$0
Subtotal (CDX One-Time Burden)
                                    $19,481
                                       0
                                       0
                                     $237
                                      $0
                                      $0
                                    $19,718
                                      $0
                                      $0
Class I Producer
Paper
                                    $5,713
                                    $2,285
                                    $1,143
                                     $100
                                      $40
                                      $20
                                    $5,813
                                    $2,325
                                    $1,163

Electronic
                                    $3,656
                                    $6,399
                                    $7,313
                                      $0
                                      $0
                                      $0
                                    $3,656
                                    $6,399
                                    $7,313
Class II Producer
Paper
                                    $4,570
                                    $2,285
                                    $1,143
                                      $80
                                      $40
                                      $20
                                    $4,650
                                    $2,325
                                    $1,163

Electronic
                                    $2,742
                                    $4,570
                                    $5,484
                                      $0
                                      $0
                                      $0
                                    $2,742
                                    $4,570
                                    $5,484
MeBr Producer
Paper
                                    $1,371
                                     $686
                                     $686
                                      $40
                                      $20
                                      $20
                                    $1,411
                                     $706
                                     $706

Electronic
                                      $0
                                     $457
                                     $457
                                      $0
                                      $0
                                      $0
                                      $0
                                     $457
                                     $457
Class I Imports
Paper
                                    $14,397
                                    $6,170
                                    $2,057
                                     $140
                                      $60
                                      $20
                                    $14,537
                                    $6,230
                                    $2,077

Electronic
                                    $7,313
                                    $14,625
                                    $18,282
                                      $0
                                      $0
                                      $0
                                    $7,313
                                    $14,625
                                    $18,282
Class II Imports
Paper
                                    $34,964
                                    $16,453
                                    $4,113
                                     $340
                                     $160
                                      $40
                                    $35,304
                                    $16,613
                                    $4,153

Electronic
                                    $16,453
                                    $32,907
                                    $43,876
                                      $0
                                      $0
                                      $0
                                    $16,453
                                    $32,907
                                    $43,876
MeBr Importer
Paper
                                    $2,285
                                    $1,143
                                    $1,143
                                      $40
                                      $20
                                      $20
                                    $2,325
                                    $1,163
                                    $1,163

Electronic
                                      $0
                                     $914
                                     $914
                                      $0
                                      $0
                                      $0
                                      $0
                                     $914
                                     $914
Class I Exports
Paper
                                    $4,113
                                    $2,057
                                     $514
                                      $40
                                      $20
                                      $5
                                    $4,153
                                    $2,077
                                     $519

Electronic
                                    $2,285
                                    $4,113
                                    $5,484
                                      $0
                                      $0
                                      $0
                                    $2,285
                                    $4,113
                                    $5,484
Class II Exports
Paper
                                    $8,227
                                    $4,113
                                    $2,057
                                      $80
                                      $40
                                      $20
                                    $8,307
                                    $4,153
                                    $2,077

Electronic
                                    $9,141
                                    $12,797
                                    $14,625
                                      $0
                                      $0
                                      $0
                                    $9,141
                                    $12,797
                                    $14,625
MeBr Exporter
Paper
                                    $6,856
                                    $3,428
                                    $1,143
                                     $120
                                      $60
                                      $20
                                    $6,976
                                    $3,488
                                    $1,163

Electronic
                                      $0
                                    $2,742
                                    $4,570
                                      $0
                                      $0
                                      $0
                                      $0
                                    $2,742
                                    $4,570
Second-Party Destruction
Paper
                                    $2,571
                                    $1,143
                                     $286
                                      $45
                                      $20
                                      $5
                                    $2,616
                                    $1,163
                                     $291

Electronic
                                      $0
                                    $1,143
                                    $1,828
                                      $0
                                      $0
                                      $0
                                      $0
                                    $1,143
                                    $1,828
Second-Party Transformation
Paper
                                    $7,998
                                    $3,999
                                     $857
                                     $140
                                      $70
                                      $15
                                    $8,138
                                    $4,069
                                     $872

