Burden Calculation Tables

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Overview

Table 1a
Table 1b
Table 1c
Table 2
Capital and O&M Costs

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Sheet 1: Table 1a

Table 1a: Annual Respondent Burden and Cost – NESHAP for Privately-Owned Municipal Solid Waste Landfills - (40 CFR Part 63, Subpart AAAA) (Renewal)
Burden Item	(A) Respondent Hours per Occurrence	(B) Number of Occurrences Per Respondent Per Year	(C) Technical Person-Hours per Respondent Per Year (A x B)	(D) Average Number of Respondents Per Year a	(E) Civil Engineer Technician Hours Per Year (A × C)	(F) Civil Engineer Technical Hours per Year (E × F)	(I) Management Hours per Year (H × .05)	(H) Clerical Hours per Year (H × 0.1)	(J) Total Labor Costs Per Year b
1. Applications	N/A
2. Surveys and Studies	N/A
3. Reporting Requirements											Labor
A. Familiarization with regulatory requirements c	5	1	5	748	0	3,740	187	374	$398,013.23		Category	Rates	Occupation Code
B. Required Activities											Management	$125.18	11-9198
1. Initial performance test report d	12	1	12	0	0	0	0	0	$0		Technical - Civil Engineer	$96.35	17-2051
2. Surface methane monitoring quarterly d	44	4	176	0	0	0	0	0	$0		Technical - Civil Engineering Technician	$57.14	17-3022
3. Wellhead monitoring monthly d	40	12	480	0	0	0	0	0	$0		Clerical	$38.14	43-9061
C. Create Information	Included in 3B										https://www.bls.gov/oes/current/oes_nat.htm#11-0000
D. Gather Information	Included in 3B
E. Report Preparation
1. Initial Design Capacity Report e	2	1	2	0	0	0	0	0	$0
2. Amended Design Capacity Report e	2	1	2	0	0	0	0	0	$0
3. Report of NMOC rate (Tier 1) e	8	1	8	0	0	0	0	0	$0
4. Report of NMOC rate (Tier 2) e	12	1	12	0	0	0	0	0	$0
5. Landfill Closure Report e	1	1	1	0	0	0	0	0	$0
6. Equipment Removal Report e	36	1	36	0	0	0	0	0	$0
7. Collection and Control System Design Plan e	80	1	80	0	0	0	0	0	$0
8. Revised Design Plan e	20	1	20	0	0	0	0	0	$0
9. Initial Performance Test	Included in 3B
10. Compliance Report	Included in 3B
11. Semi-Annual Report f	27	1	27	472	0	12,744	637	1,274	$1,356,224.76
12. Corrective Action Analysis g	15	1	15	0	0	0	0	0	$0
13. Implementation Timeline g	15	1	15	0	0	0	0	0	$0
14. Root Cause Analysis g	15	1	15	0	0	0	0	0	$0
15. 24-Hour High Temperature Report h	2	1	2	0	0	0	0	0	$0
16. Semi-Annual Wet Landfill Monitoring Report i	15	1	15	190	0	2,850	143	285	$303,298.85
Subtotal for Reporting Requirements					22,234				$2,057,537
4. Recordkeeping Requirements
A. Read Instructions	Included in 3A
B. Plan Activities	N/A
C. Implement Activities	N/A
D. Develop Record System	N/A
E. Record Information
1. Data Compilation and Review (controllers) j	5	12	60	0	0	0	0	0	$0
2. Recordkeeping and Data Storage (controllers) j	11	12	132	0	0	0	0	0	$0
3. Recordkeeping and Data Storage (others) j	4	1	4	0	0	0	0	0	$0
4. Records of liquids addition k	2	12	24	22	0	528	26	53	$56,190.10
E. Personnel Training	N/A
F. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					607				$56,190
Total Labor Burden and Costs (rounded) l					22,800				$2,110,000
Total Capital and O&M Cost (rounded) l									$7,080
GRAND TOTAL (rounded) l									$2,120,000
Assumptions:
a We estimate that, during the three-year period of this ICR, there will be an average of 1,169 landfills per year (748 privately-owned and 421 publicly-owned) subject to the requirements of NESHAP Subpart AAAA. Of these, an average of 737 landfills per year (471 privately-owned and 265 publicly-owned) are controlling emissions.
