**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS for**  **Municipal Solid Waste Landfills (40 CFR Part 6**  **0 , Subpart**  **WWW ) (Renewal)**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  NSPS for Municipal Solid Waste L andfills (40 CFR Part 60, Subpart WWW) (Renewal) , EPA ICR Number 1557.09 , OMB Control Number 2060

- 0220

. **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS) for Municipal Solid Waste (MSW) Landfil ls were proposed on May 30, 1991, promulgated on May 12, 1996, and amended on June 16, 1998 (63 FR 32753), February 24, 1999 (64 FR 9262), and April 10, 2000 (65 FR 18909)

. These regulations apply to MSW landfills for which construction, modification, or reconstruction commences on or after May 30, 1991. A MSW landfill is an entire disposal facility in a contiguous geographical space where household waste is placed in or on. An MSW landfill may also rec eive other types of RCRA Subtitle D wastes (§257.2 of this title) such as commercial solid waste, nonhazardous sludge, conditionall y exempt small quantity generator waste, and industrial solid waste. Portions of an MSW landfill may be separated by

access roads. An MSW landfill may

be publicl y or privatel y owned , and may be a new landfill, an existing landfill, or a lateral expansion. This information is being collected to assure compliance with 40 CFR Part 60, Subpart WWW

. In general, all NSPS 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 sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS

. 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. Based on our consultations with industry representatives, there is an average of one affected facilities 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 ye ars, an average of 195 respondents per ye ar will be subject to the standard , and four additional respondents per year will become subject to the standard

.2

The Office of Management and Budget ( OMB ) approved the currentl y active I CR without any

Terms of Clearance. In the United States, there are approximately 195 MSW facilities, which are owned and operated b y the municipal solid waste industry (the “Affected Public”). While a majority of the facilities are privatel y owned, for

- profit businesses, some landfills could be owned by municipal, state, or tribal government . At this time, the number of publicl y- owned landfills cannot be determined. The burden to the “Affected Public” may be found in Table 1: Annual Respondent Burden and Cost

– NSPS for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart WWW) (Renewal)

. The Federal government burden associated with the review of reports submitted by the respondent may

be found in Table 2: Average Annual EPA Burden

– NSPS for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart WWW ) (Renewal).
**2. Need for and Use o f the Collection**  **2(a) Need/Authority for the Collection** EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

**. . .** application of the best technological sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non - air quality health and environmental impact and energy requirements) the Administrat or determines has been adequatel y demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards e very four years. 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 moni toring 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 may3 reasonabl y require. In the Administrator's judgment, methane, carbon dioxide, and non

- methane organic g as compound emissions from MSW landfills cause or contribute to air pollution that may reasonabl y be anticipated to endanger pu blic health or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR Part 60, Subpart WWW

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the appli cable regulations which w ere promulgated in accordance with the Clean Air Act. The collected information is also 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 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 properl y installed and operated , that leaks are being detected and repaired , and that the standard is being met. The performance test may also be obs erved. The required quarterl y 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**  **3(a) Nonduplication** If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y 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 cop y 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 dup lication exists. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 79 FR 30117 ) on May 27, 2014 . No comments were received on the burd en published in the Federal Register

.4

**3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of all complianc e data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. In developing this I CR, we contacted the Solid Waste Association of North America (SWANA) at (800) 467

- 9262, and the National Waste & Recycling Association (NW&RA) at (202) 244

- 4700. It is our policy

to respond after a tho rough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice

. S WANA and NW&RA submitted concurrent comments regarding the current estimates for number of respondents, capital/start

up and operation and maintenance costs, ty pes of reporting and recordkeeping activities and the burden associated with the activities . The comment letter states the following : 1. The current estimate for total number of respondents is inaccurate because the EPA Fact Sheet for the recentl y proposed Updates to the NSPS for NSW Landfills (79 FR 41796) states that “about 1,000 MSW landfills are subject to either the 1996 emission guidelines for MSW landfills 40 CFR Part 60, Subpart Cc, or the 1996 NSPS for new or modified landfills (Subpart WWW)”. We did not increase the estimated number of respondents from 195 to 1,000 because it is unclear how many of the 1,000 facilities the commenters believe are subject to Subpart WWW provisions alone. T he two subparts apply to different sets of facilities: Subpart Cc applies to all landfills constructed, reconstructed, or modified prior to May

