2498ss02

SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
NSPS Review for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart XXX)
1. Identification of the Information Collection
1(a) Title of the Information Collection
NSPS Review for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart XXX) EPA
ICR Number 2498.02, OMB Control Number 2060-0697.
1(b) Short Characterization/Abstract
The New Source Performance Standards (NSPS) for Municipal Solid Waste Landfills
were proposed on May 30, 1991, promulgated on May 12, 1996, and amended on June 16, 1998
(63 FR 32753), February 24, 1999 (64 FR 9262), and April 10, 2000 (65 FR 18909). These
standards apply to municipal solid waste landfills that commenced construction, modification, or
reconstruction on or after May 30, 1991.
Clean Air Act (CAA) section 111(b)(1)(B) requires the EPA to “at least every 8 years
review and, if appropriate, revise” new source performance standards. In response to this
mandate, EPA proposed a new subpart (40 CFR part 60, subpart XXX) that will apply to
municipal solid waste landfills that commenced construction, modification, or reconstruction
after July 17, 2014.
The proposed subpart included provisions reducing the NMOC emission rate threshold that
triggers the requirement to install controls to 40 megagrams per year (Mg/yr) from the current
NSPS level of 50 Mg/yr (see 40 CFR part 60, subpart WWW).

EPA is issuing a supplemental proposal to lower the emission rate threshold from 40
Mg/yr to 34 Mg/yr. The proposed option retains the design capacity cutoff of 2.5 million Mg and
2.5 million cubic meters in the current NSPS. The proposed option also retains the same
recordkeeping and reporting requirements that were included in the ICR submitted under EPA
ICR Number 2498.01 for the July 17, 2014 proposal. The proposed option is hereinafter referred
to as “option 2.5/34.” This information is being collected to assure compliance with the proposed
40 CFR part 60, subpart XXX.
In general, the landfills NSPS require initial notifications are required to submit initial
notifications and reports and maintain records, and conduct initial performance tests and periodic
monitoring. Landfill owners/operators must submit an initial design capacity report, initial
performance test report, emission rate reports, and collection and control system design plans.
Landfill closure and equipment removal reports are required when the landfill closes or the
landfill meets the criteria for removing controls. Annual compliance reports must include the
following information: descriptions of any period in which the value of any of the monitored
operating parameters fell outside the specified ranges, any period during which the monitoring

2
system is not operating or when the collected gas was diverted from the control device, and any
exceedances during the period.
Landfill owners or operators must keep continuous monitoring records of the parameters
reported in the initial performance report; records of monthly monitoring of wellhead
temperature, pressure, and nitrogen or oxygen concentration; and records of quarterly monitoring
of surface methane concentrations. Landfill owners or operators must also maintain records of
all reports, plot map, and well locations. The recordkeeping and reporting requirements specific
to municipal solid waste landfills are detailed in Section 4(b) of this supporting statement. These
notifications, reports, and records are essential in determining compliance and are required of all
affected facilities subject to the NSPS.
Any owner or operator subject to the provisions of proposed subpart XXX will maintain a
file of these measurements, and retain the file for at least five years following the date of such
measurements, maintenance reports, and records. All reports are sent to the delegated state or
local authority. In the event that there is no such delegated authority, the reports are sent directly
to the United States Environmental Protection Agency (EPA) regional office.
Based on our consultations with industry representatives, there is an average of one
affected facility at each plant site, and each plant site has only one respondent (i.e., the
owner/operator of the landfill).
It is estimated that on average, 137 respondents per year will be subject to the regulation
in the next three years based on a design capacity threshold of at least 2.5 million Mg and cubic
meters. It is also estimated that an average of two additional respondents per year with a design
capacity threshold less than 2.5 million Mg or cubic meters will become subject to the regulation
in the next three years.
Approximately 147 new or modified municipal solid waste (MSW) facilities, which are
owned and operated by the public and private landfill owners (the “Affected Public”), would be
subject to the regulation over the next three years. Forty-five of the facilities are publicallyowned and 102 facilities are privately-owned, for-profit businesses. The burden to the “Affected
Public” may be found in Tables 1.A to 3.B in Attachments A and B. The cost of this ICR to all
MSW facilities is $6.1 million in labor costs, averaged over the first 3 years after the proposal is
final.
The burden to the “Federal Government” is attributed entirely to work performed by
federal employees or government contractors or to state or local agencies that have been
delegated authority; this burden may be found in Tables 1.C through 3.C of Attachment C.
2. Need for and Use of the Collection
2(a) Need/Authority for the Collection
The EPA is charged under section 111 of the Clean Air Act (CAA), as amended, to
establish standards of performance for new stationary sources that reflect:

