SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Municipal Solid Waste Landfills (40 CFR Part 63, Subpart AAAA) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Municipal Solid Waste Landfills (40 CFR Part 63, Subpart AAAA) (Renewal), 

EPA ICR Number 1938.06, OMB Control Number 2060-0505.

1(b) Short Characterization/Abstract

The NESHAP for the regulations published at 40 CFR Part 63, Subpart AAAA were 

proposed on November 7, 2000, promulgated on January 16, 2003, and most recently amended 

April 20, 2006. These regulations apply to existing and new municipal solid waste (MSW)

landfills that have accepted waste since November 8, 1987 or have additional capacity for waste 

deposition, including those that operate as bioreactors, and the landfill either: 1) is a major 

source or is collocated with a major source; or 2) is an area source with a design capacity of 2.5 

million megagrams (Mg) and 2.5 million cubic meters (m3), and emits equal to or greater than 

50 tons per year of non-methane organic compounds (NMOC). New facilities include those that 

commenced construction or reconstruction after the date of proposal. This information is being 

collected to assure compliance with 40 CFR Part 63, Subpart AAAA.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also 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. These notifications, reports, and records are essential in determining compliance,

and are required of all affected facilities subject to the NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements,

maintenance reports, and records. All reports are sent to the delegated state or local authority. In 

the event that there is no such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) regional office.

The term “Affected Public” applies to owners and operators of MSW landfills and may

be found in Table 1: Annual Respondent Burden and Cost – NESHAP for Municipal Solid 

Waste Landfills (40 CFR Part 63, Subpart AAAA) (Renewal). None of the facilities are owned 

by state, local, tribal, or the Federal government. All are owned and operated by privatelyowned, for-profit businesses. The burden to the “Federal Government” is attributed entirely to 

work performed by federal employees or government contractors, and may be found in Table 2: 

Average Annual EPA Burden and Cost – NESHAP for Municipal Solid Waste Landfills (40 

CFR Part 63, Subpart AAAA) (Renewal).
2

Based on our consultations with industry representatives, there is an average of one 

affected facility at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, approximately 1,126 respondents per year will be subject to the 

standard, and 1 additional respondent per year will become subject to the standard. The estimate 

is based on the industry growth rate obtained from a previous renewal. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance.”

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, Section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, hazardous air pollutant (HAP) emissions from MSW 

landfills cause or contribute to air pollution that may reasonably be anticipated to endanger 

public health or welfare. Therefore, the NESHAP was promulgated for this source category at 

40 CFR Part 63, Subpart AAAA.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensures compliance with 

the applicable regulations which were promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.
3

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 is used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, that leaks are being detected and repaired, and that the standard is being 

met. The performance test may also be observed.

The required semiannual 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 40 CFR Part 63, Subpart 

AAAA.

3(a) Nonduplication

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

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities.
4

Industry trade associations and other interested parties were provided with an opportunity

to comment on the burden associated with the standard when it was being developed and further 

amended, and the standard has been previously reviewed to determine the minimum information 

needed for compliance purposes. For the current renewal, EPA contacted both the Solid Waste 

Association of North America (SWANA) at (240) 494-2241 and the Waste Business Journal at 

(619) 793-5190.

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 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

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 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 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 Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, 

Subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested
5

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners and 

operators of MSW landfills. The United States Standard Industrial Classification (SIC) codes 

and corresponding North American Industry Classification System (NAICS) codes for 

respondents affected by the standard are listed in the following table.

Standard (40 CFR Part 63, Subpart AAAA) SIC Codes NAICS Codes

Administration of Air and Water Resource and Solid Waste 

Management Programs

9511 924110

Refuse Systems (Solid Waste Landfill) 4953 562212

 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Municipal Solid Waste Landfills (40 CFR Part 63, Subpart AAAA).

A source must make the following notifications:

Notifications

Notification of startup, shutdown, and malfunction plan 63.5(b), 63.1980(b)

Notification of startup, shutdown, and malfunction plan reports 63.6(e), 63.1980(b)

A source must make the following reports:

Reports

Semiannual report of deviation 63.105(d)(5), 

63.1965

Semiannual report of compliance 63.1980(c)-(f)

A source must keep the following records:

Recordkeeping

Record of startup, shutdown, and malfunction 63.10(d)(1)
6

Recordkeeping

Records of SSM plan and SSM reports 63.1980(b)

Records of percent moisture in waste calculation, where applicable 63.1980(g)-(h)

Records are required to be retained for five years 63.10(b)(2)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site.

