681 |
20 |
188 |
$19,681 |
20 |
188 |
$19,681 |
20 |
$984.04 |
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| 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 |
$4,187.40 |
800 |
$83,748 |
20 |
800 |
$83,748 |
20 |
800 |
$83,748 |
20 |
$4,187.40 |
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| Reclamation |
Third-party Reporting |
HFC Reclaimers |
One-time label redesign |
84.112(c) |
Cylinders |
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Comment:
Assumptions based on number of HFC reclamation facilities, including those that have not reported to HAWK
37 |
0 |
0 |
1 |
9.00 |
Garfinkel, Johanna:
Assumed 3.5 hours for administrative activities (marketing managers) and 5.5 hours for graphic design
$1,159.03 |
333 |
$42,884 |
37 |
- |
$0 |
- |
- |
$0 |
- |
$1,159.03 |
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| 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 |
37 |
37 |
1 |
40.00 |
$1,634.64 |
- |
$0 |
- |
1,480 |
$119,596 |
37 |
1,480 |
$119,596 |
37 |
$1,634.64 |
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| Reclamation |
Reporting |
Refrigerant Reclaimers |
Two-time reporting from reclaimers/distributors/wholesalers who sell reclaimed HFCs to report on the data types and volumes of reclaimed HFC refrigerants sold for use in servicing/repair of equipment in the covered subsector |
|
NA |
- |
37 |
37 |
1 |
8 |
$646.46 |
- |
$0 |
- |
296 |
$23,919 |
37 |
296 |
$23,919 |
37 |
$646.46 |
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| Reclamation |
Reporting |
Refrigerant Wholesalers and Distributors |
|
NA |
- |
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Comment:
Same assumption from 608 ICR; 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 |
10,000 |
1 |
8 |
$530.21 |
- |
$0 |
- |
80,000 |
$5,302,080 |
10,000 |
80,000 |
$5,302,080 |
10,000 |
$530.21 |
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| Heel |
Third-party Reporting |
Refrigerant Technician |
Certification statement accompanying those who choose the alternate method to get a disposable cylinder evacuated to a specified level of vacuum (15 in-Hg) so that the cylinder can be discarded and then no longer need additional processing for heel removal |
84.112(). |
Cylinders undergoing heel recovery |
0 |
0 |
300,000 |
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Comment:
Assumed applicable to 10% of cylinders (1/3 of cylinders are assumed to go from the end-user to a disposal facility, it's assumed that the end-user (i.e., technician) would fully recover the refrigerant from a portion of those - 10% - and would just send the evacuated cylinder for disposal)
1.12 |
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Comment:
Third-party conferral statements estimated in 2024 Allocation Rule burden is 2 hours - burden for preparing this certification statement assumed to be lower.
