Burden Calculation Tables

2778t01.xlsx

Recordkeeping and Reporting of the Management of Certain Hydrofluorocarbons and Substitutes under Subsection (h) of the American Innovation and Manufacturing Act of 2020 (Proposed Rule)

Burden Calculation Tables

OMB: 2060-0760

Document [xlsx]
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Overview

Respondent Burden
Respondent Burden Summary
Agency Burden
Tables for Supporting Statement
ICR 1626.18 9-6-2022
Labeling Burden Estimates

Sheet 1: Respondent Burden

Subsection H Leak Repair, Inspection, ALD, and Reclamation Requirements




*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***


































Leak repair 15+ pound threshold (plus school bus AC); ALD for 1500+ pound CR and IPR equipment (50/50 direct and indirect ALD)


















































































Assumptions









































Median Wage (2021) Total (+ Overhead)






































Overhead
110%






































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).































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).































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).





































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).





































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).





































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).





































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).





































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).
















































































2025 2026 2027
















Year Total Responses Total Hours Total Costs
















Affected Equipment (above LR threshold) Year 1 Year 2 Year 3
245,340 Total ODS equipment, VM, 2025













Year 1 8,739,279 166,538 $12,896,991.26
















15-50 pounds (including school buses above 15 pounds) 201,123 205,737 210,324
1,348,234 Total HFC equipment, VM, 2025













Year 2 21,214,466 222,260 $15,740,028.39
















50+ pounds 143,263 150,265 157,184
15% Proportion of ODS equipment, VM, 2025













Year 3 21,366,296 223,432 $15,966,834.14
















50+ pound appliances with quarterly reporting 12,343 12,774 13,189
85% Proportion of HFC equipment, VM, 2025













Annual Average 17,106,680 204,077 $14,867,951.26
















CR and IPR Appliances above LR with charge size > 1500 pounds (direct ALD) 6,180 6,225 6,246
15% 15-50 (plus school buses above 15 pounds) Affected Equipment relative to total HFC equipment, VM, 2025


































CR and IPR Appliances above LR with charge size > 1500 pounds (indirect ALD) 6,180 6,225 6,246
11% 50+ Affected Equipment relative to total HFC equipment, VM, 2025


































Assumed equipment per facility (from CARB data/2016 TSD) 2.8

















































































New Equipment Installations Year 1 Year 2 Year 3





































15-50 pounds (including school buses above 15 pounds) 51,283 52,280 53,140





































50+ pounds 112,829 113,536 114,249





































CR and IPR Appliances with charge size > 1500 pounds (direct ALD) 24,658 24,830 24,904





































CR and IPR Appliances with charge size > 1500 pounds (indirect ALD) 24,658 24,830 24,904












































































20.095209760689

Existing Equipment Installations Year 1 Year 2 Year 3


































20.0952097606889

15-50 pounds (including school buses above 15 pounds) 764,439 784,495 804,633





































50+ pounds 637,555 668,194 698,323


















RR TSD 11,787,755

12,199,756

12,607,713

































Leak Repair Total 11,787,755

12,199,756

12,607,713










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





















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


Year 1 Year 1 Year 1 Year 2 Year 2 Year 2 Year 3 Year 3 Year 3
Average Annual
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

Total/Yr All Respondents Responses Costs Hours Responses Costs Hours Responses Costs Hours
Total/Yr All Respondents Responses Costs Hours
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
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] 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. 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
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] 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. 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
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] 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: 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
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
17,107,132 14,779,827 202,939
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: 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
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



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] 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: 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
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 [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: 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 [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: 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 [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: 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 [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: 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 [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: 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 [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: 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 [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: 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 [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: 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 [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: 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 [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: Assumed that 25% of respondents start registering and reporting before the required start date 1 [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: Assumptions based on 2024 HFC Allocation Rule 3 [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: 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 [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: Assumed that 25% of respondents start registering and reporting before the required start date 1 4 4 [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: 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




