(ii) Respondent Activities

Respondent Activities

Familiarization with regulatory requirements.

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 information.

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.

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities
7

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in ICIS and Enforcement and Compliance History Online 

(ECHO). 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standard, and note the operating conditions under which compliance was 

achieved. Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs. The semiannual 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. ICIS 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.

The records required by this regulation must be retained by the owner/operator for five 

years.

5(c) Small Entity Flexibility

The majority of respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 
8

the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Municipal Solid 

Waste Landfills (40 CFR Part 63, Subpart AAAA) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency 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 20,900 (Total Labor Hours from Table 1). These 

hours are based on Agency studies and background documents from the development of the 

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The types of industry costs associated with the information collection activities in the 
9

subject standard are both labor costs, which are addressed elsewhere in this ICR, and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance (O&M) costs 

are the ongoing costs to maintain monitor(s) and other costs such as photocopying and postage.

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

None N/A N/A N/A $15 1,127 $16,905

Total

(rounded)

$16,900

N/A – Not Applicable

Note: Totals have been rounded to three significant figures.

There are no total capital/startup costs for this ICR, as shown in column D in the above 

table.

The total operation and maintenance (O&M) costs for this ICR are $16,900. This is the 

total of column G. 

The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $16,900. These are 

recordkeeping costs. 

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be 

$873,000. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)
10

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for 

Municipal Solid Waste Landfills (40 CFR Part 63, Subpart AAAA) (Renewal).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately

1,126 existing respondents will be subject to the standard. It is estimated that one additional

respondent per year will become subject. The overall average number of respondents, as shown 

in the table below, is 1,127 per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 1 1,125 0 0 1,126

2 1 1,126 0 0 1,127

3 1 1,127 0 0 1,128

Average 1 1,126 0 0 1,127

1

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

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 1,127. 

The total number of annual responses per year is calculated using the following table:

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

(C)

Number of 

(D)

Number of Existing 

Respondents That 

(E)

Total Annual Responses

E=(BxC)+D
11

Total Annual Responses

Respondents Responses Keep Records But Do 

Not Submit Reports

Semiannual compliance report 11,127 1 0 1,127

Semiannual SSM report 1,127 2 0 2,254

Total 3,381

1

Semiannual compliance reports are required under this NESHAP. However, an annual compliance report is 

already required under 40 CFR Part 60, Subpart CC or WWW. Therefore, semiannual compliance reporting 

under this NESHAP will pose a burden for only one additional report.

The number of Total Annual Responses is 3,381.

The total annual labor costs are $2,100,000. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Municipal Solid 

Waste Landfills (40 CFR Part 63, Subpart AAAA) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2 below, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 20,900. Details regarding these estimates may be found 

in Table 1: Annual Respondent Burden and Cost – NESHAP for Municipal Solid Waste 

Landfills (40 CFR Part 63, Subpart AAAA) (Renewal). 

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 6 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $16,900. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over the next three years is estimated to be 

19,200 labor hours at a cost of $873,000. See Table 2: Average Annual EPA Burden and Cost –
12

NESHAP for Municipal Solid Waste Landfills (40 CFR Part 63, Subpart AAAA) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an increase in the total estimated burden as currently identified in the OMB 

Inventory of Approved Burdens. This increase is due to an increase in the number of new 

sources due to industry growth; it is not due to any program changes. In addition, we have 

adjusted the respondent burden calculation to assume all respondents will re-familiarize 

themselves with the regulatory requirements each year. 

There is also an increase in the total O&M cost associated with this ICR. Similar to the 

total estimated burden, EPA has adjusted the total O&M cost to account for industry growth that 

has occurred since the previous ICR.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 6 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-OECA-2014-0075. 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 
13

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-OECA-2014-0075 and OMB Control Number 2060-0505 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
14

Table 1: Annual Respondent Burden and Cost – NESHAP for Municipal Solid Waste Landfills (40 CFR Part 63, Subpart 

AAAA) (Renewal)

Burden item

(A)

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person 

hours per 

year

(Ex0.1)

(H)

Total Cost Per 

year b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Familiarize with rule requirement c

New Sources 10 1 10 1 10 0.5 1 $1,156.46 

Existing Sources 2 1 2 1,126 2,252 112.6 225.2 $260,433.67 

B. Required activities

 Prepare SSM plan d40 1 40 1 40 2 4 $4,625.82 

C. Notification requirements

 Deviation of SSM plan e1 2 2 56 112 5.6 11.2 $12,952.30 

D. Write Report

 Semiannual compliance reports f, g 2 1 2 1,127 2,254 112.7 225.4 $260,664.96 

 Semiannual SSM reports h6 2 12 1,127 13,524 676.2 1352.4 $1,563,989.7

4 

Subtotal for Reporting Requirements 20,921 $2,103,822.9

4 

4. Recordkeeping requirements N/A

Subtotal for Recordkeeping Requirements 0 $0 

TOTAL LABOR BURDEN AND COST 

(rounded) 20,900 $2,100,000 

Capital and O&M Cost $16,900

Grand Total (rounded) $2,120,000 
15

Note: Totals have been rounded to three significant figures. Figures may not add exactly due to rounding.