b This ICR uses mean hourly wage for the following labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2020, “National Occupational Employment and Wage Estimates United States” for employees at privately-owned landfills: Managers, All Other for Managerial Labor, Civil Engineers, Civil Engineer Technicians, and Office Clerks, General for Clerical Labor. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. We assume that publicly-owned landfills will be operated and managed by private contractors.
c We have assumed that it will take five hours for each respondent to read instructions as part of their reporting requirements.
d No respondents are included for the initial performance test report, quarterly surface methane monitoring, and monthly wellhead monitoring. The burden for these items is accounted for in the estimates for the corresponding burden line items under the ICRs for 40 CFR Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720). Cost of re-monitoring for exceedances of surface monitoring or wellhead monitoring are not included because the rule does not require re-monitoring unless an exceedance is found. Landfills can minimize the number of exceedances found by ensuring the GCCS is well-operated and the surface is well sealed.
e No respondents are included for the initial or amended design capacity reports, reports of NMOC rate (Tier 1 and Tier 2), landfill closure report, equipment removal report, or the initial or revised collection and control system design plan. The burden for these items is accounted for in the estimates for the corresponding burden line items under the ICRs for 40 CFR Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720).
f All controlled landfills are required to submit an annual report. Under the NESHAP rule, all controlled landfills are required to submit semiannual compliance reports. However, one annual compliance report is already required under 40 CFR Part 60, Subpart Cf, or 40 CFR Part 60, Subpart XXX. Therefore, this NESHAP rule requires only one additional report instead of two for this subpart to avoid double counting reports submitted for other subparts.
g We assume that, during the three-year period of this ICR, an average of one privately-owned landfill per year and one publicly-owned landfill per year will be required to conduct a root cause analysis, corrective action analysis, and implementation timeline. These items are not required by the rule for controlling landfills. The burden for these items is accounted for in the estimates for the corresponding burden line items under the ICRs for 40 CFR Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720).
h We assume that, during the three-year period of this ICR, no privately-owned landfills or publicly-owned landfills will be required to submit a 24-hour high temperature report. Historically, most landfills operate under the temperature threshold that would trigger this report. Landfill operators can operate their landfills so that they avoid temperatures ever getting this high.
i Landfills with a design capacity equal to or greater than 2.5 million megagrams and 2.5 million cubic meters that have employed leachate recirculation or added liquids based on a Research, Development, and Demonstration permit must file this report. We assume that, during the three-year period of this ICR, 190 privately-owned landfills and 99 publicly-owned landfills will be required to file this report. Under the NESHAP rule, these landfills are required to submit semiannual reports. However, one annual compliance report is already required under 40 CFR Part 60, Subpart Cf, or 40 CFR Part 60, Subpart XXX. Therefore, this NESHAP rule requires only one additional report instead of two for this subpart to avoid double counting reports submitted for other subparts.
j No respondents are included for these data compilation and recordkeeping tasks. The burden for these items is accounted for in the estimates for the corresponding burden line items under the ICRs for 40 CFR Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720).
k Landfills that add liquids other than leachate are required to keep records to demonstrate that their landfill has not met the 40% moisture by weight definition for the bioreactor landfill under the NESHAP. Based on RD&D permit data, we estimate 34 landfills (22 are privately owned, 12 are publicly owned) add liquids other than leachate and would maintain these records. We have assumed that each of these landfills takes 2 hours per month to maintain these records.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 1b

Table 1b: Annual Respondent Burden and Cost – NESHAP for Publicly-Owned Municipal Solid Waste Landfills - (40 CFR Part 63, Subpart AAAA) (Renewal)