Electronic
                                      $0
                                    $3,199
                                    $5,713
                                      $0
                                      $0
                                      $0
                                      $0
                                    $3,199
                                    $5,713
Class I Laboratory Supplier
Paper
                                    $8,227
                                    $4,113
                                    $2,057
                                      $80
                                      $40
                                      $20
                                    $8,307
                                    $4,153
                                    $2,077

Electronic
                                    $9,141
                                    $12,797
                                    $14,625
                                      $0
                                      $0
                                      $0
                                    $9,141
                                    $12,797
                                    $14,625
Class II Request for Additional Consumption Allowances
Paper
                                    $3,085
                                    $1,543
                                    $1,543
                                      $30
                                      $15
                                      $15
                                    $3,115
                                    $1,558
                                    $1,558

Electronic
                                    $5,484
                                    $6,856
                                    $6,856
                                      $0
                                      $0
                                      $0
                                    $5,484
                                    $6,856
                                    $6,856
Class II Trades
Paper
                                    $24,680
                                    $12,340
                                    $2,057
                                     $240
                                     $120
                                      $20
                                    $24,920
                                    $12,460
                                    $2,077

Electronic
                                      $0
                                    $10,969
                                    $20,110
                                      $0
                                      $0
                                      $0
                                      $0
                                    $10,969
                                    $20,110
MeBr Trades
Paper
                                    $3,085
                                    $1,028
                                    $1,028
                                      $30
                                      $10
                                      $10
                                    $3,115
                                    $1,038
                                    $1,038

Electronic
                                      $0
                                    $1,828
                                    $1,828
                                      $0
                                      $0
                                      $0
                                      $0
                                    $1,828
                                    $1,828
MeBr Distributor of QPS
Paper
                                    $15,996
                                    $7,998
                                    $1,143
                                     $280
                                     $140
                                      $20
                                    $16,276
                                    $8,138
                                    $1,163

Electronic
                                      $0
                                    $6,399
                                    $11,883
                                      $0
                                      $0
                                      $0
                                      $0
                                    $6,399
                                    $11,883
MeBr Sales of Critical Use
Paper
                                     $343
                                     $171
                                      $0
                                      $10
                                      $5
                                      $0
                                     $353
                                     $176
                                      $0

Electronic
                                      $0
                                     $114
                                      $0
                                      $0
                                      $0
                                      $0
                                      $0
                                     $114
                                      $0
MeBr Pre-2005 Stock
Paper
                                     $343
                                     $171
                                     $171
                                      $10
                                      $5
                                      $5
                                     $353
                                     $176
                                     $176

Electronic
                                      $0
                                     $114
                                     $114
                                      $0
                                      $0
                                      $0
                                      $0
                                     $114
                                     $114
Petition to Import
Paper
                                    $25,709
                                    $10,283
                                    $2,571
                                     $250
                                     $100
                                      $25
                                    $25,959
                                    $10,383
                                    $2,596