30, 1991 and Subpart WWW apples to all landfills constructed, reconstructed, or modified on or after May 30, 1991. 2. The current estimate s for the capital/startup and operating and maintenance (O&M) costs in Section 6(b)(iii) are too low because EPA has not included the purchase price and O&M costs for (1) flow meters, (2) thermocouples, and (3) data recorders. Inthis ICR, we have incorporated the suggested purchase price and O&M costs for all three devices. 3. The assumption that only n ew respondents will need to conduct quarterl y s urface methane monitoring is incorrect because the activity is required for all respondents that operate a gas collection and control sy stem (GCCS). We have made the appropriate change to our burden calculati ons to address this comment.5

4. The current burden estimate only includes the initial performance test report and quarterl y surface methane monitoring under required activities. The comment states that we neglected to include the required monthly wellhead m onitoring and the burden of conducting Tier 2 and 3 testing. The commenter also provides a table with examples of the annual costs that a landfill subject to the regulation would expect (see table below). **Requirement Price Per**  **Annual Total** Annual report (now semi

- annual) $5,000/each $10,000 Semi

- annual SSM reports $2,000/each $4,000 Quarterl y SEM $2,500/quarter $10,000 Remonitoring for SEM $2,500/year $2,500 Monthly wellhead monitoring $2,000/month $24,000 Remonitoring for wells $5,000/year $5,000 O&M of monitoring equipment $5,000/year $5,000 Recordkeeping and data storage $1,000/month $12,000 Data compilation and review $500/month $6,000 In response to this comment, EPA incorporate d the suggested costs into our burden estimate, with the following exceptions: (1) We did not change the annual report to a semi

- annual report because the regulations do not require semi

- annual reporting; (2) we did not incorporate the suggested costs for the semi

- annual shutdown, startup and malfunction (SSM) report because that is onl y a requirement of the NESHAP for landfills (40 CFR Part 63 Subpart AAAA); (3) we did not include the cost of remonitoring for wells because Subpart WWW do es not require remon itoring for wells; (4) we did not add this suggested cost of O&M of monitoring equipment because the O&M costs of monitoring equipment were addressed in an earlier comment ; and (5) we did not include the cost of conducting Tier 2 and Tier 3 testing because the comment letter does not specify the burden of this activity

. **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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR Part 1320, Section 1320.5. These standards require the respondents to maintain all records, including reports and6

notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five ye ar records retention requirement is consistent with the Part 70 permit program and the five ye ar statute o f limitations on which the permit program is based. T he retention of records for five years allow s EPA to establish the compliance history of a source , an y pattern of non - compliance and to determine the appropriate level of enforcement action. EPA has fo und that the most flagrant violators have violations extending beyond five ye ars. 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 369 02, September 1, 1976; amended b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**
T he reporting or recordkeeping requirements in the standard do not include sensitive questions. **4. The Respondents and the Information Requested**  **4(a) Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are MSW landfills

. The United States Standard Industrial Classification ( SI C ) code for the respondents affected b y the standards is SI C 9511 , which corresponds to the North American Industry Classification Sy stem (NA IC S ) 924110 for Air and Water Resources and Solid Waste Management

. **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NSPS for Municipal Solid Waste Landfill s (40 CFR Part 60, Subpart WWW) (Renewal)

. A source must make the following reports:

**Notification s**  Notification of actual startup 60.7(a)(3)7 **Reports** Initial design capacity

report 60.7(a)(1), 60.757(a) Initial and annual non

- methane organic compounds (NMOC) emission rate reports 60.757(b) Collection and control system design plan 60.757(c) Landfill closure report 60.757(d) Equipment removal report 60.757(e) Initial and annual operations reports 60.8, 60.757(f) A source must keep the following records: **Recordkeeping** Maintain records of maximum design capacity, refuse