3
. . . the degree of emission limitation achievable through the
application of the best system of emission reduction which (taking
into consideration the cost of achieving such emissions reduction,
or any non-air quality health and environmental impact and energy
requirements) the Administrator determines has been adequately
demonstrated. Section 111(a)(l).
The EPA refers to this charge as selecting the best system of emission reduction (BSER)
Section 111 also requires that the Administrator review and, if appropriate, revise such standards
every eight years.
In addition, CAA section 114(a) states that the Administrator may require any
owner/operator subject to any requirement of this CAA to:
(A) Establish and maintain such records; (B) make such reports;
(C) install, use, and maintain such monitoring equipment, and use
such audit procedures, or methods; (D) sample such emissions (in
accordance with such procedures or methods, at such locations, at
such intervals, during such periods, and in such manner as the
Administrator shall prescribe); (E) keep records on control
equipment parameters, production variables or other indirect data
when direct monitoring of emissions is impractical; (F) submit
compliance certifications in accordance with Section 114(a)(3);
and (G) provide such other information as the Administrator may
reasonably require.
The Administrator has determined that landfill gas emissions from municipal solid waste
landfills either cause or contribute to air pollution that may reasonably be anticipated to endanger
public health or welfare. Therefore, the NSPS were promulgated for this source category at 40
CFR part 60, subpart WWW and a review of these NSPS is being proposed under new subpart
XXX.
2(b) Practical Utility/Users of the Data
The recordkeeping and reporting requirements in the standard ensure compliance with the
applicable regulations, which were promulgated in accordance with the CAA. In addition, the
collected information is used for targeting inspections and as evidence in legal proceedings.
Performance tests are required in order to determine an affected facility’s initial
capability to comply with the emission standard. Continuous emission monitors are used to
ensure compliance with the standard at all times. During the performance test, a record of the
operating parameters under which compliance was achieved may be recorded and used to
determine compliance in place of a continuous emission monitor.

4
The notifications required in the standard are used to inform the EPA or delegated
authority when a source becomes subject to the requirements of the regulations. The reviewing
authority may then inspect the source to check if the pollution control devices are properly
installed and operated, that leaks are being detected and repaired, and that the standards are being
met. The performance test may also be observed.
The required reports are used to determine periods of excess emissions, identify problems
at the facility, verify operation/maintenance procedures and for compliance determinations.
3. Non-duplication, Consultations, and Other Collection Criteria
The requested recordkeeping and reporting are required under proposed 40 CFR part 60,
subpart XXX.
3(a) Non-duplication
If the subject standards have not been delegated, the information is sent directly to the
appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state
or local agency. If a state or local agency has adopted its own similar standards to implement the
federal standards, a copy of the report submitted to the state or local agency can be sent to the
Administrator in lieu of the report required by the federal standards. Therefore, no duplication
exists.
3(b) Public Notice Required Prior to ICR Submission to OMB
A public notice of this collection is provided in the Federal Register notice of the
supplemental proposed rulemaking published for the NSPS Review for Municipal Solid Waste
Landfills.
3(c) Consultations
Industry experts have been consulted and the EPA’s internal data sources and projections
of industry and growth over the next three years have been considered. The primary source of
information is the data from 40 CFR part 98, subpart HH of the EPA Greenhouse Gas Reporting
Program (GHGRP). This data was supplemented with a database maintained by EPA’s Landfill
Methane Outreach Program (LMOP), as well as information received from EPA Regional
Offices and state authorities, and public comments regarding landfills expected to be built or
modify between 2014-2018.
Based on these data sources, a consolidated database of 14 new landfills was created,
consisting of 11 model landfills and three landfills that have been permitted but not yet
constructed. The growth rate for the industry and attributes for the these model landfills are
based on the assumption that the sizes and locations of landfills opening in the most recent
complete eight years of data (2005-2012) from the above three data sources would be similar to
landfills opening in the next 8 years (2013-2020). In addition to the new landfills, the EPA
database shows a total of 133 modified sources during the period of 2014-2018.