0.5 |
$28.93 |
- |
$0 |
- |
- |
$0 |
341,820 |
168,529 |
$9,750,261 |
337,059 |
$32.50 |
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| Heel |
Recordkeeping |
Final processor |
Maintain records on:
- Signed cylinder evacuation certification statement from technician |
84.112(). |
Cylinders undergoing heel recovery |
0 |
0 |
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Comment:
Based on the number of Materials Recovery Facilities (Recyclers) [NAICS Code 562920] and Solid Waste Landfills [NAICS Code 562212] used in the cylinder heel recovery cost analysis
1611.00 |
209.22 |
0.017 |
$1.79 |
- |
$0 |
- |
- |
$0 |
- |
5,618 |
$603,891 |
337,059 |
$374.85 |
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ANNUAL TOTAL |
|
|
3,089,523 |
3,112,151 |
3,392,081 |
260 |
137 |
|
141,372 |
$12,155,355 |
4,445,381 |
223,029 |
$17,580,430 |
4,810,033 |
396,447 |
$27,869,424 |
5,115,220 |
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3 YEAR TOTAL |
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|
9,593,756 |
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ANNUAL AVERAGE |
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3,197,919 |
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Unique Respondents |
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773,004 |
781,563 |
777,899 |
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$19,201,737 |
4,790,212 |
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- |
- |
- |
- |
- |
- |
- |
- |
- |
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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 |
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Legal |
Manager |
Technical |
Clerical |
Number of Respondents/Activity |
Annual Burden Hours |
Total Cost/Year |
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$147.17 |
$118.00 |
$80.81 |
$40.87 |
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Contingency Planning |
Reclaimer |
Collect data required in contingency plan |
0.00 |
0.00 |
(3.35) |
(1.65) |
(5.00) |
$(338.14) |
$- |
$- |
37.00 |
(185.00) |
$(12,511) |
Recordkeeping |
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Reclaimer |
Document whether authorities decline arrangement |
0.00 |
0.00 |
0.00 |
(0.50) |
(0.50) |
$(20.43) |
$- |
$- |
37.00 |
(18.50) |
$(756) |
Recordkeeping |
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Reclaimer |
Write contingency plan |
0.00 |
0.00 |
(7.50) |
(2.50) |
(10.00) |
$(708.23) |
$- |
$- |
37.00 |
(370.00) |
$(26,204) |
Recordkeeping |
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Reclaimer |
Maintain contingency plan |
0.00 |
0.00 |
0.00 |
(1.00) |
(1.00) |
$(40.87) |
$- |
$- |
37.00 |
(37.00) |
$(1,512) |
Recordkeeping |
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Reclaimer |
Submit contingency plan to relevant emergency centers |
0.00 |
0.00 |
0.00 |
(0.50) |
(0.50) |
$(20.43) |
$- |
$(4.87) |
37.00 |
(18.50) |
$(936) |
Recordkeeping |
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Reclaimer |
Amend contingency plan when appropriate |
0.00 |
0.00 |
(5.00) |
0.00 |
(5.00) |
$(404.04) |
$- |
$(0.10) |
6.00 |
(30.00) |
$(2,425) |
Recordkeeping |
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Final processor |
Collect data required in contingency plan |
0.00 |
0.00 |
(3.35) |
(1.65) |
(5.00) |
$(338.14) |
$- |
$- |
1611.00 |
(8055.00) |
$(544,737) |
Recordkeeping |
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Final processor |
Document whether authorities decline arrangement |
0.00 |
0.00 |
0.00 |
(0.50) |
(0.50) |
$(20.43) |
$- |
$- |
1611.00 |
(805.50) |
$(32,918) |
Recordkeeping |
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Final processor |
Write contingency plan |
0.00 |
0.00 |
(7.50) |
(2.50) |
(10.00) |
$(708.23) |
$- |
$- |
1611.00 |
(16110.00) |
$(1,140,950) |
Recordkeeping |