- in

- place, year by

- ye ar waste acceptance rate (maintain for 5 years) 60.758(a) Maintain records of s ys tem 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 ye ars) 60.758(b) Maintain records of monitoring for five ye ars 60.758(c) Maintain records of plot map and well locations for the life of the landfill (for life of the collection sy stem) 60.758(d) Maintain records of collection and control s ys tem exceedances for 5 ye ars 60.758(e)
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 recordke eping at a plant site. Also, regulatory

agencies in cooperation with th e respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated th at approximately 10 percent of the respondents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities**8 **Respondent Activities** Read instructions. Perform initial performance test, Reference Method 25, 25C, 18 test, and repeat performance tests 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring s ys tem. 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** 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.9 **Agency Activities** Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capabi lity 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 and quarterly reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and i ts delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for f

ive ye ars. **5(c) Small Entity Flexibility** All of the current 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 ty pes 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, theref ore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **5(d) Collection Schedule** The specific frequency

for each information collect ion activity within this request is shown in below Table 1: Annual Respondent Burden and Cost

– NSPS for Municipal Solid Waste L andfills (40 CFR Part 60, Subpart WWW) (Renewal). **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and10

reporting requirements applicable to the industry for the subpart included in this I CR. 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

. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 111,471 ( Total Labor Hours from Table 1). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency

kn owledge and experience with the NSPS program, the previously approved ICR, and an y comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 2 8

. 0 2 ($ 60.98 + 110%) Technical $ 10 1

. 05 ($4 8

. 12 + 110%) Clerical $ 5 1

. 37 ($2 4

. 46 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 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 ty pe of industry

cost s 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. The capital/startup costs are one time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor 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 1 (G)

Total O&M, (E X F)11 **Capital/Startup vs. Operation and Maintenance (O&M) Costs** Portable Methane Monitor $8,100 4 $32,400 $1,000 1 7 5 $17 5,00 0

Flow Meter $3,000 4 $12,000 $1,000 17 5 $175,00 0 Thermocouple $500 4 $2,000 $1,000 17 5 $17 5,000 Data Recorder $4,500 4 $18,000 $1,000 17 5 $17 5,000 **TOTAL $64,400**  **$700,000** 1 Only respondents that have active gas collection and control systems (GCCS) need to have these equipment installed. There are a total of 195 MSW landfills subject to this standard. We assume 90% of these landfills have GCCS installed (175 sources). The total capital/startup costs for this I CR are $ 64 ,400 . This is the total o f column D in the above table. The total operation and maintenance ( O&M) costs for this I CR are $ 70 0 ,000

. This is the total of column G. The average annual cost for capital/sta rtup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $ 764 ,400

. These are recordkeeping costs. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained 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 $ 30,932

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 4 General Schedule , which excludes locality

rates of pay

. The rates have been increased by 60 percent to acc ount 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

– NSPS for Municipal12

Solid Waste Landfills (40 CFR Part 60, Subpart WWW) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 195 existing respondents will be subject to the standard. It is estimated that an additional 4 res pondents per ye ar will become subject. The overall average number of respondents, as shown in the table below, is 195 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR. **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w 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 4 187 0 0 191
2 4 191 0 0 195 3 4 195 0 0 199 Average 4 191 0 0 195 1 New respondents include sources with constructed, reconstructed and modified affected facilities. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 195

. The total number of annual responses per ye ar is calculated using the following table:13 **Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D
Initial performance report 4 1 N/A 4 Initial design capacity report 4 1 N/A 4 Report of non

- me thane organic compounds flow

rate 20 1 N/A 20 Report of tier 2 and 3 NMOC

sampling 20 1 N/A 20 Annual reports 195 1 N/A 195 Total Number of Annual Responses 243 The number of Total Annual Responses is 243

. The total annual labor costs are $ 10,913,267

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NSPS for Municipal Solid Waste L andfills (40 CFR Part 60, Subpart WWW) (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 111,471

. Details regarding these estimates may be found in Table 1. Annual Respondent Burden and Cost