5
Given the numerous reporting and recordkeeping similarities between proposed subpart
XXX and the currently promulgated NSPS subpart WWW, many of the line item burden
estimates in this ICR estimate are the same as the burdens recently submitted to OMB under ICR
number 1557.09 for the most recent ICR renewal for subpart WWW. For the most recent subpart
WWW ICR renewal, industry trade associations and other parties were provided an opportunity
to comment on the burden associated with the standard. For the most recent subpart WWW ICR
renewal, industry trade associations EPA consulted with two trade groups: the Solid Waste
Association of North America (SWANA) at (800) 467-9262, and the National Waste &
Recycling Association (NW&RA) at (202) 244-4700. EPA received written comments from the
Solid Waste Association of North America (SWANA) requesting that EPA adjust the line item
estimates for certain burden items. 1 While the estimated respondent universe and labor rates for
subpart XXX as well as some of burden line item estimates in subpart XXX are unique to this
subpart, many of the comments on the ICR renewal for subpart WWW were relevant for
improving the burden estimates in this ICR. The burden table calculations provide notes on
which burden line items reflect public comments received on the ICR renewal for subpart
WWW.
The public was provided an opportunity to review and comment on the burden estimated
in the ICR for the July 17, 2014 proposed subpart XXX (79 FR 41796). In these comments, the
EPA received comments that its estimates did not accurately account for the burden on MSW
landfills that would become modified and become subject to subpart XXX. The EPA has revised
its estimates to incorporate both new and modified sources in this ICR. The public will be
provided the opportunity to review and comment on the burden estimated in this Information
Collection Request during the comment period for the proposed rulemaking.
3(d) Effects of Less Frequent Collection
Less frequent information collection would decrease the margin of assurance that
facilities are continuing to meet the standards. Requirements for information gathering and
recordkeeping are useful techniques to ensure that good operation and maintenance practices are
applied and that emission limitations are met. If the information required by these standards was
collected less frequently, the proper operation and maintenance of control equipment and the
possibility of detecting violations would be less likely. The EPA will be considering mechanisms
to further streamline recordkeeping and reporting requirements as part of the notice and
comment process on this proposal.
3(e) General Guidelines
None of these reporting or recordkeeping requirements violate any of the regulations
established by OMB at 5 CFR part 1320, section 1320.5.
These standards require the respondents to maintain all records, including reports and
notifications for at least five years. This is consistent with the General Provisions as applied to
the standards. EPA believes that the five-year records retention requirement is consistent with the
1

See Docket EPA-HQ-OECA-2014-0047 for a copy of the written comments submitted by SWANA.

6
Part 70 permit program and the five-year statute of limitations on which the permit program is
based. The retention of records for five years allows EPA to establish the compliance history of a
source, any pattern of non-compliance, and to determine the appropriate level of enforcement
action. EPA has found that the most flagrant violators have violations extending beyond the five
years. In addition, EPA would be prevented from pursuing the violators due to the destruction or
nonexistence of essential records.
3(f) Confidentiality
Any information submitted to the EPA for which a claim of confidentiality is made will
be safeguarded according to the EPA policies set forth in Title 40, chapter 1, part 2, subpart B Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976;
amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674,
March 23, 1979).
3(g) Sensitive Questions
The reporting or recordkeeping requirements in the standard do not include sensitive
questions.
4. The Respondents and the Information Requested
4(a) Respondents/NAICS Codes
The respondents to the recordkeeping and reporting requirements are municipal solid
waste landfills which correspond to the North American Industry Classification System (NAICS)
924110 for Air and Water Resources and Solid Waste Management, and NAICS 562212 for
Solid Waste Landfill. The respondents include both publically and privately owned landfills. The
breakdown of ownership is shown in the burden tables of this ICR.
4(b) Information Requested
None of these reporting or recordkeeping requirements violate any of the regulations
established by OMB at 5 CFR part 1320, section 1320.5.
(i) Data Items
In this ICR, all data recorded and/or reported are required by NSPS for Municipal Solid
Waste Landfill (40 CFR Part 60, proposed subpart XXX) and the general provisions of Part 60.
A source must make the following reports:
Reports
Initial design capacity report and amended design capacity report