Electronic
                                      $0
                                    $13,711
                                    $20,567
                                      $0
                                      $0
                                      $0
                                      $0
                                    $13,711
                                    $20,567
Destruction Efficiency Report
Paper
                                     $514
                                     $514
                                     $514
                                      $5
                                      $5
                                      $5
                                     $519
                                     $519
                                     $519
MeBr Applications
Paper
                                    $8,684
                                    $8,684
                                    $8,684
                                      $10
                                      $10
                                      $10
                                    $8,694
                                    $8,694
                                    $8,694
Subtotal (Reporting to EPA)
                                   239,946
                                   227,263
                                   219,436
                                    $2,110
                                    $1,000
                                     $335
                                   $242,056
                                   $228,263
                                   $219,771
Transformation Verification
Paper
                                    $14,397
                                    $14,397
                                    $14,397
                                     $140
                                     $140
                                     $140
                                    $14,537
                                    $14,537
                                    $14,537
Destruction Verification
Paper
                                    $4,628
                                    $4,628
                                    $4,628
                                      $45
                                      $45
                                      $45
                                    $4,673
                                    $4,673
                                    $4,673
Lab Certification
Paper
                                   $114,260
                                   $114,260
                                   $114,260
                                    $5,000
                                    $5,000
                                    $5,000
                                   $119,260
                                   $119,260
                                   $119,260
MeBr QPS Applicator Certification
Paper
                                    $9,598
                                    $9,598
                                    $9,598
                                     $420
                                     $420
                                     $420
                                    $10,018
                                    $10,018
                                    $10,018
MeBr Commodity Owner, Shipper or Agent Recordkeeping
Paper
                                    $28,565
                                    $28,565
                                    $28,565
                                    $1,250
                                    $1,250
                                    $1,250
                                    $29,815
                                    $29,815
                                    $29,815
MeBr End User Self-Certification
Paper
                                    $28,565
                                    $28,565
                                    $28,565
                                    $5,000
                                    $5,000
                                    $5,000
                                    $33,565
                                    $33,565
                                    $33,565
Subtotal (Reporting to Other Stakeholders)
                                   200,012
                                   200,012
                                   200,012
                                    $11,855
                                    $11,855
                                    $11,855
                                   $211,867
                                   $211,867
                                   $211,867
Total
                                   459,439
                                   427,275
                                   419,448
                                    $14,202
                                    $12,855
                                    $12,190
                                   $473,641
                                   $440,130
                                   $431,638

(c)	Estimating Agency Burden and Costs

The conversion to an electronic reporting system as well as the adoption of CDX to facilitate form submission and processing are expected to create long term burden reductions and increased efficiencies for EPA. Because the current electronic reporting system via CDX is voluntary and only allows for the electronic submission of select reports, the Agency first will need to make some adjustment to convert to a mandatory electronic reporting system. EPA estimates incurring a one-time cost of $200,000 to upgrade CDX to accept additional electronic ODS report. In addition, annual costs will be associated with the operation and maintenance (O&M) of CDX for the data flow. EPA developed an estimate of CDX O&M costs attributable to chemical reporting program by apportioning the overall CDX maintenance cost estimated in the CROMERR ICR to individual programs. This approach yields an estimate of $57,353 per year per program. Note that although the data flow for this ICR will be smaller than the data flows included in the CROMERR analysis, the CROMERR analysis does not include costs associated with operations and, therefore, the $57,353 might be considered a lower bound estimate of total O&M.

Agency burden savings are expected to result from the elimination of the need to process paper forms and from the use of more automated quality assurance/quality control (QA/QC).

The overarching assumption used in the analysis of the respondent burden and cost is that the respondent burden and cost for the three years of this ICR will vary each year based on the number of paper and electronic reports submitted. Specifically:

 After Year 1 the burden of entering data into the ODS tracking system is assumed to decrease as reporters transition from paper to electronic reports;
 After Year 1 the burden of preparing, reviewing, and processing company balance statements is assumed to decrease as more communications are sent electronically; and
 After Year 2 the burden of providing reporting guidance is assumed to decrease.

Costs are subdivided into Agency and contractor costs. The average hourly rates for EPA technical and managerial staff of $45.42 and $63.14, respectively, are derived from the 2017 annual base pay table, which was retrieved from the Office of Personnel Management website. EPA then multiplied hourly rates by the standard government benefits multiplication factor of 1.6 to get hour rates of $72.67 for technical staff and $101.02 for managerial staff. The cost of contractor time and overhead is valued at $105.00 per hour, including overhead and fringe. The number of occurrences of each activity is based on the reporting requirements and EPA's experience with reporting under both the CFC and HCFC allowance systems.