– NSPS for Municipal Solid Waste L andfills (40 CFR Part 60, Subpart WWW) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 45 9 hours per response

. The total annual capital/start up and O&M costs to the regulated entity are $ 76 4,400

. 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 next three years is estimated to be 525 labor hours at a cost of $ 30,932 . See Table 2: Average Annual EPA Burden and Cost

– NSPS14

for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart WWW) (Renewal). **6(f) Reasons for Change in Burden** There is an adjustment increase in the total estimated burden as currently identified in the OMB Inventory

of Approved I CR Burdens. This increase is not due to any program changes. The change in burden and cost estimat es occurred as a result of incorporating comments received from industry

consultations. In general , the comments addressed respondent activities that were not included in the previous I CR and increased the burden estimate for activities that were already included. The details of the comments received from industry and how they

were incorporated can be found in Section 3(c)

– Consultations. In corporating the comments resulted in a substantial increase in the labor and cost burden estimates. In addition, a small amount of the increase in burden cost is due to the use of the most updated labor rates. There is also an increase in the total estimated Capital/Startup and O&M costs. This increase occurred as a result of incorporating comments received from industry consultations. In general, the comments stated that the previous ICR did not include the purchase price and O&M costs of three additional devices that respondents are required to use. The cost of the devices can be found in section 6(a)(iii)

– C apital/Startup vs. Operation and Maintenance Costs. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 45 9 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; devel op, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 I CR und er Docket ID Number EPA

- HQ

- OECA

- 201 4

- 0047 . 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 i n the sy stem , select “search,” then key in the docket ID number identified15

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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the tel ephone number for the docket center i s (202) 566

- 1927

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please in clude the EPA Docket ID Number EPA

- HQ

- OECA

- 20 1 4

- 0047 and OMB Control Number 2060

- 0220 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.16 **Table 1: Annual Respondent Burden and Cost**

**– NSPS for**  **Municipal Solid Waste Landfills ( 40 CFR Part 60, Subpart WWW)**  **(Renewal)**

**Burden item (A)**  **Technical person**  **** **hours per occurrence**  **(B )** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Technical p**  **erson**   ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **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. Read Instructions c 1 1 1 195 195 9.75 19.5 $21,954.66 B. Required Activities d Initial performance test report 2 1 2 4 8 0.4 0.8 $900.70 Surface methane monitoring quarterlye 22 4 88 175.5 15444 772.2 1544.4 $1,738,809.07 Remonitoring for surface methane mo nitoring f 22 1 22 175.5 3861 193.05 386.1 $434,702.27 Wellhead monitoring monthlyg 18 12 216 175.5 37908 1895.4 3790.8 $4,267,985.90 C. Create Information See 3B D. Gather existing information See 3B E. Write report Initial design capacity report h 2 1 2 4 8 0.4 0.8 $900.70 Report of non

- methane organic compounds (NMOC) flow

rate i 2 1 2 20 39 1.95 3.9 $4,390.93
Report of tier 2 and 3 NMOC sampling Change j 12 1 12 20 234 11.7 23.4 $26,345.59
Initial p erformance test See 3B Compliance report See 3B Annual report k 44 1 44 195 8580 429 858 $966,005.04 **Reporting Subtotal 76,219**  **$7,461,995** 4. Recordkeeping requirements A. Read Instructions See 3A B. Plan activities N/A C. Implement activities N/A D. Develop record system N/A E. Time to enter information Recordkeeping and data storage l 9 12 108 195 21060 1053 2106 $2,371,103.28 Data compilation and review m 4 12 48 195 9360 468 936 $1,053,823.68 Record of accumulated refuse j 8 1 8 29 234 11.7 23.4 $26,345.5917

**Burden item (A)**  **Technical person**  **** **hours per occurrence**  **(B )** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Technical p**  **erson**   ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Total Cost per year**  **b**

F. Train to train personnel N/A G. Audits N/A **Recordkeeping Subtotal 35,252**  **$3,451,273 TOTAL LABOR BURDEN AND**  **COST 111,471**  **$ 10,913,267** 

