2522 02_Landfills EG ICR Supporting Statement (Final Rule)

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 2522.02, 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)) were proposed on May 30, 1991, and promulgated on
March 12, 1996. This final rule updates 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 is 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 finalized revisions to the NSPS (see
40 CFR part 60, subpart XXX, ICR Number 2498.03).
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 finalizing 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 finalized 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 finalized subpart Cf is published in the Federal Register. The final rule
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 62, subpart GGG), or
a state plan implementing subpart 40 CFR part 60 subpart Cc. This information is being collected

2
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. The
final rule is also requiring an annual wet landfill report for any landfill that recirculated leachate
or added other liquids in the last 10 years. Landfills in the closed landfill subcategory are exempt
from the wet landfill report. In addition, landfills with exceedances of wellhead operational
standards may have additional reporting and recordkeeping burden, including a root cause
analysis, corrective action analysis, and implementation timeline.
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. In addition, owners or operators are required to maintain
records of 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 finalized 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 1,192 MSW landfills (the “Affected Public”)

3
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.
Of the 1,192 MSW landfills, 53 percent (631 facilities) are owned and operated by the
local government and 47 percent (561 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 $41,177,473 in labor costs, averaged
over the first three years after the final rule is implemented.
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

4
(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
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 municipal solid waste landfill emissions 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 finalized 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 finalized 40 CFR part 60,
subpart Cf, as implemented through state plans and the landfills federal plan.
3(a) Nonduplication

5
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 finalized
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 1,851 landfills was created.
Given the numerous reporting and recordkeeping similarities between finalized 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.
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
1

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

6
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 was also provided an opportunity
to review and comment on the burden estimated in the ICR for the August 27, 2015 proposed
subpart Cf (80 FR 52100). The EPA did not receive any additional comments specific to the ICR
burden methodology used in the 2015 proposal. EPA has updated the burden associated with this
final rule ICR to reflect the latest inventory of new and modified landfills and any final changes
to the reporting and requirements of the final rule since the 2015 proposal
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.
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

7
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
Corrective Action Analysis
Implementation Timeline
Root Cause Analysis
Wet Landfill Annual Report
A source must keep the following records:

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)
60.38f(k)
60.38f(k)
60.38f(k)
60.38f(l)

8
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 and
monitoring data for 5 years
Maintain records of root cause analysis conducted, corrective action,
and implementation timeline
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)
Maintain records of any engineering calculations or company records
used to estimate quantities of leachate of liquids added

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

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.
The EPA is requiring owners and operators of existing landfills to submit electronic
copies of certain required performance test reports, NMOC emission rate reports, annual reports,
annual reports on wet landfilling practices, and Tier 4 emission rate reports through EPA’s
Central Data Exchange (CDX) (http://cdx.epa.gov/epa_home.asp) using the Compliance and
Emissions Data Reporting Interface (CEDRI). Electronic copies of records may also be
maintained in order to satisfy federal recordkeeping requirements.

9
(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, Tier 3, or Tier 4 procedures in the
regulation.
Perform initial performance test, Reference Method 25, 25A, or 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.

10
Agency Activities
Review notifications and reports, including performance test reports, excess emissions reports,
root cause and corrective action analysis, implementation timeline, and wet landfill monitoring
report 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.
Certain 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 39 of the privately-owned existing landfills
and 24 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 finalized subpart 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

11
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. Landfills in the closed landfill
subcategory are also exempt from the annual wet landfill report. Second, while the standard
continues to require monthly monitoring of wellhead parameters, the EPA has removed the
wellhead operating standards for oxygen/nitrogen, which will reduce the corrective actions, remonitoring, and requests for alternative timelines. Third, the rule has provided a non-numeric
definition of treatment, which is expected to provide some flexibility for landfills with LFG
energy recovery. Since treatment is one of the three compliance pathways for controlling LFG,
this ICR does not estimate the number of landfills that may opt to use the treatment pathway for
compliance. Finally, the landfill has included alternative site-specific emission thresholds for
determining when a landfill must install (Tier 4) controls, which is expected to provide flexibility
for landfill owners/operators required to control under subpart Cf. The ICR burden was estimated
assuming 50% of landfills use Tier 1 and 50% use Tier 2 as it is unknown how many landfills
would opt to use Tier 4.
Subpart Cf does not contain any provisions reserved exclusively for the benefit of small
entities. However, the 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
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 679,668 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