Burden Item	(A) Person Hours per Occurrence	(B) Number of Occurrences Per Respondent Per Year	(C) Technical Person-Hours per Respondent Per Year (A x B)	(D) Average Number of Respondents Per Year a	(E) Civil Engineer Technician Hours Per Year (A × C)	(F) Civil Engineer Hours per Year (E × F)	(I) Management Hours per Year (H × .05)	(H) Clerical Hours per Year (H × 0.1)	(J) Total Labor Costs Per Year b						(B1) Annualized Non-Labor Capital Costs Per Occurrence	(B2) Annual Non-Labor O&M Costs Per Occurrence
1. Applications	N/A
2. Surveys and Studies	N/A
3. Reporting Requirements											Labor
A. Familiarization with regulatory requirements c	5	1	5	421	0	2,105	105	211	$224,015.47		Category	Rates	Occupation Code		$0
B. Required Activities											Management	$125.18	11-9198
1. Initial performance test report d	12	1	12	0	0	0	0	0	$0		Technical - Civil Engineer	$96.35	17-2051		$1,983.66	$1,000.00
2. Surface methane monitoring quarterly d	44	4	176	0	0	0	0	0	$0		Technical - Civil Engineering Technician	$57.14	17-3022		$703.50
3. Wellhead monitoring monthly d	40	12	480	0	0	0	0	0	$0		Clerical	$38.14	43-9061		$17.00
C. Create Information	Included in 3B										https://www.bls.gov/oes/current/oes_nat.htm#11-0000
D. Gather Information	Included in 3B
E. Report Preparation
1. Initial design capacity report e	2	1	2	0	0	0	0	0	$0
2. Amended design capacity report e	2	1	2	0	0	0	0	0	$0						$0
3. Report of NMOC rate (Tier 1) e	8	1	8	0	0	0	0	0	$0						$0
4. Report of NMOC rate (Tier 2) e	12	1	12	0	0	0	0	0	$0						$0
5. Landfill Closure Report e	1	1	1	0	0	0	0	0	$0						$2,708.28
6. Equipment Removal Report e	36	1	36	0	0	0	0	0	$0						$0
7. Collection and Control System Design Plan e	80	1	80	0	0	0	0	0	$0						$0
8. Revised design plan e	20	1	20	0	0	0	0	0	$0						$0
9. Initial Performance Test	Included in 3B														$0
10. Compliance Report	Included in 3B
11. Semi-Annual Report f	27	1	27	265	0	7,155	358	716	$761,439.75
12. Corrective Action Analysis g	15	1	15	0	1	0	0	0	$0
13. Implementation Timeline g	15	1	15	0	2	0	0	0	$0
14. Root Cause Analysis g	15	1	15	0	3	0	0	0	$0
15. 24-Hour High Temperature Report h	2	1	2	0	4	0	0	0	$0
16. Semi-Annual Wet Landfill Monitoring Report i	15	1	15	99	0	1,485	74	149	$158,034.67						$0
Subtotal for Reporting Requirements					12,367				$1,143,490
4. Recordkeeping Requirements
A. Read Instructions	Included in 3a
B. Plan Activities	N/A
C. Implement Activities	N/A
D. Develop Record System	N/A
E. Record Information
1. Data Compilation and Review (controllers) j	5	12	60	0	0	0	0	0	$0
2. Recordkeeping and Data Storage (controllers) j	11	12	132	0	0	0	0	0	$0						$0
3. Recordkeeping and Data Storage (others) j	4	1	4	0	0	0	0	0	$0						$0
4. Records of liquids addition k	2	12	24	12	0	288	14	29	$30,649.15						$0
E. Personnel Training	N/A
F. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					331				$30,649
Total Labor Burden and Costs (rounded) l					12,700				$1,170,000
Total Capital and O&M Cost (rounded) l									$3,980
GRAND TOTAL (rounded) l									$1,170,000
Assumptions:
a We estimate that, during the three-year period of this ICR, there will be an average of 1,169 landfills per year (748 privately-owned and 421 publicly-owned) subject to the requirements of NESHAP Subpart AAAA. Of these, an average of 737 landfills per year (471 privately-owned and 265 publicly-owned) are controlling emissions.
b This ICR uses mean hourly wage for the following labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2020, “National Occupational Employment and Wage Estimates United States” for employees at privately-owned landfills: Managers, All Other for Managerial Labor, Civil Engineers, Civil Engineer Technicians, and Office Clerks, General for Clerical Labor. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. We assume that publicly-owned landfills will be operated and managed by private contractors.
c We have assumed that it will take five hours for each respondent to read instructions as part of their reporting requirements.
d No respondents are included for the initial performance test report, quarterly surface methane monitoring, and monthly wellhead monitoring. The burden for these items is accounted for in the estimates for the corresponding burden line items under the ICRs for 40 CFR Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720). Cost of re-monitoring for exceedances of surface monitoring or wellhead monitoring are not included because the rule does not require re-monitoring unless an exceedance is found. Landfills can minimize the number of exceedances found by ensuring the GCCS is well-operated and the surface is well sealed.
e No respondents are included for the initial or amended design capacity reports, reports of NMOC rate (Tier 1 and Tier 2), landfill closure report, equipment removal report, or the initial or revised collection and control system design plan. The burden for these items is accounted for in the estimates for the corresponding burden line items under the ICRs for 40 CFR Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720).