Standard Citation
by Section
60.7(a)(1), 60.767(a)

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Reports
Notification of actual startup
Initial and annual (or 5-year) non-methane organic compounds
(NMOC) emission rate reports
Initial and revised collection and control system design plans
Landfill closure report
Equipment removal report
Initial performance test report and annual operations reports

Standard Citation
by Section
60.7(a)(3)
60.767(b)
60.767(c) , 60.767(h)
60.767(d)
60.767(e)
60.8, 60.767(f),
60.767(g)

A source must keep the following records:
Recordkeeping
Maintain records of maximum design capacity, refuse-in-place, yearby-year waste acceptance rate (maintain for 5 years)
Maintain records of system design and initial performance
test/compliance determination (must be kept for life of the control
equipment; records of subsequent tests must be maintained for 5 years)
Maintain records of monitoring for five years
Maintain records of plot map and well locations for the life of the
landfill (for life of the collection system)
Maintain records of collection and control system exceedances for 5
years
Maintain records of annual recalculation of site-specific density and
design capacity

60.768(a)
60.768(b)
60.768(c)
60.768(d)
60.768(e)
60.768(f)

Electronic Reporting
Currently, some of the respondents are using monitoring equipment that automatically
records parameter data. Further, data collected from wellhead and surface emission monitoring
equipment can be transferred from the equipment to a computer for additional spreadsheet
analysis. Although personnel at the affected facility must evaluate the data, internal automation
has significantly reduced the burden associated with monitoring and recordkeeping at the
facility.
Also, regulatory agencies, in cooperation with the respondents, continue to create
reporting systems to transmit data electronically. At this time, it is estimated that approximately
90 percent of the respondents will use electronic reporting for subpart XXX. Further, most of the
methods in the landfills NSPS are not supported by the EPA Electronic Reporting Tool (ERT).
Thus, electronic reporting of performance tests may not be required for some landfills initially,
but will be required when applicable methods are added to the ERT.

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For data collected using test methods supported by the ERT as listed on the EPA’s ERT
website (http://www.epa.gov/ttn/chief/ert/index.html), the owner or operator must submit the
results of the performance test to the Compliance and Emissions Data Reporting Interface
(CEDRI), accessed through the EPA’s Central Data Exchange (CDX)
(http://cdx.epa.gov/epa_home.asp), unless otherwise approved by the Administrator.
Performance test data must be submitted in a file format generated through the use of the EPA’s
ERT. NMOC emission rate reports and annual reports will be submitted using subpart specific
forms in the CEDRI.
(ii) Respondent Activities
Respondent Activities
Read instructions.
Calibrate and operate surface emission monitoring equipment for quarterly monitoring and
portable LFG emission analyzer equipment for monthly wellhead monitoring.
Estimate NMOC emission estimates using Tier 1, Tier 2, or Tier 3 procedures in the
regulation.
Perform initial performance test, Reference Method 25, 25C test, and repeat performance test
if necessary.
Write the notifications and reports listed above.
Enter information required to be recorded above.
Submit the required reports developing, acquiring, installing, and utilizing technology and
systems for the purpose of collecting, validating, and verifying.
Develop, acquire, install, and utilize technology and systems for the purpose of processing and
maintaining information.
Develop, acquire, install, and utilize technology and systems for the purpose of 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.
Transmit, or otherwise disclose the information.
Currently, sources are using monitoring equipment that provides parameter data in an
automated way (e.g., continuous parameter monitoring system). Although personnel at the
source still need to evaluate the data, this type of monitoring equipment has significantly reduced
the burden associated with monitoring and recordkeeping.
5. The Information Collected: Agency Activities, Collection Methodology, and
Information Management
5(a) Agency Activities