Table VII. and below summarizes total burden hours and total costs of each activity for Year 1, Year 2, and Year 3. Total burden hours are calculated by multiplying the number of activities by staff hours per activity. Total costs are calculated by multiplying total burden hours by the assumed hourly wage rate of staff and adding these costs to non-labor costs associated with CDX updates and maintenance.
Table VII. Agency Burden  -  Total Burden Hours
                                   Activity
                         Managerial Hours per Activity
                         Technical Hours per Activity
                        Contractor Hours per Activity
                             Number of Activities
                                 Total Hours

                                      Y1
                                      Y2
                                      Y3
                                      Y1
                                      Y2
                                      Y3
Collect and Process MeBr Applications
                                                                            1.0
                                                                            2.0
                                                                            0.0
                                                                            2.0
                                                                            2.0
                                                                            2.0
                                                                            6.0
                                                                            6.0
                                                                            6.0
Notify Submitters of Baseline Allowances
                                                                            0.5
                                                                            1.0
                                                                            0.0
                                                                           28.0
                                                                           28.0
                                                                           28.0
                                                                           42.0
                                                                           42.0
                                                                           42.0
Enter Data in the ODS Tracking System
                                                                            0.0
                                                                            1.0
                                                                            0.0
                                                                          419.0
                                                                          197.0
                                                                           64.0
                                                                          419.0
                                                                          197.0
                                                                           64.0
Review Data for Reporting Compliance
                                                                            0.2
                                                                            1.0
                                                                            1.0
                                                                          455.0
                                                                          455.0
                                                                          453.0
                                                                        1,001.0
                                                                        1,001.0
                                                                          996.6
Prepare and Process Paper Company Balance Statements
                                                                            0.2
                                                                            0.5
                                                                            0.5
                                                                          208.0
                                                                           97.0
                                                                           37.0
                                                                          249.6
                                                                          116.4
                                                                           44.4
Process Transfer Requests
                                                                            0.0
                                                                            1.0
                                                                            0.0
                                                                           54.0
                                                                           54.0
                                                                           54.0
                                                                           54.0
                                                                           54.0
                                                                           54.0
Review Petitions Submitted to Import Used ODS
                                                                            2.0
                                                                            4.0
                                                                            0.0
                                                                           50.0
                                                                           50.0
                                                                           50.0
                                                                          300.0
                                                                          300.0
                                                                          300.0
Provide Reporting Guidance
                                                                            0.3
                                                                            1.0
                                                                            0.0
                                                                           30.0
                                                                           30.0
                                                                           15.0
                                                                           37.5
                                                                           37.5
                                                                           18.8
Conduct Stakeholder Outreach Efforts
                                                                            4.0
                                                                           10.0
                                                                           40.0
                                                                            3.0
                                                                            2.0
                                                                            1.0
                                                                          162.0
                                                                          108.0
                                                                           54.0
Maintain the ODS Tracking System
                                                                           30.0
                                                                          175.0
                                                                          300.0
                                                                            1.0
                                                                            1.0
                                                                            1.0
                                                                          505.0
                                                                          505.0
                                                                          505.0
Ensure Non-Exceedance of Montreal Protocol Caps
                                                                            2.0
                                                                            8.0
                                                                           40.0
                                                                            2.0
                                                                            2.0
                                                                            2.0
                                                                          100.0
                                                                          100.0
                                                                          100.0
Ensure Non-Exceedance of CAAA Limits
                                                                            2.0
                                                                            8.0
                                                                           40.0
                                                                            1.0
                                                                            1.0
                                                                            1.0
                                                                           50.0
                                                                           50.0
                                                                           50.0
Report to the Ozone Secretariat
                                                                            4.0
                                                                           30.0
                                                                           40.0
                                                                            1.0
                                                                            1.0
                                                                            1.0
                                                                           74.0
                                                                           74.0
                                                                           74.0
Seek Information on MeBr CUE Program and Fumigation Industry
                                                                            0.3
                                                                            0.3
                                                                            0.3
                                                                           75.0
                                                                           75.0
                                                                           75.0
                                                                           37.5
                                                                           37.5
                                                                           37.5