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Final processor |
Maintain contingency plan |
0.00 |
0.00 |
0.00 |
(1.00) |
(1.00) |
$(40.87) |
$- |
$- |
1611.00 |
(1611.00) |
$(65,835) |
Recordkeeping |
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Final processor |
Submit contingency plan to relevant emergency centers |
0.00 |
0.00 |
0.00 |
(0.50) |
(0.50) |
$(20.43) |
$- |
$(4.87) |
1611.00 |
(805.50) |
$(40,763) |
Recordkeeping |
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Final processor |
Amend contingency plan when appropriate |
0.00 |
0.00 |
(5.00) |
0.00 |
(5.00) |
$(404.04) |
$- |
$(0.10) |
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Comment:
15% of final processors (per RCRA team guidance)
242.00 |
(1210.00) |
$(97,802) |
Recordkeeping |
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Emergency Procedures |
Reclaimer |
Collect information |
0.00 |
0.00 |
(0.22) |
(1.50) |
(1.72) |
$(79.08) |
$- |
$- |
1.00 |
(1.72) |
$(79) |
Recordkeeping |
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Reclaimer |
Emergency reporting |
(1.28) |
0.00 |
(0.90) |
0.00 |
(2.18) |
$(261.10) |
$- |
$- |
1.00 |
(2.18) |
$(261) |
Recordkeeping |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Notifying/coordination with authorities |
0.00 |
(0.10) |
(0.90) |
0.00 |
(1.00) |
$(84.53) |
$- |
$(11.35) |
1.00 |
(1.00) |
$(96) |
Third party reporting |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Observe scene of hazardous waste discharge |
0.00 |
0.00 |
(0.50) |
0.00 |
(0.50) |
$(40.40) |
$- |
$- |
0.00 |
0.00 |
$- |
Recordkeeping |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Report by phone requested data items to NRC |
0.00 |
0.00 |
(0.50) |
0.00 |
(0.50) |
$(40.40) |
$- |
$(5.29) |
0.00 |
0.00 |
$- |
Third party reporting |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Document that local officials decline to enter into arrangements for coordinating response |
0.00 |
0.00 |
(0.10) |
0.00 |
(0.10) |
$(8.08) |
$- |
$- |
0.00 |
0.00 |
$- |
Recordkeeping |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Reclaimer |
Post emergency information by phone |
0.00 |
0.00 |
0.00 |
(0.10) |
(0.10) |
$(4.09) |
$- |
$- |
0.00 |
0.00 |
$- |
Recordkeeping |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Final processor |
Collect information |
0.00 |
0.00 |
(0.22) |
(1.50) |
(1.72) |
$(79.08) |
$- |
$- |
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Comment:
Based on 3% of Materials Recovery Facilities (Recyclers) [NAICS Code 562920] and Solid Waste Landfills [NAICS Code 562212] used in the cylinder heel recovery cost analysis (per guidance from RCRA team)
48.00 |
(82.56) |
$(3,796) |
Recordkeeping |
|
|
|
|
|
|
|
|
|
|
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|
|
|
|
|
|
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|
|
Final processor |
Emergency reporting |
(1.28) |
0.00 |
(0.90) |
0.00 |
(2.18) |
$(261.10) |
$- |
$- |
48.00 |
(104.64) |
$(12,533) |
Recordkeeping |
|
|
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|
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|
|
|
|
|
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|
|
Final processor |
Notifying/coordination with authorities |
0.00 |
(0.10) |
(0.90) |
0.00 |
(1.00) |
$(84.53) |
$- |
$(11.35) |
48.00 |
(48.00) |
$(4,602) |
Third party reporting |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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|
|
|
|
|
|
|
Final processor |
Observe scene of hazardous waste discharge |
0.00 |
0.00 |
(0.50) |
0.00 |
(0.50) |
$(40.40) |
$- |
$- |
48.00 |
(24.00) |
$(1,939) |
Recordkeeping |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Final processor |
Report by phone requested data items to NRC |
0.00 |
0.00 |
(0.50) |
0.00 |
(0.50) |
$(40.40) |
$- |
$(5.29) |
48.00 |
(24.00) |
$(2,193) |