12
guideline 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 and the August 27, 2015 proposal for
subpart Cf.
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
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 final rule 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 final 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

13
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 final rule.
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
Method 25,
25A or 25C
testing costs for
initial
performance
test
Sampling probe
and Method 25,
25A, 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/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)

$10,067

$1,105

580

$640,900

$0

0

$0

$10,067

$2,455

83

$203,765

$0

0

$0

0

0

0

$0

$2,816

666

$1,874,51
7

0

0

0

$0

$204

666

$135,796

$3,000
$500
$4,500

$330

580

$191,400

$55
$494

580
580

$31,900
$286,520

$1000

666

$665,667

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 $2.7 million. The total
non-labor costs are $4 million per year.
6(c) Estimating Agency Burden and Cost

14
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
$1,161,840. 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

$64.16 (GS-13, Step 5, $40.10 + 60%)
$47.62 (GS-12, Step 1, $29.76 +60%)
$25.76 (GS-6, Step 3, $16.10 + 60%)

These rates are from the Office of Personnel Management (OPM), 2016 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 final rule, the
number of respondents is 1,192 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

Initial design capacity report

178

1

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

Amended design capacity report

72

1

N/A

72

Report of NMOC rate (Tier 1)

285

1

N/A

285

Report of NMOC rate (Tier 2)

114

1

N/A

114

Landfill Closure Report

60

1

N/A

60

Equipment Removal Report

0

1

N/A

0

(A)
Information Collection Activity

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

178

15
Total Responses

(A)
Information Collection Activity

Collection and Control System Design
Plan
Initial Performance Test Report
Revised design plan
Annual Report
Corrective Action Analysis
Implementation Timeline
Root Cause Analysis
Wet Landfill Monitoring Report
Total Number of Annual Responses

(B)
Number of
Respondents

(C)
Number of
Responses
per
Respondent

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

649

1

N/A

649

649
64
1,997
6
6
6
771

1
1
1
1
1
1
1

N/A
N/A
N/A
N/A
N/A
N/A
N/A

649
64
1,997
6
6
6
771
4,857

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

The number of Total Annual Responses is 4,857 responses over the three-year period, or
1,619 responses per year (rounded).
The total labor costs are $123.5 million or $41.2 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 2,039,003 over this initial three-year period, or an
average of 679,688 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 420 hours per response.
The total annual capital/startup and O&M costs to the regulated entity are $12,143,667
over the three-year period or an average of $4,047,889 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
17,829 labor hours at a cost of $1,. See Tables 1.C through 3.C of Attachment C.

16

6(f) Reasons for Change in Burden
The number of respondents increased in this final rule as compared to the estimates in the
proposal due to changes to the inventory of existing landfills. In addition, the rule now requires
additional reports since the 2015 proposal, including a corrective action analysis, implementation
timeline, root cause analysis, and wet landfill monitoring report. Thus, the burden hours, costs,
and number of responses have increased in this final rule. Labor rates were also updated for EPA
thus causing a change in annual labor costs for the respondents and Agency.
6(g) Burden Statement
The annual reporting and recordkeeping burden for this collection of information is
estimated to average 420 hours per response. Burden means the total time, effort, or financial
resources expended by persons to generate, maintain, retain, or disclose or provide information
to or for a Federal agency. This includes the time needed to review instructions; develop,
acquire, install, and utilize technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and disclosing and providing
information; adjust the existing ways to comply with any previously applicable instructions and
requirements; train personnel to be able to respond to a collection of information; search data
sources; complete and review the collection of information; and transmit or otherwise disclose
the information.
An agency may not conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a 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 ICR Number 2522.02 in any correspondence.
correspondence.

17
Part B of the Supporting Statement
This part is not applicable because no statistical methods were used in collecting this
information.