Table 1a: Annual Respondent Burden and Cost – Emission Guidelines and Compliance Times for Existing Municipal Solid Waste Landfills (40 CFR Part 60, Subpart Cc and 40 CFR Part 62, Subpart GGG) (Renewal) | ||||||||
Private | 103.97 | 129.93 | 51.79 | |||||
Public | 46.67 | 62.9 | 25.25 | |||||
Burden Item | (A) Technical person-hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Technical person-hours per respondent per year (C=AxB) |
(D) Respondents per year a |
(E) Technical hours per year (E=CxD) |
(F) Management hours per year (F=Ex0.05) |
(G) Clerical hours per year (G=Ex0.10) |
(H) Total cost per year ($) b, c |
1. Reporting Requirements (Privately Owned Landfills) | ||||||||
A. Familiarize with regulatory requirements d | 1 | 1 | 1 | 142 | 142 | 7.1 | 14.2 | $16,421.66 |
B. Initial design capacity report | N/A | 1 | 0 | 0 | 0 | 0 | 0 | $0 |
C. Initial and annual NMOC emission rate reports e | N/A | 1 | 0 | 0 | 0 | 0 | 0 | $0 |
D. Collection and control system design plan | N/A | 1 | 0 | 0 | 0 | 0 | 0 | $0 |
E. Increments of progress | N/A | 5 | 0 | 0 | 0 | 0 | 0 | $0 |
F. Amended design capacity report f | 2 | 1 | 2 | 7.1 | 14.2 | 0.71 | 1.42 | $1,642.17 |
G. Annual compliance report g | 2 | 1 | 2 | 142 | 284 | 14.2 | 28.4 | $32,843.32 |
H. Landfill closure report h | 2 | 1 | 2 | 5 | 10 | 0.50 | 1.00 | $1,156.46 |
I. Equipment removal report i | 2 | 1 | 2 | 0 | 0 | 0 | 0 | $0 |
J. Surface methane monitoring | 14 | 4 | 56 | 142 | 7,952 | 397.6 | 795.2 | $919,613.02 |
Subtotal for Reporting Requirements for Privately Owned | 9,663 | $971,677 | ||||||
2. Reporting Requirements (Publicly Owned Landfills) | ||||||||
A. Familiarize with regulatory requirements d | 1 | 1 | 1 | 289 | 289 | 14.45 | 28.9 | $33,421.55 |
B. Initial design capacity report | N/A | 1 | 0 | 0 | 0 | 0 | 0 | $0 |
C. Initial and annual NMOC emission rate reports e | N/A | 1 | 0 | 0 | 0 | 0 | 0 | $0 |
D. Collection and control system design plan | N/A | 1 | 0 | 0 | 0 | 0 | 0 | $0 |
E. Increments of progress | N/A | 5 | 0 | 0 | 0 | 0 | 0 | $0 |
F. Amended design capacity report f | 2 | 1 | 2 | 14.45 | 28.9 | 1.45 | 2.89 | $1,512.63 |
G. Annual compliance report g | 2 | 1 | 2 | 289 | 578 | 28.9 | 57.8 | $30,252.52 |
H. Landfill closure report h | 2 | 1 | 2 | 9 | 18 | 0.90 | 1.8 | $942.12 |
I. Equipment removal report i | 2 | 1 | 2 | 0 | 0 | 0 | 0 | $0 |
J. Surface methane monitoring | 14 | 4 | 56 | 289 | 16,184 | 809.2 | 1618.4 | $847,070.56 |
Subtotal for Reporting Requirements for Publicly Owned | 19,663 | $913,199 | ||||||
3. Recordkeeping Requirements (Privately Owned Landfills) | ||||||||
A. Records of control system monitoring | 0.5 | 12 | 6 | 142 | 852 | 42.6 | 85.2 | $98,529.97 |
B. Records of accumulated refuse | 8 | 1 | 8 | 142 | 1,136 | 56.8 | 113.6 | $131,373.29 |
C. Records of surface methane monitoring | 0.5 | 4 | 2 | 142 | 284 | 14.2 | 28.4 | $32,843.32 |
D. Records of collection and control system exceedances | 0.5 | 4 | 2 | 142 | 284 | 14.2 | 28.4 | $32,843.32 |
E. Records of system design and initial performance test | N/A | 4 | 0 | 142 | 0 | 0 | 0 | $0 |
Subtotal for Recordkeeping Requirements for Privately Owned | 2,939 | $295,590 | ||||||
4. Recordkeeping Requirements (Publicly Owned Landfills) | ||||||||
A. Records of control system monitoring | 0.5 | 12 | 6 | 289 | 1,734 | 86.7 | 173.4 | $90,757.56 |
B. Records of accumulated refuse | 8 | 1 | 8 | 289 | 2,312 | 115.6 | 231.2 | $121,010.08 |
C. Records of surface methane monitoring | 0.5 | 4 | 2 | 289 | 578 | 28.9 | 57.8 | $30,252.52 |
D. Records of collection and control system exceedances | 0.5 | 4 | 2 | 289 | 578 | 28.9 | 57.8 | $30,252.52 |
E. Records of system design and initial performance test | N/A | 4 | 0 | 289 | 0 | 0 | 0 | $0 |
Subtotal for Recordkeeping Requirements for Publicly Owned Landfills | 5,982 | $272,273 | ||||||
Reporting and Recordkeeping Subtotals for Privately and Publicly Owned Landfills | ||||||||
Reporting Labor Burden (Privately Owned Landfills) | 9,663 | $971,676.62 | ||||||
Recordkeeping Labor Burden (Privately Owned Landfills) | 2,939 | $295,589.90 | ||||||
Subtotal Labor Burden and Cost (Privately Owned Landfills) | 12,602 | $1,267,267 | ||||||