QR Reporting HFC Producers Register with tracking ID system 84.118(d)(5) Cylinders 10 [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: 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 [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: 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 [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: Assumed that 25% of respondents start registering and reporting before the required start date 13 [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: Assumptions based on 2024 HFC Allocation Rule 37 [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: 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 [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: 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 [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: Assumed that 25% of respondents start registering and reporting before the required start date 2,500 [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: 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 [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: Assumed that 25% of respondents start registering and reporting before the required start date 2,500 [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: Assumptions based on 2024 HFC Allocation Rule 10,000 10,000 [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: 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 [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: Assumed that 25% of respondents start registering and reporting before the required start date 8 [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: 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 [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: Assumed that 25% of respondents start registering and reporting before the required start date 8 [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: Assumptions based on 2024 HFC Allocation Rule 31 31 [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: 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 $-



























Reclaimer Post emergency information by phone 0.00 0.00 0.00 (0.10) (0.10) $(3.74) $- $- 0.00 0.00 $-



























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)



























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)





































-21.61 452 -1138 $(88,124)


























Sheet 2: Respondent Burden Summary


*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***


Without Avoided Reclaimer Burden










Year Total Responses Total Hours Total Labor Costs Total O&M Costs Total Costs
Year 1 (2025) 8,739,279 166,538 $12,896,991.26 $0.00 $12,896,991.26
Year 2 (2026) 21,214,466 222,260 $15,740,028.39 $0.00 $15,740,028.39
Year 3 (2027) 21,366,296 223,432 $15,966,834.14 $0.00 $15,966,834.14
3yr ICR Annual Average 17,106,680 204,077 $14,867,951.26 $0.00 $14,867,951.26












With Avoided Reclaimer Burden










Year Total Responses Total Hours Total Labor Costs Total O&M Costs Total Costs
Year 1 (2025) 8,739,731 165,400 $12,808,867.17 $0.00 $12,808,867.17
Year 2 (2026) 21,214,918 221,122 $15,651,904.30 $0.00 $15,651,904.30
Year 3 (2027) 21,366,748 222,294 $15,878,710.06 $0.00 $15,878,710.06
3yr ICR Annual Average 17,107,132 202,939 $14,779,827.18 $0.00 $14,779,827.18












With Avoided Reclaimer Burden removed from average (for supporting statement)






Year Total Responses Total Hours Total Labor Costs Total O&M Costs Total Costs
Year 1 (2025) 8,739,279 166,538 $12,896,991.26 $0.00 $12,896,991.26
Year 2 (2026) 21,214,466 222,260 $15,740,028.39 $0.00 $15,740,028.39
Year 3 (2027) 21,366,296 223,432 $15,966,834.14 $0.00 $15,966,834.14
Annual Average 17,106,680 204,077 $14,867,951.26 $0.00 $14,867,951.26
Average Annual Avoided Reclaimer Burden and Costs 452 -1,138 -$88,124.00 $0.00 -$88,124.00
Incremental ICR Burden and Costs 17,107,132 202,939 $14,779,827.26 $0.00 $14,779,827.26

Sheet 3: Agency Burden

Subsection H Leak Repair, Inspection, ALD, and Reclamation Requirements


*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***




























Leak repair 15+ pound threshold; ALD for 1500+ pound CR and IPR equipment
































Annual Agency Burden and Cost






















































Assumptions

































Median Wage (2021) Total (+ Overhead)






























Overhead
1.60 Standard Government Benefits Multiplier





























Managerial Rate (GS 15 Step 1) $69.06 $110.50 From 2022 OPM hourly base pay table for DC region: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2021/DCB_h.pdf





























Technical Rate (GS 13 Step 1) $49.68 $79.49 From 2022 OPM hourly base pay table for DC region: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2021/DCB_h.pdf





























Clerical Rate (GS 11 Step 1) $34.86 $55.78 From 2022 OPM hourly base pay table for DC region: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2021/DCB_h.pdf





























Extramural Rate
$130.52 Source: Based on OYI average hourly rate for Senior Technical Analyst III and Consultant I under EPA contract 68HERH19D0029, TO 10































