Third party reporting |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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|
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|
|
|
|
|
|
|
|
|
|
Final processor |
Document that local officials decline to enter into arrangements for coordinating response |
0.00 |
0.00 |
(0.10) |
0.00 |
(0.10) |
$(8.08) |
$- |
$- |
48.00 |
(4.80) |
$(388) |
Recordkeeping |
|
|
|
|
|
|
|
|
|
|
|
|
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|
|
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|
|
|
|
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|
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|
|
|
|
Final processor |
Post emergency information by phone |
0.00 |
0.00 |
0.00 |
(0.10) |
(0.10) |
$(4.09) |
$- |
$- |
48.00 |
(4.80) |
$(196) |
Recordkeeping |
|
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|
|
|
Personnel Training |
Reclaimer |
Collect job-related data |
0.00 |
0.00 |
(0.50) |
0.00 |
(0.50) |
$(40.40) |
$- |
$- |
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Comment:
Applies to all reclaimers (per RCRA team guidance)
37.00 |
(18.50) |
$(1,495) |
Recordkeeping |
|
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|
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|
|
|
|
|
Reclaimer |
Maintain information at facility |
0.00 |
0.00 |
0.00 |
(0.10) |
(0.10) |
$(4.09) |
$- |
$- |
37.00 |
(3.70) |
$(151) |
Recordkeeping |
|
|
|
|
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|
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|
|
|
|
|
|
|
|
|
|
|
|
|
|
Final processor |
Collect job-related data |
0.00 |
0.00 |
(0.50) |
0.00 |
(0.50) |
$(40.40) |
$- |
$- |
[Threaded comment]
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Comment:
Applies to all final processors (per RCRA team guidance)
1611.00 |
(805.50) |
$(65,091) |
Recordkeeping |
|
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|
|
|
|
|
|
Final processor |
Maintain information at facility |
0.00 |
0.00 |
0.00 |
(0.10) |
(0.10) |
$(4.09) |
$- |
$- |
1611.00 |
(161.10) |
$(6,584) |
Recordkeeping |
|
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|
|
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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 |
|
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|
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|
|
|
|
Recordkeeping |
This provision doesn't kick in until 2029 |
|
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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. |
|
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|
|
|
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|
|
|
|
Recordkeeping |
This provision doesn't kick in until 2029 |
|
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|
No Speculative Accumulation 40 CFR 266.602(a)(2) and (b)(3) |
Final processor |
Label containers in accumulation area with start date |
0.00 |
0.00 |
(0.25) |
0.00 |
(0.25) |
$(20.20) |
$- |
$- |
1611.00 |
(402.75) |
$(32,545) |
Recordkeeping |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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|
|
|
|
|
|
Final processor |
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) |
$(20.20) |
$- |
$- |
1611.00 |
(402.75) |
$(32,545) |
Recordkeeping |
|
|
|
|
|
|
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|
$(43.22) |
15345 |
-31348 |
$(2,131,844) |
|
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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 ER&R |
|
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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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|
|
|
|
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| Annual Respondent Burden and Cost |
|
|
|
|
|
|
|
|
|
|
|
|
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| Assumptions |
|
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|