                                                                        3,037.6
                                                                        2,628.4
                                                                        2,346.3

Table VIII. Agency Burden  -  Total Costs
                                   Activity
                                  Total Costs

                                      Y1
                                      Y2
                                      Y3
Collect and Process MeBr Applications
                                                                           $493
                                                                           $493
                                                                           $493
Notify Submitters of Baseline Allowances
                                                                         $3,449
                                                                         $3,449
                                                                         $3,449
Enter Data in the ODS Tracking System
                                                                        $30,449
                                                                        $14,316
                                                                         $4,651
Review Data for Reporting Compliance
                                                                        $90,033
                                                                        $90,033
                                                                        $89,637
Prepare and Process Paper Company Balance Statements
                                                                        $22,680
                                                                        $10,577
                                                                         $4,034
Process Trade Reports
                                                                         $3,924
                                                                         $3,924
                                                                         $3,924
Review Petitions to Import Used ODS
                                                                        $24,636
                                                                        $24,636
                                                                        $24,636
Provide Reporting Guidance
                                                                         $2,938
                                                                         $2,938
                                                                         $1,469
Conduct Stakeholder Outreach Efforts
                                                                        $15,992
                                                                        $10,662
                                                                         $5,331
Maintain the ODS Tracking System
                                                                        $47,248
                                                                        $47,248
                                                                        $47,248
Ensure Non-Exceedance of Montreal Protocol Caps
                                                                         $9,967
                                                                         $9,967
                                                                         $9,967
Ensure Non-Exceedance of CAAA Limits
                                                                         $4,983
                                                                         $4,983
                                                                         $4,983
Report to the Ozone Secretariat
                                                                         $6,784
                                                                         $6,784
                                                                         $6,784
Seek Information on MeBr CUE Program and Fumigation Industry
                                                                         $3,257
                                                                         $3,257
                                                                         $3,257
Subtotal (Labor Costs)
                                                                       $266,832
                                                                       $233,266
                                                                       $209,863
CDX Upgrade
                                                                       $200,000
                                                                             $0
                                                                             $0
CDX Maintenance
                                                                        $57,353
                                                                        $57,353
                                                                        $57,353
Subtotal (Non-Labor Costs)
                                                                       $257,353
                                                                        $57,353
                                                                        $57,353
Total
                                                                       $524,185
                                                                       $290,619
                                                                       $267,216

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

The values for respondent universe and total burden and costs are based on estimates of the number of respondents and hours to compile data and prepare reports. Historical data from reports submitted over the last several years and consultations with stakeholders were used to develop estimates. Costs associated with compliance for EPA and respondents are averages and were estimated from publicly available data sources. The total also reflects Agency practice of periodically seeking necessary information from the regulated community through the use of its authority under Section 114 of the Clean Air Act. No new recordkeeping and reporting requirements were added.

(e) 	Bottom Line Burden Hours and Cost Tables

	(i)  Respondent Tally

As shown in Table IX., EPA estimates the total annual hour and cost burden to all respondents to average 3,811 hours and $448,470. Therefore, over the three-year span of this ICR, the total burden estimated for compliance for respondents is estimated to be 11,432 hours (3,811 x 3 years) and $1,345,410 ($448,470 x 3 years).

Table IX. Respondent Burden Summary Table

                             Total Hours Per Year
                           Total Labor Cost Per Year
                          Total O&M Cost per Year
                              Total Cost Per Year
Year 1
                                                                          4,021
                                                                       $459,439
                                                                        $14,202
                                                                       $473,641
Year 2
                                                                          3,740
                                                                       $427,275
                                                                        $12,855
                                                                       $440,130
Year 3
                                                                          3,671
                                                                       $419,448
                                                                        $12,190
                                                                       $431,638
Annual Average
                                                                          3,811
                                                                       $435,388
                                                                        $13,082
                                                                       $448,470

      (ii) The Agency Tally

As shown in Table X., EPA estimates the total annual hour and cost burden to the Agency to average 2,671 hours and $360,673. Therefore, over the three-year span of this ICR, the total burden estimated for compliance for respondents is estimated to be 8,012 hours (2,671 x 3 years) and $1,082,020 ($360,673 x 3 years).