Agency Tally
































Reviewing and Responding

































Year 1 Year 2 Year 3 Number of Responses per Respondent Agency Hours per Activity per Respondent and Loaded Hourly Wages Year 1 Year 1 Year 1 Year 2 Year 2 Year 2 Year 3 Year 3 Year 3


Year 1 Year 1 Year 1 Year 2 Year 2 Year 2 Year 3 Year 3 Year 3







Manag. Technical Clerical Contractor
























Activity Number of Respondents Number of Respondents Number of Respondents $110.50 $79.49 $55.78 $130.52 Total Annual Agency Hours Total Agency Labor Costs Number of Annual Responses Total Annual Agency Hours Total Agency Labor Costs Number of Annual Responses Total Annual Agency Hours Total Agency Labor Costs Number of Annual Responses

Total/Yr All Respondents Responses Costs Hours Responses Costs Hours Responses Costs Hours



Owners/operators of appliances with 15 or more pounds of HFC refrigerant prepare & submit requests for extensions to the 30-day repair timeline 275 285 294 1 - 0.25 - - 69 $5,460 275 71 $5,656 285 74 $5,850 294

Leak Repair/Inspection Reporting 875 $25,784.25 324 905 $26,675.99 336 935 $27,559.04 347



Owners/operators of appliances with 15 or more pounds of HFC refrigerant prepare & submit requests for extensions to 1 year retrofit timeline 55 57 59 1 - 1 - - 55 $4,368 55 57 $4,525 57 59 $4,680 59

Fire Suppression Reporting 20 $794.88 10 20 $794.88 10 20 $794.88 10



Owners/operators of appliances with 15 or more pounds of HFC refrigerant prepare & submit requests to cease a retrofit if all leaks are repaired 172 178 184 1 - 0.08 - - 14 $1,141 172 15 $1,179 178 15 $1,217 184

Tracking ID System 1 $1,817,964 15,120 1 $1,817,964 15,120 1 $1,363,473 11,340



Owners/operators of appliances with 15 or more pounds of HFC refrigerant that leak 125 percent or more of the full charge in a calendar year to submit report on leak and intended repair 365 378 390 1 - 0.50 - - 183 $14,517 365 189 $15,007 378 195 $15,492 390

Total 896 $1,844,542.65 15,454 926 $1,845,434.39 15,466 956 $1,391,826.56 11,697



Owners/operators of appliances with 15 or more pounds of HFC refrigerant notify EPA that purged refrigerants that are destroyed were excluded from annual leak rate calculations for the first time 7 8 8 1 - 0.50 - - 4 $298 7 4 $309 8 4 $319 8

Reclaimer Reporting and Recordkeeping 3 -$141.19 (2) 3 -$141.19 (2) 3 -$141.19 (2)
Average cost 1,693,793

HFC fire suppression equipment OEMs/servicers/recyclers prepare & submit annual reports 20 20 20 1 - 0.50 - - 10 $795 20 10 $795 20 10 $795 20

Total with Avoided 899 $1,844,401 15,452 929 $1,845,293 15,464 959 $1,391,685 11,695
Total cost 1,694,431

Develop and Maintain a Tracking ID System 1.0 1.0 0.75 1 120 3,000 - 12,000 15,120 $1,817,964 1 15,120 $1,817,964 1 11,340 $1,363,473 1



$1,693,793.34 14,204









SUBTOTAL 896 926 956 7 120 3,003 -
15,454 $1,844,543 896 15,466 $1,845,434 926 11,697 $1,391,827 956




































Respondents + EPA $1,693,793.34































3 (141) (2)








Requirement Type Activity



AVOIDED Hours per Activity per Respondent and Loaded Hourly Wages Burden Hours/Activity Labor Costs/Activity Capital Costs O&M Costs Total Hours and Costs



















Manag. Technical Clerical Contractor Number of Respondents/
Activity		 Annual Burden Hours Total Cost/Year