**Assu mptions:** 
a We have assumed that the average number of existing respondents is 195 plus 4 additional new sources who will become subject to the rule over the three

- year period of this ICR. b This ICR uses the following labor rates: $ 1 28.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and $51.37 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, “Table 2 . Civilian Worke rs, 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 one hour for each respondent to read instructions as part of their reporting requirements

. d We have assumed that 90 percent of new respondents will also have an active gas collection system.
e Based on industry comments, we assume that quarterly surface methane monitoring will cost $2,500 per quarter per respondent, which is approximately 22 technical person hours per occurrence. f Based on industry comments, we assume that re

- monitoring for surface methane monitoring will occur approximately once per year per respondent and cost $2,500 per occurrence, which is approximately 22 technical person hours per occurrence. g Based on industry comments, we assume that monthly wellhead monitoring will cost $2,000 per month per respondent, which is ap proximately 18 technical person hours per occurrence. h We have assumed that it will take two hours for each respondent to complete the initial design capacity report. i We have assumed that 10 percent of respondents will have to complete the non

- methane organi c com pounds flow

rate report. j We have assumed that all sources completing reports of non

- methane organic compounds flow will have to complete the non

- methane organic compound sampling report. k Based on industry comments, we assume that the annual repo rt will cost $5,000 to w rite, which is approximately 44 technical person hours per occurrence. l Based on industry comments, we assume that recordkeeping and data storage will cost $1,000 per month per respondent, which is approximately 9 technical person hours per occurrence. m Based on industry comments, we assume that data compilation and review will cost $500 per month per respondent, which is appr oximately 4 technical person hours per occurrence. n We have assumed that 15 perc ent of respondents will take 8 hours to enter the record of accumulated refuse information18

**Table 2: Average Annual EPA Burden and Cost**

**– NSPS for**  **Municipal Solid Waste Landfills ( 40 CFR Part 60, Subpart**  **WWW) (Renewal)** 

**Burden item (A)**  **Technical p**  **erson hours**  **p er**  **o ccurrence**  **(B)**

**Number of o**  **ccurrences per y**  **ear (C)** 

**Technical person hours**  **per plant p er**  **y ear**  **(C=AxB) (D)** 

**Plants per**  **y ear**  **a (E)** 

**Technical h**  **ours per**  **y ear**  **(E=CxD) (F)** 

**Managem ent**  **hours per y ear**  **(F=0.05xE) (G)** 

**Clerical hours p**  **er y**  **ear (G=0.1xE)**  **(H)**

**Tot al**  **Cost, per y**  **ear b** 

Revie w reports Initial design capacity 2 1 2 4 8 0.4 0.8 $542.07 Review NMOC emission rate reports c 1 1 1 20 19.5 0.975 1.95 $1,321.29 Review tier 2 calculations d 1 1 1 20 19.5 0.975 1.95 $1,321.29 Review tier 3 calculations d 1 1 1 20 19.5 0.975 1.95 $1,321.29 Annual report e 2 1 2 195 390 19.5 39 $2 6 ,42 5

. 8 2 **TOTAL LABOR BURDEN AND COST**  **525 $** **30,932**

**Assu mptions**  : a We have assumed that the average number of existing respondents is 195 plus 4 additional new sources who will become subject to the rule over the three

- year period of this ICR. b This cost is based on the following hourly labor rates, increased by 60% to account for the benefit packages available to gov ernment employees: $62.90 for Managerial (GS

- 13, Step 5, $39.31+60%), $46.67 for Technical (GS

- 12, Step 1, $29.17 + 60%) and $25.25 Clerical (GS

- 6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM) “2014 General Schedule” which excludes l ocality rates of pay.
c We have assumed that the agency will take one hour once per year to review each of the non

- methane organic compounds emission rate reports for 10 percent of respondents. d We have assumed that the agency will take one hour once pe r year to review each of the tier 1 and 3 calculations for 1 0 percent of respondents

. e We have assumed that the agency will take two hours once per year to review each of the annual report s submitted by each of 195 respondents

.