Reporting Labor Burden (Publicly Owned Landfills) | 19,663 | $913,199.38 | ||||||
Recordkeeping Labor Burden (Publicly Owned Landfills) | 5,982 | $272,272.68 | ||||||
Subtotal Labor Burden and Cost (Publicly Owned Landfills) | 25,645 | $1,185,472 | ||||||
TOTAL LABOR BURDEN AND COST (rounded) j | 38,200 | $2,450,000 | ||||||
TOTAL CAPITAL AND O&M COST (rounded) j | $603,000 | |||||||
GRAND TOTAL (rounded) j | $3,050,000 | |||||||
Assumptions: | ||||||||
a We estimate there are 431 existing landfills subject to the emission guidelines. Of these, we estimate 142 (33%) landfills are private and 289 (67%) are public. | ||||||||
b This ICR uses the following labor rates: Technical $103.97 ($49.51 + 110%); Managerial $129.93 ($61.87+ 110%); and Clerical $51.79 ($24.66 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. | ||||||||
c Labor rates for Federal agency personnel were applied to publicly owned landfills, and are based on the average hourly labor rate as follows: Technical $46.67 (GS-12, Step 1, $29.17 + 60%); Managerial $62.90 (GS-13, Step 5, $39.31 + 60%); and Clerical $25.25 (GS-6, Step 3, $15.78 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2014 General Schedule, which excludes locality rates of pay. The rates have been applied to local agencies and have been increased by 60 percent to account for the benefit packages available to government employees. | ||||||||
d This ICR assumes all owners/operators of MSW landfills will have to re-familiarize with regulatory requirements each year | ||||||||
e This ICR assumes that all landfills affected by a State plan or the Federal plan have already exceeded the 50 Mg/yr NMOC emission threshold and are no longer submitting annual NMOC emission rate reports. | ||||||||
f This ICR assumes 5 percent of landfills will submit an amended design capacity report per year. | ||||||||
g We estimate that 33% of landfills are subject to the Federal plan and 67% of landfills are subject to a State plan. Our estimate of 142 private landfills includes 47 private landfills subject to the Federal plan and 95 private landfills subject to a State plan. Our estimate of 289 public landfills includes 95 public landfills subject to the Federal plan and 194 public landfills subject to a State plan. | ||||||||
h This ICR assumes 3 percent of landfills will submit a landfill closure report per year. | ||||||||
i This ICR assumes no landfills will submit an equipment removal report over the 3-year period of this ICR. | ||||||||
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding |
Table 1b: Average Annual State/Local Agency Burden and Cost – Emission Guidelines and Compliance Times for Existing Municipal Solid Waste Landfills (40 CFR Part 60, Subpart Cc and 40 CFR Part 62, Subpart GGG) (Renewal) | |||||||||
46.67 | 62.9 | 25.25 | |||||||
Burden Item | (A) Technical person-hours per occurrence |
(B) No. of occurrences per landfill per year |
(C) Landfills per agency (Average no. in States enforcing State plans)a |
(D) Technical person-hours per agency per year (D=AxBxC) |
(E) No. of agencies enforcing State plans a |
(F) Technical hours per year (F=DxE) |
(G) Management hours per year (G=Fx0.05) |
(H) Clerical hours per year (H=Fx0.10) |
(I) Total cost per year ($)b |
1. Reporting Requirements | |||||||||
A. Review initial design capacity report | N/A | 1 | 0 | 0 | 0 | 0 | 0 | 0 | $0 |
B. Review initial and annual NMOC emission rate reports c | N/A | 1 | 0 | 0 | 0 | 0 | 0 | 0 | $0 |
C. Review collection and control system design plan | N/A | 1 | 0 | 0 | 0 | 0 | 0 | 0 | $0 |
D. Review increments of progress | N/A | 5 | 0 | 0 | 0 | 0 | 0 | 0 | $0 |
E. Review amended design capacity report d | 1 | 1 | 0.43 | 0.43 | 34 | 14.62 | 0.73 | 1.46 | $765.21 |
F. Review annual compliance report e | 2 | 1 | 8.5 | 17 | 34 | 578 | 29 | 58 | $30,252.52 |
G. Review landfill closure report f | 1 | 1 | 0.26 | 0.26 | 34 | 8.84 | 0.44 | 0.88 | $462.69 |
H. Review equipment removal report g | 1 | 1 | 0 | 0 | 0 | 0 | 0 | 0 | $0 |
Total Labor Burden and Cost (rounded) h | 692 | $31,500 | |||||||
Assumptions: | |||||||||
a This ICR assumes that 289 landfills are subject to State plans, and that 34 State and local agencies will be enforcing State plans. Thus, each agency is expected to review reports for an average of 8.5 landfills. | |||||||||