f All controlled landfills are required to submit an annual report. Under the NESHAP rule, all controlled landfills are required to submit semiannual compliance reports. However, one annual compliance report is already required under 40 CFR Part 60, Subpart Cf, or 40 CFR Part 60, Subpart XXX. Therefore, this NESHAP rule requires only one additional report instead of two for this subpart to avoid double counting reports submitted for other subparts.
g We assume that, during the three-year period of this ICR, an average of one privately-owned landfill per year and one publicly-owned landfill per year will be required to conduct a root cause analysis, corrective action analysis, and implementation timeline. These items are not required by the rule for controlling landfills. The burden for these items is accounted for in the estimates for the corresponding burden line items under the ICRs for 40 CFR Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720).
h We assume that, during the three-year period of this ICR, no privately-owned landfills or publicly-owned landfills will be required to submit a 24-hour high temperature report. Historically, most landfills operate under the temperature threshold that would trigger this report. Landfill operators can operate their landfills so that they avoid temperatures ever getting this high.
i Landfills with a design capacity equal to or greater than 2.5 million megagrams and 2.5 million cubic meters that have employed leachate recirculation or added liquids based on a Research, Development, and Demonstration permit must file this report. We assume that, during the three-year period of this ICR, 190 privately-owned landfills and 99 publicly-owned landfills will be required to file this report. Under the NESHAP rule, these landfills are required to submit semiannual reports. However, one annual compliance report is already required under 40 CFR Part 60, Subpart Cf, or 40 CFR Part 60, Subpart XXX. Therefore, this NESHAP rule requires only one additional report instead of two for this subpart to avoid double counting reports submitted for other subparts.
j No respondents are included for these data compilation and recordkeeping tasks. The burden for these items is accounted for in the estimates for the corresponding burden line items under the ICRs for 40 CFR Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720).
k Landfills that add liquids other than leachate are required to keep records to demonstrate that their landfill has not met the 40% moisture by weight definition for the bioreactor landfill under the NESHAP. Based on RD&D permit data, we estimate 34 landfills (22 are privately owned, 12 are publicly owned) add liquids other than leachate and would maintain these records. We have assumed that each of these landfills takes 2 hours per month to maintain these records.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 1c

Table 1c: Summary of Annual Respondent Burden and Cost Breakdown by Affected Sector - NESHAP for Municipal Solid Waste Landfills (40 CFR Part 63, Subpart AAAA) (Renewal)
			Labor Hours			Costs
Affected Sector	Number of Respondents per Year (Average)	Number of Responses Per Year (Average)	Reporting	Record keeping	Total (Rounded)	Labor Cost (rounded)	Capital and O&M Cost (rounded)	Total Costs (Rounded)
All Respondents - Private Sector	748	657	22,234	607	22,800	$2,110,000	$7,080	$2,120,000
All Respondents - Public Sector	421	369	12,367	331	12,700	$1,170,000	$3,980	$1,170,000
All Respondents - Total	1,169	1,026	34,601	938	35,500	$3,280,000	$11,100	$3,290,000

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Sheet 4: Table 2

Table 2: Average Annual EPA Burden and Cost - NESHAP for Municipal Solid Waste Landfills (40 CFR Part 63, Subpart AAAA) (Renewal)
Burden Item	(A) EPA hours per occurrence	(B) Number of occurrences per year	(C) EPA hours per occurrence per year (C=A×B)	(D) Landfills per year a	(D) Technical hours per year (D=C)	(E) Management hours per year (E=D×0.05)	(F) Clerical hours per year (F=D×0.1)	(G) Costs, $ b
1. Familiarization with regulatory requirements (10 EPA Regions) c	4	1	4	10	40	2	4	$2,275.38		Labor Rates
2. Enter and update information into agency recordkeeping system d	2	1	2	0	0	0	0	$0		Management	$68.37
3. Required activities										Technical	$50.72
A. Observe initial performance test e	12	1	12	0	0	0	0	$0		Clerical	$27.46
B. Observe surface methane monitoring quarterly e	20	1	20	0	0	0	0	$0
C. Review operating parameters e	1	1	1	0	0	0	0	$0
D. Review continuous parameter monitoring e	1	1	1	0	0	0	0	$0
E. Review notification of performance test e	2	1	2	0	0	0	0	$0
4. Excess Emissions Enforcement Activities f	24	0.1	2.4	0	0	0	0	$0
5. Notification requirements
A. Review amended design capacity report g	2	1	2	0	0	0	0	$0
