EPA-HQ-OAR-2014-0451-0134 - proposed rule ss

SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
1. Identification of the Information Collection
1(a) Title of the Information Collection
Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills (40
CFR part 60, subpart Cf), EPA ICR Number 2522.01, OMB Control Number 2060- NEW.
1(b) Short Characterization/Abstract
The Emission Guidelines and Compliance Times for Existing Municipal Solid Waste
Landfills (40 CFR part 60, subpart Cc) and the New Source Performance standards (NSPS) (40
CFR part 60, subpart WWW) were proposed on May 30, 1991, and promulgated on March 12,
1996. This proposal will update the emission guidelines in a new subpart Cf and will apply to
existing municipal solid waste (MSW) landfills that accepted waste since November 8, 1987 and
commenced construction, reconstruction, or modification on or before July 17, 2014. Once
implementation of these revised emission guidelines are finalized, the burden associated with 40
CFR part 60, subpart Cf will replace the ICR burden estimates for (40 CFR part 60, subpart Cc,
ICR Number 1893.06) and (40 CFR part 60, subpart WWW, ICR Number 1557.09). MSW
landfills that were constructed after July 17, 2014 or that were modified (had changes in design
capacities) after July 17, 2014 are subject to EPA’s proposed revisions to the NSPS (see 40 CFR
part 60, subpart XXX, ICR Number 2498.02).
The EPA is not statutorily obligated to review the emission guidelines, but has the
discretionary authority to do so when circumstances indicate that this is appropriate. Based on
changes in the landfills industry and changes in size, ownership, and age of landfills since the
emission guidelines were promulgated in 1996, the EPA has concluded that it is appropriate to
review the landfills emission guidelines. EPA is proposing a new subpart (40 CFR part 60
subpart Cf), that will apply to municipal solid waste landfills that have accepted waste since
November 8, 1987 and were constructed, modified, or reconstructed on or before July 17, 2014.
All MSW landfills that are subject to the original NSPS (40 CFR part 60, subpart WWW), the
federal plan (40 CFR part 62 subpart GGG), or a state plan implementing the original emission
guidelines (40 CFR part 60, subpart Cc) would continue to comply with their current
requirements unless and until they are covered by a more stringent state or federal plan
implementing the emission guidelines in this new subpart Cf.
This proposed subpart contains a revision to reduce the NMOC emission rate threshold
from the current level of 50 megagrams per year (Mg/yr) to 34 Mg/yr for landfills that are not
closed as of the date the proposed subpart Cf is published in the Federal Register. The proposed
option retains the design capacity cutoff of 2.5 million Mg and 2.5 million cubic meters in the
current emission guidelines. Closed landfills will retain the same NMOC threshold of 50 Mg/yr,
which is the level currently promulgated under subpart WWW. Closed landfills will also be
exempted from the one time reporting requirements, provided the landfill fulfilled these
requirements under the NSPS (40 CFR part 60, subpart WWW), the federal plan (40 CFR part

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62, subpart GGG), or a state plan implementing subpart 40 CFR part 60 subpart Cc. This
information is being collected to assure compliance with 40 CFR part 60, subpart Cf.
In general, existing MSW landfills 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 established ranges, and any period when the collection system or air pollution control
equipment is not operating, or when the collected gas was diverted from the control device.
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. In addition, owners or operators are required to maintain
records of the annual compliance reports, including the occurrence and duration of any startup,
shutdown, or malfunction in the operation of an affected facility, or any period during which the
monitoring system is inoperative. The recordkeeping and reporting requirements specific to
municipal solid waste landfills are detailed in Section 4(b) of this supporting statement. The
notifications, reports, and records are essential in determining compliance, and are required of all
MSW landfills subject to the emission guidelines. Any owner or operator subject to the
provisions of proposed subpart Cf 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.
The landfills emission guidelines under subpart Cf are implemented through either state
plans or a federal plan that EPA will develop for landfills located in states and Indian country
that did not develop a state or tribal plan. States directly implement and enforce their state plan.
EPA implements and enforces the federal plan.
All reports are sent to the state or local authority implementing the state plan. In the event
that there is no state plan, 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 plant site).
Over the next three years, approximately 988 MSW landfills (the “Affected Public”) will
be subject to the emission guidelines. No additional sources will become subject to this
regulation. It is not possible for an additional facility to qualify as an existing source, since it
would have to be operational and exceed the design capacity requirements on or before July 17,
2014.