Total Annual Responses: Year 1 Year 1 Year 2 Year 2 Year 3 Year 3








$110.50 $79.49 $55.78 $130.52



Burden Per Response Hours Per Response Cost Per Response Hours Per Response Cost Per Response Hours Per Response Cost Per Response





Emergency Procedures Review submitted release report information



0.00 (0.50) 0.00 0.00 (0.50) $(39.74) $- $- 1.00 (0.50) $(40)



Leak Repair/Inspection Reporting 0.37 $29.48 0.37 $29.48 0.37 $29.48





Enter information into database tracking all releases



0.00 (0.50) (0.50) 0.00 (1.00) $(67.63) $- $- 1.00 (1.00) $(68)



Fire Suppression Reporting 0.50 $39.74 0.50 $39.74 0.50 $39.74





Transmit information to respective response authorities



0.00 (0.25) (0.25) 0.00 (0.50) $(33.82) $- $- 1.00 (0.50) $(34)



Tracking ID System 15120.00 $1,817,963.52 15120.00 $1,817,963.52 15120.00 $1,817,963.52











- (1) (1) - (2) (141) - - 3 (2) -$141



Reclaimer Reporting and Recordkeeping -0.67 -$47.06 -0.67 -$47.06 -0.67 -$47.06


























Average 17.19 $2,052.34 16.65 $1,986.49 12.20 $1,451.77





Sheet 4: Tables for Supporting Statement
Table V



*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***










Table VI - Respondent Burdent




Agency Burden


Respondent Sector Respondent Type Activity Affected Equipment Number of Respondents per Year Total Hours per Year Total Cost per Year


Year Total Total Hours Total Labor

Year Total Hours Total Costs

Y1 Y2 Y3 Y1 Y2 Y3 Y1 Y2 Y3


Responses Costs

Year 1 15,454 $1,844,543

Refrigeration and Air Conditioning HFC Equipment Owners & Operators Prepare and submit requests for extensions to 30-day repair timeline 15-50 pounds 137 141 144 68.7 70.3 71.8 $6,914 $7,073 $7,230


Year 1 8,739,279 166,538 $12,896,991

Year 2 15,466 $1,845,434

>50 pounds 137 144 151 68.7 72.0 75.4 $6,914 $7,252 $7,586


Year 2 21,214,466 222,260 $15,740,028

Year 3 11,697 $1,391,827

Prepare and submit requests for extensions to 1 yr retrofit/retire timeline 15-50 pounds 27 28 29 13.7 14.1 14.4 $1,383 $1,415 $1,446


Year 3 21,366,296 223,432 $15,966,834

Annual Average 14,206 $1,693,935

>50 pounds 27 29 30 13.7 14.4 15.1 $1,383 $1,450 $1,517


Annual Average 17,106,680 204,077 $14,867,951

Average Avoided Reclaimer Burden and Costs -2 $(141)

Prepare and submit request to cease a retrofit if all leaks are repaired 15-50 pounds 101 103 105 50.3 51.4 52.6 $5,061 $5,177 $5,292


Avoided Reclaimer Burden 452 (1,138) $(88,124)

Annual Average with Avoided Burden and Costs 14,203.56 $1,693,793

>50 pounds 72 75 79 35.8 37.6 39.3 $3,605 $3,781 $3,955


Incremental ICR Costs 17,107,132 202,939 $14,779,827





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 15-50 pounds 213 218 223 213 218 223 $21,471 $21,964 $22,454












>50 pounds 152 159 167 152 159 167 $15,294 $16,042 $16,780












Prepare and submit a report to EPA if excluding purged refrigerants that are destroyed from annual leak rate calculations for the first time 15-50 pounds 4 4 4 0.09 0.10 0.10 $9 $10 $10












>50 pounds 4 4 4 0.09 0.10 0.10 $9 $10 $10












Maintain purchase and service records 15-50 pounds 268,969 275,140 281,274 19,111 19,549 19,985 $1,923,576 $1,967,706 $2,011,573












>50 pounds 224,325 235,288 246,121 15,939 16,718 17,488 $1,604,295 $1,682,701 $1,760,174