6. Reporting requirements
A. Review initial design capacity report h	1	1	1	0	0	0	0	$0
B. Review annual NMOC emission rate report h	2	1	2	0	0	0	0	$0
C. Review landfill closure report h	1	1	1	0	0	0	0	$0
D. Review equipment removal report h	1	1	1	0	0	0	0	$0
E. Review Collection and Control System Design Plan h	15	1	15	0	0	0	0	$0
F. Review Revised Collection and Control System Design Plan h	5	1	5	0	0	0	0	$0
G. Review Initial Performance Test Report i	12	1	12	0	0	0	0	$0
H. Review Semi-annual Report j	2	1	2	737	1,474	74	147	$83,847.75
I. Corrective Action Analysis k	3.75	1	3.75	0	0	0	0	$0
J. Implementation Timeline k	3.75	1	3.75	0	0	0	0	$0
K. Root Cause Analysis k	3.75	1	3.75	0	0	0	0	$0
L. 24-Hour High Temperature Report l	3.75	1	3.75	0	0	0	0	$0
M. Semi-Annual Wet Landfill Monitoring Report m	2	1	2	289	578	29	58	$32,879.24
7. Travel Expenses for Tests Attended n	3 days * ($134 hotel + $63 meals/incidentals) + ($600 round trip) = $1191 per trip							$0
TOTAL o					2,410			$119,000
Assumptions:
a We estimate that, during the three-year period of this ICR, there will be an average of 1,169 landfills per year (748 privately-owned and 421 publicly-owned) subject to the requirements of NESHAP Subpart AAAA. Of these, an average of 737 landfills per year (471 privately-owned and 265 publicly-owned) are controlling emissions.
b This ICR uses the following labor rates: $68.37 for managerial, $50.72 for technical, and $27.46 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2020 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c This ICR estimates that staff from each EPA region will familiarize themselves with the requirements of this subpart each year, to account for staff transitions.
d No respondents are included for this line item. This line item is accounted for under ICRs for 40 Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720).
e The number of occurrences is estimated to be zero. This line item is accounted for under ICRs for 40 Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720) and is not duplicated here.
f Number of occurrences is based on the assumption that of the landfills that do the initial performance test, 10% of them will have exceedances and need enforcement. No respondents are included for this line item. This line item is accounted for under ICRs for 40 Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720).
g No respondents are estimated here because the facilities have already submitted initial design capacity reports under Subparts WWW or XXX. Amended design capacity reports would be submitted as sources were modified with additional capacity and would become subject to subpart XXX. The burden for this line item is accounted for under ICRs for 40 Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697).
h No respondents are included for the initial or amended design capacity reports, reports of NMOC rate (Tier 1 and Tier 2), landfill closure report, equipment removal report, or the initial or revised collection and control system design plan. The burden for these items is accounted for in the estimates for the corresponding burden line items under the ICRs for 40 CFR Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720).
i No respondents are included for review of the initial test report. The burden for this item is accounted for in the estimates for the corresponding burden line item under the ICR for 40 CFR Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697).
j All controlled landfills are required to submit an annual report. Under the NESHAP rule, all controlled landfills are required to submit semiannual compliance reports. However, one annual compliance report is already required under 40 CFR Part 60, Subpart Cf, or 40 CFR Part 60, Subpart XXX. Therefore, this NESHAP rule requires only one additional report instead of two for this subpart to avoid double counting reports submitted for other subparts.
k We assume that, during the three-year period of this ICR, an average of one privately-owned landfill per year and one publicly-owned landfill per year will be required to conduct a root cause analysis, corrective action analysis, and implementation timeline. These items are not required by the rule for controlling landfills. The burden for these items is accounted for in the estimates for the corresponding burden line items under the ICRs for 40 CFR Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720).
l We assume that, during the three-year period of this ICR, no privately-owned landfills or publicly-owned landfills will be required to submit a 24-hour high temperature report. Historically, most landfills operate under the temperature threshold that would trigger this report. Landfill operators can operate their landfills so that they avoid temperatures ever getting this high.