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EPA conducts the following activities in connection with the acquisition, analysis,
storage, and distribution of the required information.
Agency Activities
Observe initial performance tests, repeat performance tests and quarterly surface emissions
monitoring if necessary.
Review notifications and reports, including performance test reports, excess emissions reports,
required to be submitted by industry.
Audit facility records.
Input, analyze, and maintain data in Enforcement and Compliance History Online (ECHO)
and ICIS.
5(b) Collection Methodology and Management
Following notification of startup, the reviewing authority might inspect the source to
determine whether the pollution control devices are properly installed and operated. Performance
tests reports are used by the EPA to determine a source’s initial capability to comply with the
emission standard. Data and records maintained by the respondents are tabulated and published
for use in compliance and enforcement programs. The annual reports are used for problem
identification, as a check on source operation and maintenance, and for compliance
determinations.
Information contained in the reports is reported by state and local governments in the
ICIS Air database, which is operated and maintained by EPA's Office of Compliance. OTIS is
EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial
and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and
enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters.
EPA and its delegated Authorities can edit, store, retrieve and analyze the data.
As more of the methods used in the NSPS are added to the ERT, these data will also be
stored and accessible through the EPA’s Central Data Exchange (CDX)
(http://cdx.epa.gov/epa_home.asp).
The records required by this regulation must be retained in a readily accessible format by
the owner/operator for five years.
5(c) Small Entity Flexibility
Although it is unknown how many new “greenfield” landfills will be owned or operated
by small entities, recent trends in the waste industry have been towards consolidated ownership
among larger companies. Based on landfills anticipated to modify and become subject to subpart
XXX, and the ownership of recent greenfield landfills, the EPA has determined that
approximately seven of the privately owned landfills and six of the publically owned landfills are
small entities.

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Subpart XXX does not contain any provisions reserved exclusively for the benefit of
small entities. However, the proposed design capacity threshold of 2.5 million megagrams and
2.5 million cubic meters limits the effect of this regulation on smaller landfills, which tend to be
disproportionately owned by smaller entities.
5(d) Collection Schedule
The specific frequency for each information collection activity within this request is
shown in Tables 1.A through 3.B of Attachments A and B.
6. Estimating the Burden and Cost of the Collection
Tables 1.A through 3.A of Attachment A document the computation of individual
burdens for the recordkeeping and reporting requirements applicable to publically-owned MSW
landfills. Tables 1.B to 3.B present the burden on privately-owned MSW landfills.
The individual burdens are expressed under standardized headings consistent with the
concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and
major assumptions have been identified. Responses to this information collection are mandatory.
The EPA 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.
6(a) Estimating Respondent Burden
The average annual burden to industry over the next three years from these recordkeeping
and reporting requirements is estimated to be 101,031 labor hours for the proposed option 2.5/34
(Total Labor Hours from Tables 1.A through 3.B). These hours are based on EPA studies and
background documents from the development of the regulation, EPA knowledge and experience
with the NSPS program, the most recent ICR renewal for subpart WWW, and any comments
received on the ICR for the July 17, 2014 proposal for subpart XXX.
6(b) Estimating Respondent Costs
(i) Estimating Labor Costs
This ICR uses the following labor rates:
Managerial
Technical
Civil Engineer Technician
Clerical

$109.43
$ 86.46
$ 49.85
$ 30.28

($52.11 + 110%)
($41.17 + 110%)
($23.74 + 110%)
($14.42 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics,
May 2013, National Occupational Employment and Wage Estimates United States. The rates are
from column 1, “Total Compensation.” The rates have been increased by 110 percent to account

11
for the benefit packages available to those employed by private industry. For public-sector
respondents (i.e., publicly-owned or -operated landfills), it was assumed that the work performed
will be completed by private contractors.
(ii) Estimating Capital/Startup and Operation and Maintenance Costs
The types of industry costs associated with the information collection activities in the
subject standard are both labor costs, which are addressed elsewhere in this ICR, and the costs
associated with continuous monitoring at the flare station, quarterly surface monitoring, monthly
wellhead monitoring, and conducting a Tier II NMOC emission rate test. The capital/startup
costs are one-time costs when a facility becomes subject to the regulation or when the facility
first installs controls. The capital costs have been annualized over the five-year period allowed
before another Tier II test must be conducted. The capital costs for the initial performance testing
continuous monitoring equipment are annualized over a 15-year period, consistent with the
expected lifetime of the flare, and an estimated annual O&M for these equipment were also
estimated based on recent consultation with industry on the subpart WWW ICR renewal.
For landfills that must install gas collection and control systems, there are additional nonlabor costs associated with conducting an initial (and repeat, if necessary) performance test on
the flare or other destruction device, conducting quarterly surface emission monitoring (SEM),
and conducting monthly wellhead monitoring. However, the proposed rule cost analysis assumes
that the portable equipment used to complete the SEM and wellhead is rented and not purchased.
Based on industry experience, many landfills contract out monitoring services. Therefore no
capital/startup costs are estimated. The table below includes rental cost and calibration and
hydrogen fuel costs for the annual O&M of SEM equipment. For wellhead monitoring, the
comments received on the most recent ICR renewal provided a cost per month for monitoring,
but the costs did not break out labor vs. equipment costs and this ICR applies the full cost in
terms of burden hours. Therefore, the table below only shows the O&M costs associated with the
calibration gases for the wellhead monitoring device. The costs to monitor surface emissions and
wellheads are also included in the annualized cost impacts analysis for the supplemental
proposal.
The annual operation and maintenance costs are the ongoing costs to maintain, calibrate,
and operate the purchased monitoring equipment, rent monitoring equipment, and other costs
such as photocopying and postage.