Assumptions:

a

 We have assumed that there are approximately 1,127 existing sources currently subject to this rule. There will be one additional new source that will become 

subject to the rule each year over the three-year period of this ICR.

b

 This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 “Table 2. Civilian Workers, by 

Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit 

packages available to those employed by private industry.

c

 We have assumed that it will take 10 hours for a new respondent to read and understand regulatory requirements. 

d

 It will take the respondent 40 hours to prepare the SSM plan.

e

 We have assumed that 5 percent of respondents will deviate from the SSM plan.

f

 We have assumed that it will take 2 hours for each respondent to complete the semiannual report.

g

 Under the NESHAP rule, semiannual compliance reports are required, however, since one annual compliance report is already required under 40 CFR part 60, 

subpart CC or WWW, this rule requires that we decrease the annual burden by one report instead of two for this subpart.

h We have assumed that it will take 6 hours for respondents to complete the SSM reports.
16

Table 2: Average Annual EPA Burden and Cost – NESHAP for Municipal Solid Waste Landfills (40 CFR Part 63, Subpart 

AAAA) (Renewal)

Activity

(A) 

EPA 

personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

personhours per 

plant per 

year

(C=AxB)

(D) 

Plants 

per year 

a

(E) 

Technical 

personhours per 

year

(E=CxD)

(F) 

Management 

personhours per 

year

(Ex0.05)

(G) 

Clerical 

personhours per 

year

(Ex0.1)

(H) 

Cost, $ b

1. Familiarize with rule requirement 8 1 8 50 400 20 40 $20,936.00 

2. Enter and update information c4 1 4 1 4 0.2 0.4 $209.36 

3. Required activities for sources with 

add-on control devices

 a. Review operating parameters See 6

 b. Review continuous parameter 

monitoring See 6

4. Excess emissions report reviews d, e

5. Review of SSM notification of 

deviation e, f 8 1.13 9.0 50 452 22.6 45.2 $23,657.68 

6. Reporting requirements 1 1.13 1.13 50 56.5 2.825 5.65 $2,957.21 

 a. Review compliance reports g6 22.5 135 50 6,750 337.5 675 $353,295.00 

 b. Review SSM plan h8 1 8 1 8 0.4 0.8 $418.72 

 c. Review semiannual SSM reports i4 45 180 50 9,000 450 900 $471,060.00 

TOTAL ANNUAL BURDEN AND 

COST (Rounded) 19,200 $873,000 

Note: Totals have been rounded to three significant figures. Figures may not add exactly due to rounding.

Assumptions:

a

 We have assumed that there are approximately 1,127 existing sources currently subject to this rule. There will be one additional new source that will become 

subject to the rule each year over the three-year period of this ICR.

b

 This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 for 

Managerial, $46.67 for Technical, and $25.24 Clerical. These rates are from the Office of Personnel Management (OPM) “2014 General Schedule” which excludes 

locality rates of pay.
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c

 We have assumed that one respondent will take 4 hours to enter and update information into agency system. 

d

 We have assumed that it will take each of the 50 states 8 hours to conduct an excess emission enforcement activity.

e We have assumed that the average occurrences per agency or state (1.13) is derived from the number of landfills (1,127) subject to the requirements, divided by the 

number of states (50) and multiplied by the percentage of sources that are assumed to have excess emissions (0.05). There are no enforcement related activities in 

ICRs.

f

 We have assumed that each of the 50 states will take 1 hour to review the SSM notification.

g

 We have assumed that the average occurrences per agency or state (22.5) is derived from the number of landfills (1,127) subject to the requirements, divided by the 

number of states (50) that must conduct this activity.

h

 We have assumed that the one new source will take 8 hours to review the SSM plan. 

i We have assumed that each of the 50 states will take 4 hours twice per year to review the SSM reports. We have assumed that the average occurrences per agency 

or state (45) is derived from the number of landfills (1,127) divided by the number of states (50), then multiplied by two (2).