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Of the 988 MSW landfills, 65 percent (645 facilities) are owned and operated by the local
government and 35 percent (343 facilities) are privately-owned, for-profit businesses.
The burden to the “Affected Public” may be found in Tables A1 through B3 in
Attachment A. The cost of this ICR to MSW landfills is $37,828,043 in labor costs, averaged
over the first three years after the proposal is final.

2. Need for and Use of the Collection
2(a) Need/Authority for the Collection
The EPA is charged under section 111(d)(1) of the Clean Air Act (CAA), as amended, to:
. . . prescribe regulations which shall establish a procedure similar
to that provided by section 110 under which each State shall
submit to the Administrator a plan which (A) establishes standards
of performance for any existing source for any air pollutant (i) for
which air quality criteria have not been issued or which is not
included on a list published under section 108(a) . . . but (ii) to
which a standard of performance under this section would apply if
such existing source were a new source, and (B) provides for the
implementation and enforcement of such standards of
performance.

Subpart B of 40 CFR part 60 requires state plans to include monitoring, recordkeeping,
and reporting provisions consistent with the emission guidelines. In addition, CAA section
114(a)(1) states that:
…the Administrator may require any person who owns or operates
any emission source, who manufactures emission control
equipment or process equipment, who the Administrator believes
may have information necessary for the purposes set forth in this
subsection, or who is subject to any requirement of this Act (other
than a manufacturer subject to the provisions of section 206(c) or
208 with respect to a provision of title II) on a one-time, periodic
or continuous basis 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 Administer shall
prescribe); (E) keep records on control equipment

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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 emission guidelines were promulgated for this source
category at 40 CFR part 60, subpart Cc, and a federal plan was promulgated at 40 CFR part 62,
subpart GGG and a review of these emission guidelines is being proposed under new subpart 40
CFR part 60, subpart Cf.
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.
The notifications required in the standard are used to inform the EPA or delegated
authority of existing sources 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. Nonduplication, Consultations, and Other Collection Criteria
The requested recordkeeping and reporting are required under proposed 40 CFR part 60,
subpart Cf, as implemented through state plans and the landfills federal plan.
3(a) Nonduplication

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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 proposed
rulemaking published for the Emission Guidelines and Compliance Times 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). These data were 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. New and modified sources were subtracted from the
database of affected sources because they would become subject to subpart XXX upon
modification instead of the state and federal plans implementing the emission guidelines. Based
on these data sources, a dataset of approximately 1,839 landfills was created.
Given the numerous reporting and recordkeeping similarities between proposed subpart
Cf, and the currently promulgated Emissions Guidelines subpart Cc and NSPS subpart WWW,
many of the line item burden estimates in this ICR estimate are the same as the burdens for the
most recent ICR renewal, ICR number 1557.09 for subpart WWW. 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 Cf as well as some of burden line item
estimates in subpart Cf 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.