m Landfills with a design capacity equal to or greater than 2.5 million megagrams and 2.5 million cubic meters that have employed leachate recirculation or added liquids based on a Research, Development, and Demonstration permit must file this report. We assume that, during the three-year period of this ICR, 190 privately-owned landfills and 99 publicly-owned landfills will be required to file this report. Under the NESHAP rule, these landfills are required to submit semiannual reports. However, one annual compliance report is already required under 40 CFR Part 60, Subpart Cf, or 40 CFR Part 60, Subpart XXX. Therefore, this NESHAP rule requires only one additional report instead of two for this subpart to avoid double counting reports submitted for other subparts.
n There are no trips estimated since this line item is accounted for under ICRs for 40 CFR Part 60, Subpart XXX (ICR 2498.03, OMB 2060-0697) and 40 CFR Part 60, Subpart Cf (ICR 2522.02, OMB 2060-0720) and therefore not duplicated here. The source for hotel and meals/incidental costs is based on FY '18 per diem rates, averaged across all locations in the United States. Airfares are estimated based on experience from other rulemakings. See: http://www.gsa.gov/portal/category/100125
o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Capital and O&M Costs

NESHAP for Municipal Solid Waste Landfills (40 CFR Part 63, Subpart AAAA) (Renewal)
Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Requirement	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C) b	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
Photocopying and postage - Private Sector	N/A	N/A	N/A	$15	472	$7,080
Photocopying and postage - Public Sector	N/A	N/A	N/A	$15	265	$3,980
Total			$0		737	$11,100
N/A - Not Applicable
Note: Totals have been rounded to three significant figures.
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	Number of Existing Respondents b, d	Number of Existing Respondents that keep records but do not submit reports b	Number of Existing Respondents That Are Also New Respondents c	Number of Respondents (E=A+B+C-D)
1	27	734	430	25	1,166
2	27	737	430	25	1,169
3	27	739	430	25	1,171
Average	27	737	430	25	1,169
Footnotes:
a New respondents include sources with constructed, reconstructed and modified affected facilities. On average 2 new greenfields per year and 25 modified landfills per year. Of these 27 sources, 16 are expected to install controls. While sources that commenced construction or modification after July 17, 2014 are subject to 40 Part 60 Subpart XXX instead of Subpart WWW, these new sources are also subject to the NESHAP (40 Part 63 Subpart AAAA).
b Sources are subject to the NESHAP because they are a major source, or co-located with a major source, or an area source based on size threshold of 2.5 million Megagrams and 50 Mg/yr NMOC, or meets the definition of a bioreactor. Not all sources subject will be subject to control requirements. All of the major sources overlapped with landfills that had exceeded the 50 Mg/yr NMOC threshold. Since the number of co-located major sources is unknown, the estimated number of sources subject was based on all landfills that met the size threshold, to be conservative and avoid underestimating burden.
c Modified landfills are both existing and new sources. These sources have been subtracted to avoid double counting of respondents.
d Number of controlling landfills was based on the estimates for landfills controlling under a 50 Mg/yr NMOC emission threshold in 2018, 2019 and 2020, and have been updated to reflect expected values for the years 2023 through 2025. The source of these estimates were the databases used for the 2016 Landfill Rulemakings. See 2016 Municipal Solid Waste New Source Performance Standards (NSPS) and Emission Guidelines (EG) Data Files. Available at: https://www.epa.gov/stationary-sources-air-pollution/2016-municipal-solid-waste-new-source-performance-standards-nsps
Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Initial performance test report	0	1	N/A	0
Surface methane monitoring quarterly	0	4	N/A	0
Wellhead monitoring monthly	0	12	N/A	0
Initial Design Capacity Report	0	1	N/A	0
Amended Design Capacity Report	0	1	N/A	0
Report of NMOC rate (Tier 1)	0	1	N/A	0
Report of NMOC rate (Tier 2)	0	1	N/A	0
Landfill Closure Report	0	1	N/A	0
Equipment Removal Report	0	1	N/A	0
Collection and Control System Design Plan	0	1	N/A	0
Revised Design Plan	0	1	N/A	0
Initial Performance Test	0	0	N/A	0
Compliance Report	0	0	N/A	0
Semi-Annual Report	737	1	N/A	737
Corrective Action Analysis	0	1	N/A	0
Implementation Timeline	0	1	N/A	0
Root Cause Analysis	0	1	N/A	0
24-Hour High Temperature Report	0	1	N/A	0
Semi-Annual Wet Landfill Monitoring Report	289	1	N/A	289
			Total	1,026
			hrs/response:	34.6