Maintain equipment installation records 15-50 pounds 51,283 52,460 53,629 1,282 1,311 1,341 $129,046 $132,006 $134,949












>50 pounds 112,829 118,343 123,792 2,821 2,959 3,095 $283,914 $297,790 $311,500












Maintain retrofit and/or retirement plans 15-50 pounds 2,011 2,057 2,103 16,090 16,459 16,826 $1,619,492 $1,656,646 $1,693,578












>50 pounds 1,433 1,503 1,572 11,461 12,021 12,575 $1,153,592 $1,209,971 $1,265,679












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) 15-50 pounds 40 41 42 1.01 1.03 1.05 $101 $104 $106












>50 pounds 29 30 31 0.72 0.75 0.79 $72 $76 $79












Maintain records of purged and destroyed refrigerant if excluding such refrigerant from the leak rate 15-50 pounds 4 4 4 0.09 0.10 0.10 $9 $10 $10












>50 pounds 4 4 4 0.09 0.10 0.10 $9 $10 $10












Maintain reports on the results of verification tests any time leak rate threshold is exceeded 15-50 pounds 201,123 205,737 210,324 5,028 5,143 5,258 $506,091 $517,702 $529,243












>50 pounds 143,263 150,265 157,184 3,582 3,757 3,930 $360,497 $378,116 $395,525












Maintain quarterly leak inspection records IPR and CR >500 pounds 49,373 51,786 54,170 3,292 3,452 3,611 $331,300 $347,491 $363,490












Maintain annual leak inspection records 15-50 pounds 201,123 205,737 210,324 3,352 3,429 3,505 $337,394 $345,135 $352,829












>50 pounds 130,920 137,319 143,641 2,182 2,289 2,394 $219,625 $230,359 $240,965












Maintain copies of any reports submitted to EPA under the proposed reporting requirements in this action 15-50 pounds 482 494 505 8.0 8.2 8.4 $809 $828 $846












>50 pounds 392 411 430 6.5 6.9 7.2 $658 $690 $722












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. IPR and CR >1500 pounds with indirect ALD 24,658 25,863 27,054 411 431 451 $41,365 $43,386 $45,384












HFC Equipment Technicians Persons servicing HFC appliances provide leak inspection records to owners/operators 15-50 pounds 300,000 306,882 313,724 3,352 3,429 3,505 $185,064 $189,309 $193,529












>50 pounds 300,000 314,662 329,149 2,388 2,504 2,620 $131,824 $138,267 $144,632












Persons servicing HFC appliances provide reports on the results of verification tests any time leak rate threshold is exceeded to owners/operators 15-50 pounds 300,000 306,882 313,724 3,352 3,429 3,505 $185,064 $189,309 $193,529












>50 pounds 300,000 314,662 329,149 2,388 2,504 2,620 $131,824 $138,267 $144,632












Persons servicing appliances w/charge sizes >15 lbs provide invoices to appliance owners/operators 15-50 pounds 300,000 306,882 313,724 25,481 26,066 26,647 $1,406,797 $1,439,071 $1,471,152












>50 pounds 300,000 314,662 329,149 21,252 22,290 23,317 $1,173,292 $1,230,634 $1,287,294












Fire Suppression OEMs, Servicers, & Recyclers Annual report HFC Fire Suppression 20 20 20 188 188 188 $9,011 $9,011 $9,011












Maintain records 20 20 20 800 800 800 $38,344 $38,344 $38,344












HFC OEMs, Servicers, & Recyclers Register with tracking ID system Cylinders 1 3 1 0.5 1.5 0.5 $24 $72 $24












Enter data into tracking ID system 1 4 4 588 2,353 2,353 $28,194 $112,776 $112,776












Reclamation HFC Reclaimers One-time label redesign 31 - - 279 - - $13,372 $0 $0












Maintain records - 31 31 - 1,240 1,240 $- $59,433 $59,433












Tracking ID System HFC Producers Register with tracking ID system 10 1 1 5.0 0.5 0.5 $240 $24 $24