b Labor rates for Federal agency personnel were applied to State/Local agencies, and are based on the average hourly labor rate as follows: Technical $46.67 (GS-12, Step 1, $29.17 + 60%); Managerial $62.90 (GS-13, Step 5, $39.31 + 60%); and Clerical $25.25 (GS-6, Step 3, $15.78 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2014 General Schedule, which excludes locality rates of pay. The rates have been applied to local agencies and have been increased by 60 percent to account for the benefit packages available to government employees. | |||||||||
c This ICR assumes that all landfills affected by a State plan have already exceeded the 50 Mg/yr NMOC emission threshold and are no longer submitting annual NMOC emission rate reports. | |||||||||
d This ICR assumes 5 percent of landfills will submit an amended design capacity report per year. | |||||||||
e We estimate that 33% of landfills are subject to the Federal plan and 67% of landfills are subject to a State plan. Our estimate of 289 landfills subject to a State plan includes 95 private landfills and 194 public landfills. | |||||||||
f This ICR assumes 3 percent of landfills will submit a landfill closure report per year. | |||||||||
g This ICR assumes no landfills will submit an equipment removal report over the 3-year period of this ICR. | |||||||||
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
Table 2: Average Annual EPA Burden and Cost – Emission Guidelines and Compliance Times for Existing Municipal Solid Waste Landfills (40 CFR Part 60, Subpart Cc and 40 CFR Part 62, Subpart GGG) (Renewal) | ||||||||
46.67 | 62.9 | 25.25 | ||||||
Burden Item | (A) Technical person-hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Technical person-hours per respondent per year (C=AxB) |
(D) Respondents per year a |
(E) Technical hours per year (E=CxD) |
(F) Management hours per year (F=Ex0.05) |
(G) Clerical hours per year (G=Ex0.10) |
(H) Total cost per year ($)b |
1. Reporting Requirements | ||||||||
A. Review initial design capacity report | N/A | 1 | 0 | 0 | 0 | 0 | 0 | $0 |
B. Review initial and annual NMOC rate reports c | N/A | 1 | 0 | 0 | 0 | 0 | 0 | $0 |
C. Review collection and control system design plan | N/A | 1 | 0 | 0 | 0 | 0 | 0 | $0 |
D. Review increments of progress | N/A | 5 | 0 | 0 | 0 | 0 | 0 | $0 |
E. Review amended design capacity report d | 1 | 1 | 1 | 7.1 | 7.1 | 0.36 | 0.71 | $371.61 |
F. Review annual compliance report | 2 | 1 | 2 | 142 | 284 | 14.2 | 28.4 | $14,864.56 |
G. Review landfill closure report e | 1 | 1 | 1 | 5 | 5 | 0.25 | 0.50 | $261.70 |
H. Review equipment removal report f | 1 | 1 | 1 | 0 | 0 | 0 | 0 | $0 |
Total Labor Burden and Cost (rounded) h | 341 | $15,500 | ||||||
Assumptions: | ||||||||
a We estimate there are 431 existing landfills that are subject to the emission guidelines. Of these, we estimate 142 (33%) of landfills are private and 289 (67%) are public. | ||||||||
b This cost is based on the average hourly labor rate as follows: Technical $46.67 (GS-12, Step 1, $29.17 + 60%); Managerial $62.90 (GS-13, Step 5, $39.31 + 60%); and Clerical $25.25 (GS-6, Step 3, $15.78 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2014 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. | ||||||||
c This ICR assumes that all landfills affected by a State plan or the Federal plan have already exceeded the 50 Mg/yr NMOC emission threshold and are no longer submitting annual NMOC emission rate reports. | ||||||||
d This ICR assumes 5 percent of landfills will submit an amended design capacity report per year. | ||||||||
e We estimate that 33% of landfills are subject to the Federal plan and 67% of landfills are subject to a State plan. Our estimate of 142 landfills subject to the Federal plan includes 47 private landfills and 95 public landfills. | ||||||||
f This ICR assumes 3 percent of landfills will submit a landfill closure report per year. | ||||||||
g This ICR assumes no landfills will submit an equipment removal report over the 3-year period of this ICR. | ||||||||
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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