Median Wage (2022) |
Total (+ Overhead) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
110% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Refrigerant Recovery/Recycling Equipment Testing Organization |
$27.63 |
$27.63 |
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/2022/may/oes499021.htm). |
|
|
|
|
|
|
|
| Refrigerant Reclaimers |
$49.79 |
$49.79 |
Mean hourly earnings for health and safety engineers (17-2111) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2022/may/oes172111.htm). |
|
|
|
|
|
|
|
| Refrigerant Wholesalers |
$51.62 |
$51.62 |
Median hourly earnings for management occupations (11-0000) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2022/may/oes110000.htm). |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Technician Certification Programs |
$46.41 |
$46.41 |
Median hourly earnings for environmental engineers (17-2081) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2022/may/oes172081.htm). |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Disposal Establishments |
$65.26 |
$65.26 |
Median hourly earnings for lawyers (23-1011) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2022/may/oes231011.htm). |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Technicians |
$18.29 |
$18.29 |
Median hourly earnings for office clerks, general (43-9061) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2022/may/oes439061.htm). |
|
|
|
|
|
|
|
|
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|
|
|
|
| Owners/Operators |
$67.33 |
Garfinkel, Johanna:
Includes fringe rate of 31.2% - https://www.bls.gov/news.release/archives/ecec_06162022.pdf (June 2022)
$88.34 |
Median hourly earnings for marketing managers (11-2021) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2022/may/oes112021.htm). |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Small Can Manufacturers |
$27.88 |
Garfinkel, Johanna:
Includes fringe rate of 31.2% - https://www.bls.gov/news.release/archives/ecec_06162022.pdf (June 2022)
$36.58 |
Median hourly earnings for graphic designers (27-1024) from the Bureau of Labor Statistics (https://www.bls.gov/oes/2022/may/oes271024.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 |
|
|
|
|
|
|
|
| Annual Burden Hours |
Annual Labor Cost |
Annual Burden Hours |
Annual Labor Costs |
Number of Annual Responses |
|
|
|
|
|
|
|
| Refrigerant Recovery/ Recycling Equipment Testing Organization |
Apply for approval |
- |
1 |
8.00 |
8.0 |
$221.04 |
- |
$0 |
- |
1 |
|
|
|
|
|
|
| Provide notice when equipment fails recertification |
2 |
1 |
0.50 |
0.5 |
$13.82 |
1 |
$28 |
2 |
1 |
|
|
Total/Yr All Respondents |
Responses |
Costs |
Hours |
| Publish online list of all certified equipment |
2 |
1 |
0.50 |
0.5 |
$13.82 |
1.00 |
$28 |
2 |
3 |
|
|
Reporting |
372.00 |
$47,173.12 |
849.17 |
| Maintain records of equipment tested and its performance |
2 |
1 |
0.50 |
0.5 |
$13.82 |
1.000 |
$28 |
2 |
2 |
|
|
Recordkeeping |
12,248,596.94 |
$24,836,881.62 |
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 |
$466.49 |
525 |
$26,123 |
56 |
1 |
|
|
Third Party |
1,449,543.99 |
$823,964.38 |
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 |
$248.95 |
10 |
$498 |
2 |
1 |
|
|
Total |
13,698,513 |
25,708,019 |
425,513.83 |
| Maintain records of refrigerant sales transactions |
56 |
50 |
0.23 |
11.7 |
$580.88 |
653 |
$32,529 |
2,800 |
2 |
|
|
|
- |
- |
- |
| Maintain records that analysis conducted to verify that reclaimed refrigerant meets the necessary specifications |
56 |
260 |
0.02 |
4.3 |
$215.76 |
243 |
$12,082 |
14,560 |
2 |
|
|
Total Annual Responses: |
13,698,513 |
|
|
| 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 |
$447.37 |
86,667 |
$4,473,733 |
2,600,000 |
2 |
|
|
Burden Per Response |
Hours Per Response |
Cost Per Response (including non-labor) |
|
| Technician Certification Programs |
Apply for approval |