Enter data into tracking ID system 10 10 10 520 520 520 $24,924 $24,924 $24,924












HFC Importers Register with tracking ID system 75 1 1 37.5 0.5 0.5 $1,797 $24 $24












Enter data into tracking ID system 75 75 75 3,900 3,900 3,900 $186,927 $186,927 $186,927












HFC Packagers Register with tracking ID system 13 37 1 7 18.5 0.5 $312 $887 $24












Enter data into tracking ID system 13 50 50 3,824 14,706 14,706 $183,261 $704,851 $704,851












HFC Reclaimers Register with tracking ID system 8 23 1 1,250.0 11.5 0.5 $192 $551 $24












Enter data into tracking ID system 8 31 31 7,034.7 18,235 18,235 $225,552 $874,015 $874,015












HFC Suppliers Register with tracking ID system 2,500 7,500 1 4.0 3,750 1 $59,913 $179,738 $24












Enter data into tracking ID system 2,500 10,000 10,000 4,706 28,139 28,139 $337,174 $1,348,697 $1,348,697











Sheet 5: ICR 1626.18 9-6-2022
Section 608 ICR assumptions used as the basis for burden estimates for R&R associated with leak repair and leak inspection under Subsection H
















*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***














National Refrigerant Recycling and Emissions Reduction Program, EPA ICR Number: 1626.18, OMB Control Number: 2060-0256
































Annual Respondent Burden and Cost
































Assumptions
















Median Wage (2021) Total (+ Overhead)















110%













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)






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)






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)






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).






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).






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).






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).






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).























Respondent Tally















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 $809.42 - $0 - 1





Provide notice when equipment fails recertification 2 1 0.50 0.5 $50.59 1 $101 2 1

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

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

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

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

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


- - -
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

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 $633.54 86,667 $6,335,420 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 $356.16 15 $1,068 3 1

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

Recordkeeping 0.03 $2.36
Submit biannual report Golla, Emily: Updated to reflect 2021 report submissions 74 2 1.00 2.0 $142.46 148 $10,542 148 1

Third Party 0.03 $1.72
Transfer records when no longer operational 1 1 8.00 8.0 $569.86 8 $570 1 1

Average 0.03 $2.29
Recordkeeping by existing Technician Certification Programs 74 1 5.00 5.0 $356.16 370 $26,356 74 2

 


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

Annual Burden Annual Time Burden (Hours) Annual non-labor costs
Technicians Acquire certification cards 30,000 1 0.02 0.02 $0.92 500 $27,605 30,000 3

Reporting 849 N/A
Maintain certification cards 300,000 1 0.02 0.02 $0.92 5,000 $276,045 300,000 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 $4.06 22,079 $1,218,954 662,367 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 $3.63 19,700 $1,087,617 591,000 3





Provide leak inspection records to owner/operator 300,000 0.55 0.02 0.0 $0.51 2,770 $152,906 166,175 3





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





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





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





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





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





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





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





Maintain purchase and service records 255,083 6.25 0.03 0.2 $15.74 39,882 $5,236,883 1,595,275 2





Maintain leak inspection records 166,175 2.73 0.02 0.05 $4.59 7,574 $762,319 166,175 2





Maintain reports on the results of verification tests 166,175 1 0.03 0.03 $2.52 4,154 $418,150 166,175 2





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





Maintain records on mothballed equipment 137 1 0.03 0.03 $2.52 3 $345 137 2





Maintain information on purged/destroyed refrigerant 4 1 0.03 0.03 $2.52 0.1 $9 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 $11.98 4 $144 144 2





SUBTOTAL
572,727 varies varies varies varies 425,514 $31,432,946 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 $31,432,946

















































0 1














9.4











Sheet 6: Labeling Burden Estimates
Labeling and Packaging Burden Assumptions

Activity Hours per Response Basis for Assumptions
Administrative (Redesign) 3.5 Redesign costs only applies when new label or packaging needs to be desgined.
Graphic Design (Redesign) 5.5
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