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(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs
Annualized Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)
Monitoring
Device

Method 25 or
25C testing
costs for initial
performance
test
Sampling probe
and Method 25
or 25C testing
costs for Tier 2
test
Method 21
Surface
Emission
Monitor
Portable
Wellhead
Monitor
Flow Meter
Thermocouple
Data Recorder

(B)
Capital/Start
up Cost for
One
Respondent

(C)
Annualized
Capital/Startup
Cost for One
Respondent

(D)
Average
Number of
Respondents
per Year

(E)
Total
Annualize
d Capital /
Startup
Cost, (C X
D) per
Year

$10,067

$1,105

107

$118,235

$0

0

$0

$10,067

$2,455

17

$41,735

$0

0

$0

0

0

0

$0

$1,814

107

$194,642

0

0

0

$0

$204

107

$21,889

$3,000
$500
$4,500

$330

107

$35,409

$55
$494

107
107

$5,902
$53,006

$1000

107

$107,300

(F)
Annual
O&M Costs
for One
Respondent

(G)
Number of
Respondent
s with
O&M

(H)
Total
O&M,
(F X G)

The average annualized capital/startup costs for this ICR are $254,600. This is the total of
column E in the above table. The average annual O&M costs are $323,800 this is the total from
column H in the above table. The total non-labor costs are approximately $578,400.

6(c) Estimating Agency Burden and Cost
The only costs to the agency are those costs associated with analysis of the reported
information. EPA's overall compliance and enforcement program includes activities such as the
examination of records maintained by the respondents, periodic inspection of sources of
emissions, and the publication and distribution of collected information.
The average annual agency cost during the three years of the ICR is estimated to be
$177,680. In subsequent years, the agency costs will be lower because it will require less review
of initial one-time tests and reports, but as additional landfills modify and become subject to
subpart XXX the costs could grow gradually over time to account for recurring review of annual
report data. .

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This cost is based on the average hourly labor rate as follows:
Managerial
Technical
Clerical

$63.52 (GS-13, Step 5, $39.70 + 60%)
$47.14 (GS-12, Step 1, $29.46 +60%)
$25.50 (GS-6, Step 3, $15.94 + 60%)

These rates are from the Office of Personnel Management (OPM), 2015 General
Schedule, which excludes locality rate of pay. The rates have been increased by 60 percent to
account for the benefit packages available to government employees. Details upon which this
estimate is based appear in Tables 1.C through 3.C of Attachment C.
6(d) Estimating the Respondent Universe and Total Burden and Costs
Based on the regulatory database used to estimate the impacts for this proposal, , on
average over the next three years, approximately 137 existing respondents per will become
subject to the standard under the proposed option 2.5/34 based on exceeding the design capacity
threshold of at least 2.5 million Mg or cubic meters. It is estimated that on average an additional
two respondents per year will submit a one-time design capacity report over the next three years
of this ICR to demonstrate they are below the design capacity threshold.
The number of respondents is calculated using the following table, which addresses the
three years covered by this ICR.
Number of Respondents

Year

(A)
Number of
New
Respondents1

(B)
Number of
Existing
Respondents

1
2
3

138
9
0

0
138
147

(C)
Number of Existing
Respondents That
Keep Records But
Do Not Submit
Reports
0
0
0

Average

49

95

0

1

(D)
Number of Existing
Respondents That
Are Also New
Respondents

(E)
Number of
Respondents
(E=A+B+C-D)

0
0
0

138
147
147

0

144

New respondent include sources with constructed, reconstructed and modified affected facilities.

To avoid double-counting respondents, column D is subtracted. As shown above, the
average Number of Respondents over the three-year period of this ICR is 144, of which
approximately 44 are public entities and 100 are private entities.
The total number of responses over the three-year period is calculated using the following
table:
Total Responses

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(B)
Number of
Respondents

(C)
Number of
Responses
per
Respondent

Initial design capacity report

7

1

(D)
Number of
Existing
Respondents
That Keep
Records But Do
Not Submit
Reports
N/A

Amended design capacity report

0

1

N/A

0

Report of NMOC rate (Tier 1)

45

1

N/A

45

Report of NMOC rate (Tier 2)

18

1

N/A

18

Landfill Closure Report
Equipment Removal Report
Collection and Control System Design
Plan
Initial Performance Test Report
Revised design plan
Annual Report
Total Number of Annual Responses

0
0

1
1

N/A
N/A

0
0

117

1

N/A

117

117
12
322

1
1
1

N/A
N/A
N/A

117
12
322
637

(A)
Information Collection Activity

(E)
Total
Responses
E=(BxC)+D

7

The number of Total Annual Responses is 637 responses over the three-year period, or
212.4 responses per year (rounded). Many respondents submit more than one type of response
(report), depending on the year of the ICR.
The total labor costs are $18,437,299, or $6,145,766 per year. Details regarding these
estimates may be found in Tables 1.A through 3.B of Attachments A and B.
6(e) Bottom Line Burden Hours and Cost Tables
The detailed bottom line burden hours and cost calculations for the respondents and the
agency are shown in Tables 1.A through 3.B of Attachments A and B and Tables 1.C through
3.C of Attachment C and summarized below.
(i) Respondent Tally
The total annual labor hours are 303,094 over this initial three-year period, or an average
of 101,031 hours per year. Details regarding these estimates may be found in Tables 1.A through
3.B of Attachments A and B. Furthermore, the annual respondent reporting and recordkeeping
burden for this collection of information is estimated to average 476 hours per response.
The total annualized capital/startup and annual O&M costs to the regulated entity are
$1.67 million over the three-year period or an average of $578,600 per year. The cost
calculations are detailed in Section 6(b)(iii) of this supporting statement, Capital/Startup vs.
Operation and Maintenance (O&M) Costs.

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(ii) The Agency Tally
The average annual agency burden and cost over next three years for each compliance
option is estimated to be 2,790 labor hours at a cost of $177,680. See Tables 1.C through 3.C of
Attachment C.
6(f) Reasons for Change in Burden
As a result of lowering the NMOC emission rate threshold to from 40 Mg/yr to 34 Mg/yr,
and revising the estimates to account for the burden on modified landfills, the estimated number
of landfills required to install controls have increased. Thus, the burden hours, costs, and number
of responses have increased in this supplemental proposal. Further, the additional line item
burden estimates from the most recent ICR renewal (ICR Number 1557.09), which received
significant comments on burden estimates were incorporated into this ICR.
In addition, labor rates were updated for industry and EPA thus causing a change in
annual labor costs for the respondents and Agency.
6(g) Burden Statement
The annual public reporting and recordkeeping burden for this collection of information
for the proposed option 2.5/34 is estimated to average 476 hours per response. Burden means the
total time, effort, or financial resources expended by persons to generate, maintain, retain,
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 valid OMB Control Number. The OMB Control
Numbers for the EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.
To comment on the EPA'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, EPA has established a public docket for the proposed NSPS
Review for Municipal Solid Waste Landfills under Docket ID Number EPA-HQ-OAR-20030215. An electronic version of the public docket is available at http://www.regulations.gov/
which may be used to obtain a copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to access those documents
in the public docket that are available electronically. When in the system, select “search,” then
key in the docket ID number identified in this document. The documents are also available for
public viewing at the Enforcement and Compliance Docket and Information Center in the EPA
Docket Center (EPA/DC), WJC EPA West, Room 3334, 1301 Constitution Ave., NW,
Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30

16
p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading
Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1927.
Also, you can send comments to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer
for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2003-0215 and ICR
Number 2498.02 in any correspondence.
Part B of the Supporting Statement
This part is not applicable because no statistical methods were used in collecting this
information.