3 |
1 |
5.00 |
5.0 |
$232.05 |
15 |
$696 |
3 |
1 |
|
|
Reporting |
2.28 |
$126.81 |
|
| Maintain list/database of technicians certified |
Golla, Emily:
Updated to reflect 2021 report submissions
74 |
2 |
0.08 |
0.2 |
$7.74 |
12 |
$572 |
148 |
2 |
|
|
Recordkeeping |
0.03 |
$2.03 |
|
| Submit biannual report |
Golla, Emily:
Updated to reflect 2021 report submissions
74 |
2 |
1.00 |
2.0 |
$92.82 |
148 |
$6,869 |
148 |
1 |
|
|
Third Party |
0.03 |
$0.57 |
|
| Transfer records when no longer operational |
1 |
1 |
8.00 |
8.0 |
$371.28 |
8 |
$371 |
1 |
1 |
|
|
Average |
0.03 |
$1.88 |
|
| Recordkeeping by existing Technician Certification Programs |
74 |
1 |
5.00 |
5.0 |
$232.05 |
370 |
$17,172 |
74 |
2 |
|
|
|
|
|
|
| Disposal Establishments |
Maintain copies of signed statements of previous refrigerant recovery by disposal establishments |
7,500 |
260 |
0.06 |
15.2 |
$989.78 |
113,750 |
$7,423,325 |
1,950,000 |
2 |
|
|
Annual Burden |
Annual Time Burden (Hours) |
Annual non-labor costs |
|
| Technicians |
Acquire certification cards |
30,000 |
1 |
0.02 |
0.02 |
$0.30 |
500 |
$9,145 |
30,000 |
3 |
|
|
Reporting |
849 |
N/A |
|
| Maintain certification cards |
300,000 |
1 |
0.02 |
0.02 |
$0.30 |
5,000 |
$91,450 |
300,000 |
2 |
|
|
Recordkeeping |
379,615 |
N/A |
|
| 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 |
$1.35 |
22,079 |
$403,823 |
662,367 |
3 |
|
|
Third Party |
45,049 |
N/A |
|
| 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 |
$1.20 |
19,700 |
$360,313 |
591,000 |
3 |
|
|
|
|
|
|
| Provide leak inspection records to owner/operator |
300,000 |
0.55 |
0.02 |
0.0 |
$0.17 |
2,770 |
$50,656 |
166,175 |
3 |
|
|
|
|
|
|
| Maintain disposal records for appliances with charge sizes of 5 - 50 lbs. |
300,000 |
12 |
0.02 |
0.2 |
$3.66 |
60,000 |
$1,097,400 |
3,600,000 |
2 |
|
|
|
|
|
|
| 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 |
$44.17 |
13 |
$1,104 |
25 |
1 |
|
|
|
|
|
|
| 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 |
$44.17 |
3 |
$221 |
5 |
1 |
|
|
|
|
|
|
| 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 |
$44.17 |
3 |
$221 |
5 |
1 |
|
|
|
|
|
|
| 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 |
$88.34 |
125 |
$11,042 |
125 |
1 |
|
|
|
|
|
|
| Maintain records of the full charge of an appliance |
255,083 |
1 |
0.05 |
0.1 |
$4.42 |
12,754 |
$1,126,663 |
255,083 |
2 |
|
|
|
|
|
|
| Maintain records of the leak rate calculation |
255,083 |
6.25 |
0.02 |
0.1 |
$9.21 |
26,588 |
$2,348,696 |
1,595,275 |
2 |
|
|
|
|
|
|
| Maintain purchase and service records |
255,083 |
6.25 |
0.03 |
0.2 |
$13.81 |
39,882 |
$5,236,883 |
1,595,275 |
2 |
|
|
|
|
|
|
| Maintain leak inspection records |
166,175 |
2.73 |
0.02 |
0.05 |
$4.03 |
7,574 |
$669,040 |
166,175 |
2 |
|
|
|
|
|
|
| Maintain reports on the results of verification tests |
166,175 |
1 |
0.03 |
0.03 |
$2.21 |
4,154 |
$366,985 |
166,175 |
2 |
|
|
|
|
|
|
| Develop/maintain plan to retire/replace or retrofit equipment, as applicable |
2,745 |
1 |
8.00 |
8.0 |
$706.70 |
21,960.0 |
$1,939,880 |
2,745 |
2 |
|
|
|
|
|
|
| Maintain records on mothballed equipment |
137 |
1 |
0.03 |
0.03 |
$2.21 |
3 |
$303 |
137 |
2 |
|
|
|
|
|
|
| Maintain information on purged/destroyed refrigerant |
4 |
1 |
0.03 |
0.03 |
$2.21 |
0.1 |
$8 |
4 |
2 |
|
|
|
|
|
|
| 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 |
$10.97 |
4 |
$132 |
144 |
2 |
|
|
|
|
|
|
| SUBTOTAL |
|
572,727 |
varies |
varies |
varies |
varies |
425,514 |
$25,708,019 |
13,698,513 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Number of Respondents |
Total Number of Annual Responses |
Total Annual Hour Burden |
Total Annual Labor Costs |
|
|
|
|
|
|
|
|
|
|
|
|
|
572,727 |
13,698,513 |
425,514 |
$25,708,019 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
0 |
1 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
9.4 |
|
|
|
|
|
|
|
|
|
|
|
|