1

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

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The public was provided the opportunity to review and comment on the burden estimated
in the ICR for the July 17, 2014 proposed subpart XXX (79 FR 41796). The EPA received
comments that it did not account for the burden on MSW landfills that would become modified
and thus become affected by subpart XXX. As a result of these comments, EPA has moved the
impact on modified landfills out of the existing landfill impacts analysis and burden statement
and incorporated these modified landfills into the impacts and burden statement for new and
modified MSW landfills in the subpart XXX 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
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

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The reporting or recordkeeping requirements in the standard do not include sensitive
questions.
4. The Respondents and the Information Requested
4(a) Respondents/NAICS Code
The respondents for recordkeeping and reporting requirements are the owners/operators
of MSW landfills that are subject to the emission guidelines. The North American Industry
Classification System (NAICS) code is 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, Including Recordkeeping Requirements
All data in this ICR that are recorded and/or reported are required by the emission
guidelines reporting and recordkeeping requirements for existing municipal solid waste landfills,
40 CFR part 60, subpart Cf.
A source must make the following reports:
Reports
Initial and amended design capacity report
Initial and annual (or 5-year) non-methane organic compounds
(NMOC) emission rate reports (or Tier 4 surface emissions report)
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
60.33f(d), 60.38f(a),
60.38f(b)
60.33f(e), 60.38f(c)
60.38f(d), 60.38f(e)
60.38f(f)
60.38f(g)
60.8, 60.38f(h),
60.38f(i)

A source must keep the following records:
Recordkeeping
Maintain records of maximum design capacity, refuse-in-place, year-

60.39f(a),

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Recordkeeping
by-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 and
monitoring data for 5 years
Maintain records of annual recalculation of site-specific density and
design capacity
Maintain records of all surface emissions monitoring for 5 years (for
landfills opting to use the Tier 4 approach)

60.39f(b)
60.39f(c)
60.39f(d)
60.39f(e), 60.39f(h)
60.39f(f)
60.39f(g)

Electronic Reporting
Currently, some of the respondents are using monitoring equipment that automatically
records parameter data. 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 Cf. Further, most of the
methods in the landfills emission guidelines 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.
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.

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Respondent Activities
Estimate NMOC emission estimates using Tier 1, Tier 2, Tier 3, or Tier 4 procedures in the
regulation.
Perform initial performance test, Reference Method 25, 25A, and 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
For landfills covered by the federal plan, EPA is the implementing agency. 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.

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Agency Activities
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
The EPA has determined that approximately 46 of the privately-owned existing landfills
and 52 of the publically-owned existing landfills subject to similar regulations (40 CFR Part 60
subparts WWW and Cc or the corresponding state or federal plan) are small entities based on the
ownership profiles of landfills in its regulatory database.
Subpart Cf does not contain any provisions reserved exclusively for the benefit of small
entities. However, there are several compliance flexibilities that will benefit all landfills,
including small entities. First, the proposal includes a separate subcategory for closed landfills.
This subcategory retains an emission threshold of 50 Mg/yr, which is currently promulgated in
similar regulations. Landfills in this category are also exempt from many of the one-time
reporting requirements, provided those reports were submitted under 40 CFR part 60, subparts
WWW and Cc or the corresponding state or federal plan. Second, while the standard continues to
require monthly monitoring of wellhead parameters, the EPA has proposed to remove the
wellhead operating standards for temperature and oxygen/nitrogen, which will reduce the
corrective actions, re-monitoring, and requests for alternative timelines. Third, the rule has

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provided a proposed non-numeric definition of treatment, which is expected to provide some
flexibility for landfills with LFG energy recovery. Finally, the landfill has included alternative
site-specific emission thresholds for determining when a landfill must install (Tier 4) or remove
controls, which are expected to provide flexibility for landfill owners/operators required to
control under subpart Cf.
In addition to these compliance flexibilities, EPA also notes that it has retained the same
size based criteria, 2.5 million Mg and 2.5 million cubic meters design capacity as the regulatory
cutoff for annual reporting. Small landfills will be required to submit only a one-time design
capacity report. In choosing 2.5 million Mg and 2.5 million cubic meters design capacity as the
regulatory cutoff for annual reporting, EPA exempted landfills that are very unlikely to emit 50
Mg or more of NMOC per year (see 61 FR 9918, March 12, 1996).
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
landfills for the subpart included in this ICR. Tables 1.B to 3.B presents the burden on privatelyowned 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 621,947 labor hours (Total Labor Hours from
Tables 1.A through 3.B). These hours are based on Agency studies and background documents
from the development of the regulation, Agency knowledge and experience with the emission
guideline program, the most recent ICR renewal for subpart WWW, and any comments received
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:

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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
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 and Operation and Maintenance (O&M) 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. While this proposal allows landfills to conduct
Tier 3 or Tier 4, industry experience suggest that no landfills are using the Tier 3 approach and it
is unknown how many landfills would use the Tier 4 alternative. The capital costs for the initial
performance testing and 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.

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

(B)
Capital/Start
up Cost for
One
Respondent

(C)
Annualized
Capital/Start
up Cost for
One
Respondent

(D)
Average
Number of
Respondents
per Year

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

(F)
Annual
O&M Costs
for One
Respondent

(G)
Number of
Respondent
s with
O&M

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

Method 25 or
25C testing
costs for initial
performance
test

$10,067

$1,105

572

$632,060

$0

0

$0

$10,067

$2,455

109

$267,595

$0

0

$0

0

0

0

$0

$1,814

645

$1,169,30
4

0

0

0

$0

$204

645

$131,498

$3,000
$500
$4,500

$330

572

$188,760

$55
$494

107
572

$5,902
$31,460

$1000

645

$644,600

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

The average annualized capital/startup costs for this ICR are $1.4 million. This is the total
of column E in the above table. The annual O&M costs for this ICR are $1.9 million. The total
non-labor costs are $3.3 million.

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.

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The average annual agency cost during the three years of the ICR is estimated to be
$1,029,658. In subsequent years, the agency costs will be lower because it will require less
review of initial tests and reports.
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, the
number of respondents is 988 landfill owners/operators per year. The number of respondents
does not vary by year.

The total number of responses over the three-year period is calculated using the following
table:
Total Responses

(B)
Number of
Respondents

(C)
Number of
Responses
per
Respondent

203

1

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

Amended design capacity report

80

1

N/A

80

Report of NMOC rate (Tier 1)

277

1

N/A

277

Report of NMOC rate (Tier 2)

109

1

N/A

109

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

69
0

1
1

N/A
N/A

69
0

635

1

N/A

635

635
63
1,934

1
1
1

N/A
N/A
N/A

635
63
1,934
4,004

(A)
Information Collection Activity

Initial design capacity report

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

203

15
The number of Total Annual Responses is 4,004 responses over the three-year period, or
1,335 responses per year (rounded).
The total labor costs are $113.5 million or $37.8 million 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 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 541,536 over this initial three-year period, or an average
of 180,512 hours per year. Details regarding these estimates may be found in Tables A1 through
B3 of Attachment A. Furthermore, the annual public reporting and recordkeeping burden for this
collection of information is estimated to average 466hours per response.
The total annual capital/startup and O&M costs to the regulated entity are $9,822,654over
the three-year period or an average of $3,274,218 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.
(ii) The Agency Tally
The average annual agency burden and cost over next three years for is estimated to be
16,054 labor hours at a cost of $1,029,658. See Tables 1.C through 3.C of Attachment C.

6(f) Reasons for Change in Burden
There is no change in the labor hours or cost in this ICR because it is for the proposed
new subpart Cf for the Emission Guidelines and Compliance Times for Municipal Solid Waste
Landfills and is considered new burden.
6(g) Burden Statement
The annual reporting and recordkeeping burden for this collection of information is
estimated to average 466 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

16
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 EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.
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, EPA has established a public docket for this ICR under
Docket ID Number EPA-HQ-OAR-2014-0451. 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), 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 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-2014-0451 and OMB Control Number 2060-NEW in any
correspondence.
Part B of the Supporting Statement
This part is not applicable because no statistical methods were used in collecting this
information.