Table X. Agency Burden Summary Table

                             Total Hours Per Year
                           Total Labor Cost Per Year
                          Total O&M Cost per Year
                              Total Cost Per Year
Year 1
                                                                          3,038
                                                                       $266,832
                                                                       $257,353
                                                                       $524,185
Year 2
                                                                          2,628
                                                                       $233,266
                                                                        $57,353
                                                                       $290,619
Year 3
                                                                          2,346
                                                                       $209,863
                                                                        $57,353
                                                                       $267,216
Annual Average
                                                                          2,671
                                                                       $236,654
                                                                       $124,020
                                                                       $360,673

(f)	Reasons for Change in Burden

This ICR consolidates three existing ICRs: Class I, Class II, and Methyl Bromide. A comparison of the total estimated burden hours and costs as presented in this ICR relative to the existing Class I, Class II, and Methyl Bromide ICRs is summarized in below.
Table XI. Comparison with Existing ICRs
                                Annual Average
                             Total Hours Per Year
                           Total Labor Cost Per Year
                          Total O&M Cost per Year
                              Total Cost Per Year
                               Respondent Burden
Class I ICR (1432.31)
                                     2,439
                                   $259,213
                                    $5,535
                                   $264,748
Class II ICR (2014.05)
                                     1,434
                                   $152,109
                                    $1,155
                                   $153,264
MeBr ICR (2031.08)
                                     1,582
                                   $191,886
                                      $0
                                   $191,886
Subtotal
                                     5,454
                                   $603,207
                                    $6,690
                                   $609,897
This ICR
                                    3,811
                                   $435,388
                                   $13,082
                                   $448,470
Difference
                                    (1,644)
                                  ($167,820)
                                    $6,392
                                  ($161,427)
                                 Agency Burden
Class I ICR (1432.31)
                                     1,128
                                    $88,595
                                      $0
                                    $88,595
Class II ICR (2014.05)
                                     2,470
                                   $200,614
                                      $0
                                   $200,614
MeBr ICR (2031.08)
                                     2,225
                                   $136,160
                                      $0
                                   $136,160
Subtotal
                                     5,823
                                   $425,369
                                      $0
                                   $425,369
This ICR
                                    2,671
                                   $236,654
                                   $124,020
                                   $360,673
Difference
                                    (3,153)
                                  ($188,716)
                                   $124,020
                                   ($64,696)

As shown, the estimated burden hours and labor costs have decreased compared to previous ICRs. This is because the merged ICR accounts for the transition from paper to electronic reporting. Even accounting for the one-time burden associated with the transition to electronic reporting (i.e., CDX registration and CDX electronic signature), the electronic reporting results in overall burden reduction for respondents.  While the one-time burden associated with the transition to electronic reporting (i.e., CDX registration and electronic signature) temporarily increases burden, overall burden decreases because of the efficiencies associated with electronic reporting. Furthermore, the estimated Agency burden hours and labor costs have also decreased due to the transition to electronic reporting, overall costs have increased slightly due to the one-time CDX update and annual CDX O&M costs.

(h) 	Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average two hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

According to the Paperwork Reduction Act, "burden" means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. For this collection it includes the time needed to review instructions; develop, acquire, install and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control number for this information collection appears above. The OMB control numbers for EPA's regulations in title 40 of the CFR, after appearing in the Federal Register, are listed in 40 CFR part 9 and included on the related collection instrument or form, if applicable.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques.