SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Emission Guidelines and Compliance Times for Existing Municipal Solid Waste Landfills 

(40 CFR Part 60, Subpart Cc and 40 CFR Part 62, Subpart GGG) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

Emission Guidelines and Compliance Times for Existing Municipal Solid Waste Landfills 

(40 CFR Part 60, Subpart Cc and 40 CFR Part 62, Subpart GGG) (Renewal), EPA ICR 

Number 1893.06, OMB Control Number 2060-0430.

1(b) Short Characterization/Abstract

The Emission Guidelines and Compliance Times for Existing Municipal Solid Waste 

Landfills (40 CFR part 60, subpart Cc) were proposed on May 30, 1991, and promulgated on 

March 12, 1996. The landfills emission guidelines are implemented through either State or 

Federal plans (40 CFR part 62, subpart GGG), which EPA developed for landfills located in 

States and Indian countries that did not develop State or Tribal plans. States directly implement 

and enforce their own State plans, whereas EPA both implements and enforces the Federal plan.

State plans were due to EPA by December 12, 1996, and the Federal plan was promulgated on 

November 8, 1999. The emission guidelines apply to existing municipal solid waste (MSW) 

landfills that: commenced modification or construction before May 30, 1991; accepted waste at 

any time since November 8, 1987; or have a capacity available for future waste deposition. 

MSW landfills that were constructed on or after May 30, 1991, or that had changes in design 

capacities on or after May 30, 1991, are subject to EPA’s new source performance standards 

(NSPS) and not the emission guidelines. This information is being collected from subject MSW 

landfills to assure compliance with 40 CFR part 60, subpart Cc and 40 CFR part 62, subpart 

GGG.

Existing MSW landfills are required to submit reports and maintain records specified 

in section 4(b) of this supporting statement. Because landfills have been subject to the emission 

guidelines for several years, they have already completed initial notifications and submitted 

design plans. Since subpart Cc applies to existing sources only, and no more sources are 

expected to trigger the requirements, only the routine reporting and recordkeeping requirements 

currently apply. The notifications, reports, and records are essential in determining compliance, 

and are required of all MSW landfills subject to the emission guidelines.

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. For landfills subject to a State plan, reports are sent to the 

State or local authority that developed the State plan. For landfills subject to the Federal plan, 

reports are sent to the respective EPA regional office.
Over the next three years, an average of 474 MSW landfills owners/operators and 37 

State/local agencies, for a total of 511 MSW per year will be subject to the standards. This figure 

is based on the previous ICR, which initially estimated an average of 519 respondents. The 

previous ICR also estimated a landfill closure rate of three percent per year. To account for 

closures occurring in the three-year period that passed since the previous ICR, we have 

subtracted 45 landfills from the previous estimate, or 15 landfills per year (519 x 3 percent per 

year = 15 landfills per year, after rounding) over three years. No additional sources will become 

subject to this regulation during the next three years. It is not possible for additional facilities to 

qualify as an existing source, since they would have to be operational and exceed the design 

capacity requirements before May 30, 1991.

The active (previous) ICR had the following Terms of Clearance (TOC):

When this ICR is renewed, EPA should review the respondent burden,

universe, labor rates, and capital costs and ensure these estimates 

have been updated.

EPA has addressed each item of concern in the TOC by reviewing the aforementioned 

items and updating the estimates accordingly. These updates are discussed in detail in Section 

6(f).

The burden to the “Affected Public” may be found in Table 1a below: Annual 

Respondent Burden and Cost – Emission Guidelines and Compliance Times for Existing 

Municipal Solid Waste Landfills (40 CFR Part 60, Subpart Cc and 40 CFR Part 62, Subpart 

GGG) (Renewal). For landfills covered by a State plan, State and local agencies are the 

“implementing agency,” and will incur a burden through the review of reports submitted to them 

in accordance with the State plan. The Burden to “State and local agencies” is attributed entirely 

to work performed by State and local employees, and is provided below in Table 1b: Average 

Annual State/Local Agency Burden and Cost – Emission Guidelines and Compliance Times for 

Existing Municipal Solid Waste Landfills (40 CFR Part 60, Subpart Cc and 40 CFR Part 62, 

Subpart GGG) (Renewal). For landfills covered by the Federal plan, EPA is the implementing 

agency. The “burden” to the Federal government is attributed entirely to work performed by

either Federal employees or government contractors and is provided below in Table 2: Average 

Annual EPA Burden and Cost – Emission Guidelines and Compliance Times for Existing 

Municipal Solid Waste Landfills (40 CFR Part 60, Subpart Cc and 40 CFR Part 62, Subpart 

GGG).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under section 111(d)(1) of the Clean Air Act (CAA), as amended, to:

. . . prescribe regulations which shall establish a procedure similar 

to that provided by section 110 under which each State shall 

submit to the Administrator a plan which (A) establishes standards 
of performance for any existing source for any air pollutant (i) for 

which air quality criteria have not been issued or which is not 

included on a list published under section 108(a) . . . but (ii) to 

which a standard of performance under this section would apply if 

such existing source were a new source, and (B) provides for the 

implementation and enforcement of such standards of 

performance.

The EPA is required under section 129 of the Act, to establish guidelines for existing 

stationary sources that reflect the maximum achievable control technology (MACT) for 

achieving continuous emission reductions:

Section 129(a)(1)(A) states:

The Administrator shall establish performance standards and other 

requirements pursuant to section 111 and this section for each 

category of solid waste incineration units. Such standards shall 

include emissions limitations and other requirements applicable to 

new units and guidelines (under section 111(d) and this section) 

and other requirements applicable to existing units.

Section 129(a)(2) states:

Standards applicable to solid waste incineration units promulgated 

under section 111 and this section shall reflect the maximum 

degree of reduction in emissions of air pollutants listed under 

section (a)(4) that the Administrator, taking into consideration the 

cost of achieving such emission reduction, and any non-air quality 

health and environmental impacts and energy requirements, 

determines is achievable for new or existing units in each category.

Section 129(b)(1) states:

Performance standards under this section and section 111 for solid 

waste incineration units shall include guidelines promulgated 

pursuant to section 111(d) and this section applicable to existing 

units. Such guidelines shall include, as provided in this section, 

each of the elements required by subsection (a) (emissions 

limitations, notwithstanding any restriction in section 111(d) 

regarding issuance of such limitations), subsection (c) 

(monitoring), subsection (d) (operator training), subsection (e) 

(permits), and subsection (h)(4) (residual risk).

Subpart B of 40 CFR part 60 requires State plans to include monitoring, recordkeeping, 

and reporting provisions consistent with the emission guidelines. In addition, section 114(a)(1) 

states that:
4

he Administrator may require any person who owns or operates 

any emission source, who manufactures emission control 

equipment or process equipment, who the Administrator believes 

may have information necessary for the purposes set forth in this 

subsection, or who is subject to any requirement of this Act (other 

than a manufacturer subject to the provisions of section 206(c) or 

208 with respect to a provision of title II) on a one-time, periodic 

or continuous basis to:

(A) establish and maintain such records;

(B) make such reports;

(C) install, use, and maintain such monitoring 

equipment, and use such audit procedures, 

or methods;

(D) sample such emissions (in accordance with such 

procedures or methods, at such locations, at such 

intervals, during such periods and in such manner as 

the Administer shall prescribe); 

(E) keep records on control equipment 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, non-methane organic compound (NMOC) emissions 

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

endanger either public health or welfare. Therefore, the emission guidelines were promulgated 

for this source category at 40 CFR part 60, subpart Cc, and part 62, subpart GGG.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards ensure compliance 

with the applicable regulations which where 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 standards. Continuous emission monitors are used to 

ensure compliance with the standards at all times.

The notifications required in the standards 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 properly 
5

installed and operated and the standards are being met.

The required annual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures, and for compliance 

determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 60, subpart 

Cc and 40 CFR part 62, subpart GGG.

3(a) Non-duplication

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, duplication does not exist.

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 (77 FR 63813) on October 17, 2012. No comments were received on the 

burden published in the Federal Register. 

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 by industry, in compliance with the recordkeeping 

and reporting provisions in the standard, is the Online Tracking Information System (OTIS)

which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database 

for the collection, maintenance, and retrieval of all compliance data. 

Consultations with industry representatives (i.e., respondents) were conducted to 

determine if there is any way for EPA to reduce the recordkeeping and reporting burden or 

improve the language in the standard to make it easier to comply. In developing this ICR, 

EPA contacted: 1) the Solid Waste Association of North America, at (240) 494-2253; and 

2) the United States Conference of Mayors, Municipal Waste Management Association, at 

(202) 861-6798.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice.
6

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 (CBI) (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

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 the 

respondents affected by the standards are provided in the following table: 
7

Standard (40 CFR Part 60, Subpart Cc and 40 CFR 

Part 62, Subpart GGG)

SIC Codes NAICS Codes

Air and Water Resource and Solid Waste Management 9511 924110

Refuse Systems, Solid Waste Landfills 4953 562212

Respondents are also State and local agencies that review reports submitted by landfill 

owners/operators located in States that have an effective State plan. State and local agencies

will conduct the same activities as EPA. Activities for implementing agencies (i.e., State, local 

or EPA) are identified in Section 5(a).

4(b) Information Requested

(i) Data Items

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

Guidelines and Compliance Times for Existing Municipal Solid Waste Landfills (40 CFR Part 

60, Subpart Cc and 40 CFR Part 62, Subpart GGG).

A source must make the following reports:

Notifications/Reports

Initial design capacity report.1

60.33c(d), 60.757(a)

62.14355(a)(1)

Initial and annual NMOC emission rate reports.1

60.33c(e)(1)(i), 60.757(b)

62.14355(a)(2)

Collection and control system design plan.1

60.757(c), 62.14355

Increments of progress report.

1

62.14355(b-c)

Annual compliance report 60.757(f)

Landfill closure report 60.757(d)

Equipment removal report 60.757(e)

1

Because landfills have been subject to the emission guidelines for several years, they have already completed initial notifications and submitted 

design plans. Since subpart Cc only applies to existing sources, and no additional sources are expected, only routine reporting, and 

recordkeeping requirements currently apply.
8

A source must keep the following records:

Recordkeeping

Records of control system monitoring (maintain for five years) 60.758(b)

Records of maximum design capacity, refuse-in-place, year-byyear waste acceptance (maintain for five years)60.758(a)

Records of system design and initial performance test/compliance 

determination (maintain for five years)

60.758(b)

Record of a plot map and well locations for the life of the landfill 

(maintain for life of collection system)

60.758(d)

Records of collection & control system exceedances, including 

surface monitoring exceedances (maintain for five years)

60.758(c) and (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 recordkeeping at 

a source site. 

Also, regulatory agencies, in cooperation with the respondents, continue to create 

reporting systems to transmit data electronically. However, electronic reporting systems are still 

not widely used. At this time, it is estimated that approximately 10 percent of the respondents 

use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Write the 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 
9

Respondent Activities

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 system). Although personnel 

at the source still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping.

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

Information Management

5(a) Agency Activities

State and local agencies are the implementing agencies for landfills covered by a State 

plan and conduct the same activities as EPA. EPA conducts the following activities in 

connection with the acquisition, analysis, storage, and distribution of the required information.

Agency Activities

Observe performance tests if necessary (requirement no longer applies).

Review reports required to be submitted by industry. Annual compliance, amended design,

and closure reports are the only types of reports expected to be submitted by respondents and 

reviewed by EPA or State and local agencies during the time period covered by this ICR. 

Review surface monitoring methane concentrations. 

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS).

5(b) Collection Methodology and Management

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

compliance and enforcement programs. The annual reports are used for problem identification, 

as a check on source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the OTIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 
10

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). There are no small 

entities (i.e., small businesses) affected by this regulation. Therefore, EPA does not expect that 

small MSW landfills will be adversely impacted by the emission guidelines. Small landfills 

were required to submit a one-time design capacity report only. In choosing a design capacity 

of 2.5 million megagrams (Mg) and 2.5 million cubic meters as the regulatory cutoff for annual 

reporting, EPA exempted landfills that are very unlikely to emit 50 Mg or more of NMOC per 

year (see 61 FR 9918, March 12, 1996). EPA also developed a computer model version of the 

tiered approach to estimate emissions on the landfills Web site (www.epa.gov/ttn/atw/landfill/

landflpg.html) that is available to any owner or operator subject to the emission guidelines. 

Such tools significantly reduced the burden of the NMOC emission rate calculation.

5(d) Collection Schedule

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

shown below in Tables 1a and 1b: Annual Respondent Burden and Cost – Emission Guidelines 

and Compliance Times for Existing Municipal Solid Waste Landfills (40 CFR Part 60, Subpart 

Cc and 40 CFR Part 62, Subpart GGG) (Renewal).

6. Estimating the Burden and Cost of the Collection

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

reporting requirements applicable to the industry for each of the subparts included in this ICR. 

The individual burdens are expressed under standardized headings for landfills, both privatelyand publicly-owned, that are 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.

Table 1b documents the computation of annual burden for State and local agencies 

that implement and enforce the State plan. State and local agency burden is expressed under 

standardized headings, which are believed to be consistent with the concept of burden under the 

Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been 

identified in the table. On average, 37 State/local agencies will be enforcing State plans that 

cover 317 landfills affected by State plans. State and local agencies conduct the same activities 

as EPA.

In total, the emission guidelines for MSW landfills are estimated to affect an average of 

474 landfills. Of these, 157 are affected by the Federal plan and 317 are affected by State plans. 

This ICR assumes all 474 landfills have already exceeded the 50 Mg/yr NMOC emission 
11

threshold and are no longer submitting annual NMOC emission rate reports. The landfills must 

submit annual compliance reports and conduct quarterly monitoring for methane emissions from 

the surface of the landfill.

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 41,518 hours (Total Labor Hours from Table 1a

below). The average annual burden to State and local agencies that implement and enforce State 

plans is 759 hours (Total Labor Hours from Table 1b below). Therefore, total average annual 

respondent hours are 42,277. These hours are based on Agency studies and background 

documents from the development of the regulation, Agency knowledge and experience with 

the emission guideline program, the previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.44 ($57.83+ 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 110%)

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

2012, “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.

For public-sector respondents (i.e., publicly-owned or -operated landfills), EPA applied 

the same government employee labor rates as EPA agency staff, which are presented in Section 

6(c).

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

The type of industry costs associated with the information collection activities in the 

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

associated with continuous monitoring. Capital/startup costs are one-time costs when a facility

becomes subject to the regulation. No capital/startup costs are included in this ICR since these 

costs would have been incurred in the first year by existing sources, and since no new sources are 

expected. Annual operation and maintenance (O&M) costs are the ongoing costs to maintain the 

monitor(s) and other costs such as photocopying and postage.
12

(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)

NA NA NA NA $1,400 474 $663,600

1

Total number of respondents are derived from 157 Privately owned and 317 Publicly owned

There are no capital/startup costs for this ICR. This is the total of column D in the table 

above. 

The total O&M costs for this ICR are $663,600. 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 $663,600. 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 

$16,947.

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2012 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 – Emission Guidelines 

and Compliance Times for Existing Municipal Solid Waste Landfills (40 CFR Part 60, Subpart 

Cc and 40 CFR Part 62, Subpart GGG) (Renewal).
13

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

Based on our research for this ICR, the average number of respondents over the next 

three years is approximately 474 landfill owners/operators and 37 State/local agencies, for a 

total respondent count of 511. It is estimated that 15 respondents per year will undergo landfill 

closures and will no longer be subject to the emission guidelines. The overall average number 

of respondents, as shown in the table below, is 474 respondents per year.

EPA estimates that 67 percent of landfills are publicly-owned and that 33 percent are 

privately-owned. Thus, the count of 474 landfills includes 157 private landfills and 317 public 

landfills. We also estimate that 67 percent of landfills are subject to a State plan; therefore, there 

are 317 landfills (publicly- or privately-owned) for which State and local agencies will 

implement the emission guidelines.

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

years covered by this ICR. 

Number of Respondents

Year (A)

Number of 

Existing 

Respondents

(B)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(C)

Number of 

Existing 

Respondents 

That Are No

Longer 

Subject 1

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B-C-D)

Private Landfills

1 167 0 5 0 162

2 162 0 5 0 157

3 157 0 5 0 152

Average 157

Public Landfills

1 337 0 10 0 327

2 327 0 10 0 317

3 316 0 10 0 306

Average 317

Total for Private and Public Landfills 474

State/Local Agencies

1 39 0 1 0 38

2 38 0 1 0 37

3 37 0 1 0 36

Average 37

1

This ICR assumes a landfill closure rate of three percent. Upon closure, these landfills will no longer be subject
14

to the emission guidelines. This ICR also assumes there will be a proportional decrease in the number of 

State/local agency respondents.

Columns C and D are subtracted to avoid double-counting respondents. As shown above, 

the average Number of Respondents over the three-year period of this ICR is 474 landfill 

owners/operators and 37 State/local agencies, for a total respondent count of 511.

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

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)+(CxD)

Private Landfills

Amended design capacity report 8 1 0 8

Annual compliance report 157 1 0 157

Landfill closure report 5 1 0 5

Surface methane monitoring 0 4 157 628

Total Responses for Private Landfills 798

Public Landfills

Amended design capacity report 16 1 0 16

Annual compliance report 317 1 0 317

Landfill closure report 10 1 0 10

Surface methane monitoring 0 4 317 1,268

Total Responses for Public Landfills 1,611

State/Local Agencies

Amended design capacity report 16 1 0 16

Annual compliance report 317 1 0 317

Landfill closure report 10 1 0 10

Surface methane monitoring 0 4 0 0

Total Responses for State/Local Agencies 343

Total Respondents 2,752

The number of Total Annual Responses is 2,752.

The total annual labor costs are $4,054,254. Details regarding these estimates may be 

found below in both Tables 1a and 1b.

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 
15

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

(i) Respondent Tally

The total annual labor hours are 42,277 at a cost of $4,054,254. Details regarding these 

estimates may be found in Tables 1 and 2.

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

information is estimated to average 15 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $663,600. The 

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

(O&M) Costs.

The following table summarizes the respondent tally from Tables 1 and 2. 

Respondent Tally

Entity Number of 

respondents

Number of 

responses per 

year

Total hours

per year

Total annual

labor cost

Total annual

O&M costs

Private landfills 157 798 13,752 $1,331,558 $219,800

Public landfills 317 1,611 27,766 $2,688,507 $443,800

State/local agencies 37 343 759 $34.189 $0

Total (rounded) 511 2,752 42,277 $4,054,254 $663,600

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 376

labor hours at a cost of $16,947, see Table 2 below: Average Annual EPA Burden and Cost –

Emission Guidelines and Compliance Times for Existing Municipal Solid Waste Landfills (40 

CFR Part 60, Subpart Cc and 40 CFR Part 62, Subpart GGG) (Renewal).

6(f) Reasons for Change in Burden

There is a net decrease in the total burden associated with both privately- and publiclyowned landfills. This decrease is due to an adjustment to the estimated average number of 

respondents. To account for landfill closures that have occurred since the previous ICR was 

approved, this ICR applies a three-percent per year landfill closure rate to the previous ICR’s 

estimated number of respondents. This adjustment decreased the total burden hours associated 

with privately and publicly owned landfills. There is an increase in burden cost from the most 

recently approved ICR. This is due to the fact that this ICR uses updated labor rates from the 

Bureau of Labor Statistics to calculate respondent burden costs. 
16

There is an increase in the respondent burden and cost associated with State and local 

agencies. This increase is due to an adjustment in the labor burden calculations. The previous 

ICR assumed that, for each burden item, person-hours per occurrence included technical, 

managerial, and clerical labor hours. To be consistent with the estimation methodology used in 

other ICRs, this ICR assumes that person-hours per occurrence includes technical labor only, and 

that managerial and clerical hours account for an additional 5 and 10 percent, respectively, of 

technical labor hours. This adjustment increased the State and local agency burden hours and 

costs.

There is also a decrease in the Federal Agency burden due to adjustments in the labor 

burden calculations. The previous ICR included a burden item for Agency review of surface 

methane monitoring reports. Respondents, however, are not required to submit reports; 

therefore, no Agency burden will be incurred. For this reason we have adjusted the calculations 

to exclude any Agency burden associated with surface methane monitoring. We have also 

adjusted the total labor burden attributed to EPA technical, managerial, and clerical labor. 

As described in the previous paragraph, we adjusted the calculations for consistency with 

other ICRs, and so that managerial and clerical hours account for an additional 5 and 10 percent, 

respectively, of technical labor hours. The net result of these adjustments was a decrease in 

burden.

There is also a decrease in O&M costs from the most recently approved ICR. This 

decrease is not due to any program changes, and is attributed to the decrease in the number of 

respondents due to landfill closures that have occurred since the previous ICR was approved. 

As a result, there is a proportional decrease in the O&M cost.

6(g) Burden Statement

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

is estimated to average 15 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 
17

Docket ID Number EPA-HQ-OECA-2012-0680. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. 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-2012–0680 and OMB Control Number 2060-0430 in any

correspondence. 

Part B of the Supporting Statement

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

information.
18

Table 1a: Annual Respondent Burden and Cost – Emission Guidelines and Compliance Times for Existing Municipal Solid

 Waste Landfills (40 CFR Part 60, Subpart Cc and 40 CFR Part 62, Subpart GGG) (Renewal)

Burden Item

A B C D E F G H

Technical 

personhours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Technical 

personhours per 

respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b, c

1. Reporting Requirements (Privately Owned Landfills)

A. Initial design capacity report N/A 1 0 0 0 0 0 0

B. Initial and annual NMOC 

emission rate reports d N/A 1 0 0 0 0 0 0

C. Collection and control system 

design plan N/A 1 0 0 0 0 0 0

D. Increments of progress N/A 5 0 0 0 0 0 0

E. Amended design capacity 

report e2 1 2 8 16 0.8 1.6 1,781.65

F. Annual compliance report f2 1 2 157 314 15.7 31.4 34,964.84

G. Landfill closure report g2 1 2 5 10 0.5 1 1,113.53

H. Equipment removal report h2 1 2 0 0 0 0 0

I. Surface methane monitoring 14 4 56 157 8,792 439.6 879.2 979,015.58

Subtotal for Reporting 

Requirements for Privately Owned 10,502 1,016,875.60

2. Reporting Requirements (Publicly Owned Landfills)

A. Initial design capacity report N/A 1 0 0 0 0 0 0

B. Initial and annual NMOC 

emission rate reports d N/A 1 0 0 0 0 0 0

C. Collection and control system 

design plan N/A 1 0 0 0 0 0 0

D. Increments of progress N/A 5 0 0 0 0 0 0

E. Amended design capacity 

report e2 1 2 16 32 1.6 3.2 3,563.29
19

Burden Item

A B C D E F G H

Technical 

personhours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Technical 

personhours per 

respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b, c

F. Annual compliance report f2 1 2 317 634 31.7 63.4 70,597.80

G. Landfill closure report g2 1 2 10 20 1 2 2,227.06

H. Equipment removal report h2 1 2 0 0 0 0 0

I. Surface methane monitoring 14 4 56 317 17,752 887.6 1,775.2 1,976,738.45

Subtotal for Reporting

Requirements for Publicly Owned 21,204 2,053,126.60

3. Recordkeeping Requirements (Privately Owned Landfills)

A. Records of control system 

monitoring 0.5 12 6 157 942 47.1 94.2 104,894.58

B. Records of accumulated refuse 8 1 8 157 1,256 62.8 125.6 139,859.37

C. Records of surface methane 

monitoring 0.5 4 2 157 314 15.7 31.4 34,964.84

D. Records of collection and 

control system exceedances 0.5 4 2 157 314 15.7 31.4 34,964.84

E. Records of system design and 

initial performance test N/A 4 0 157 0 0 0 0

Subtotal for Recordkeeping

Requirements for Privately 

Owned 3,250 314,682.63

4. Recordkeeping Requirements (Publicly Owned Landfills)

A. Records of control system 

monitoring 0.5 12 6 317 1,902 95.1 190.2 211,793.40

B. Records of accumulated refuse 8 1 8 317 2,536 126.8 253.6 282,391.21

C. Records of surface methane 

monitoring 0.5 4 2 317 634 31.7 63.4 70,597.80

D. Records of collection and 

control system exceedances 0.5 4 2 317 634 31.7 63.4 70,597.80
20

Burden Item

A B C D E F G H

Technical 

personhours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Technical 

personhours per 

respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b, c

E. Records of system design and 

initial performance test N/A 4 0 317 0 0 0 0

Subtotal for Recordkeeping

Requirements for Publicly 

Owned 6,562 635,380.21

Reporting and Recordkeeping Subtotals for Privately and Publicly Owned Landfills

Reporting Labor Burden (Privately Owned Landfills) 10,502 1,016,875.60

Recordkeeping Labor Burden (Privately Owned Landfills) 3,250 314,683.58

Subtotal Labor Burden and Cost (Privately Owned Landfills) 13,752 1,331,558.23

Reporting Labor Burden (Publicly Owned Landfills) 21,204 2,053,126.60

Recordkeeping Labor Burden (Publicly Owned Landfills) 6,562 635,380.21

Subtotal Labor Burden and Cost (Publicly Owned Landfills) 27,766 2,688,506.81

TOTAL LABOR BURDEN AND COST (rounded) 41,518 $4,020,065

Assumptions:

a.

 We estimate there are 474 existing landfills subject to the emission guidelines. Of these, we estimate 157 (33%) landfills are private and 317 (67%) are public.

b.

 This ICR uses the following labor rates: Technical $100.23 ($47.73 + 110%); Managerial $121.44 ($57.83+ 110%); and Clerical $50.51 ($24.05 + 110%). 

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical 

hours.

c.

 Labor rates for Federal agency personnel were applied to publicly owned landfills, and are based on the average hourly labor rate as follows: Technical $46.21 

(GS-12, Step 1, $28.88 + 60%); Managerial $62.27 (GS-13, Step 5, $38.92 + 60%); and Clerical $25.01 (GS-6, Step 3, $15.63 + 60%). This ICR assumes that 

Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2012 General 

Schedule, which excludes locality rates of pay. The rates have been applied to local agencies and have been increased by 60 percent to account for the benefit 

packages available to government employees.

d.

 This ICR assumes that all landfills affected by a State plan or the Federal plan have already exceeded the 50 Mg/yr NMOC emission threshold and are no longer 

submitting annual NMOC emission rate reports.
21

e.

 This ICR assumes 5 percent of landfills will submit an amended design capacity report per year.

f.

 We estimate that 33% of private landfills are subject to the Federal plan and 67% of private landfills are subject to a State plan. Our estimate of 157 private 

landfills includes 52 private landfills subject to the Federal plan and 105 private landfills subject to a State plan. Our estimate of 317 public landfills includes 

105 public landfills subject to the Federal plan and 212 public landfills subject to a State plan.

g.

 This ICR assumes 3 percent of landfills will submit a landfill closure report per year.

h.

 This ICR assumes no landfills will submit an equipment removal report over the 3-year period of this ICR.
22

Table 1b: Average Annual State/Local Agency Burden and Cost – Emission Guidelines and Compliance Times for Existing 

Municipal Solid Waste Landfills (40 CFR Part 60, Subpart Cc and 40 CFR Part 62, Subpart GGG) (Renewal)

Burden Item

A B C D E F G H I

Technical 

personhours per 

occurrence

No. of 

occurrences 

per landfill 

per year

Landfills 

per agency 

(Average no. in 

States 

enforcing State 

plans)a

Technical 

personhours 

per agency 

per year 

(AxBxC)

No. of 

agencies 

enforcing 

State 

plans a

Technical 

hours 

per year 

(DxE)

Management 

hours 

per year 

(Fx0.05)

Clerical 

hours 

per year 

(Fx0.10)

Total 

cost per 

year ($)b

1. Reporting Requirements

A. Review initial design capacity 

report N/A 1 0 0 0 0 0 0 0

B. Review initial and annual 

NMOC emission rate reports c N/A 1 0 0 0 0 0 0 0

C. Review collection and control 

system design plan N/A 1 0 0 0 0 0 0 0

D. Review increments of progress N/A 5 0 0 0 0 0 0 0

E. Review amended design 

capacity report d1 1 0.43 0.43 37 15.91 0.8 1.59 824.53

F. Review annual compliance 

report e2 1 8.57 17.14 37 634.18 31.71 63.42 32,866.06

G. Review landfill closure report f1 1 0.26 0.26 37 9.62 0.48 0.96 498.55

H. Review equipment removal 

report g1 1 0 0 0 0 0 0 0

Total Labor Burden and Cost

(rounded) 759 $34,189

Assumptions:

a.

 This ICR assumes that 317 landfills are subject to State plans, and that 37 State and local agencies will be enforcing State plans. Thus, each agency is expected 

to review reports for an average of 8.34 landfills.

b.

 Labor rates for Federal agency personnel were applied to State/Local agencies, and are based on the average hourly labor rate as follows: Technical $46.21 (GS12, Step 1, $28.88 + 60%); Managerial $62.27 (GS-13, Step 5, $38.92 + 60%); and Clerical $25.01 (GS-6, Step 3, $15.63 + 60%). This ICR assumes that 

Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2012 General 

Schedule, which excludes locality rates of pay. The rates have been applied to local agencies and have been increased by 60 percent to account for the benefit 

packages available to government employees.
23

c.

 This ICR assumes that all landfills affected by a State plan have already exceeded the 50 Mg/yr NMOC emission threshold and are no longer submitting annual 

NMOC emission rate reports.

d.

 This ICR assumes 5 percent of landfills will submit an amended design capacity report per year.

e.

 We estimate that 33% of landfills are subject to the Federal plan and 67% of landfills are subject to a State plan. Our estimate of 317 landfills subject to a State 

plan includes 105 private landfills and 212 public landfills.

f.

 This ICR assumes 3 percent of landfills will submit a landfill closure report per year.

g

. This ICR assumes no landfills will submit an equipment removal report over the 3-year period of this ICR.
24

Table 2: Average Annual EPA Burden and Cost – Emission Guidelines and Compliance Times for Existing Municipal Solid 

Waste Landfills (40 CFR Part 60, Subpart Cc and 40 CFR Part 62, Subpart GGG) (Renewal)

Burden Item

A B C D E F G H

Technical 

personhours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Technical 

personhours per 

respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total 

cost per 

year ($)b

1. Reporting Requirements

A. Review initial design capacity report N/A 1 0 0 0 0 0 0

B. Review initial and annual NMOC rate reports c N/A 1 0 0 0 0 0 0

C. Review collection and control system design 

plan N/A 1 0 0 0 0 0 0

D. Review increments of progress N/A 5 0 0 0 0 0 0

E. Review amended design capacity report 1 1 1 8 8 0.4 0.8 414.6

F. Review annual compliance report 2 1 2 157 314 15.7 31.4 16,272.89

G. Review landfill closure report e1 1 1 5 5 0.25 0.5 259.12

H. Review equipment removal report f1 1 1 0 0 0 0 0

Total Labor Burden and Cost (rounded) 376 $16,947

Assumptions:

a

. We estimate there are 474 existing landfills that are subject to the emission guidelines. Of these, we estimate 157 (33%) of landfills are private and 317 (67%) 

are public.

b.

 This cost is based on the average hourly labor rate as follows: Technical $46.21 (GS-12, Step 1, $28.88 + 60%); Managerial $62.27 (GS-13, Step 5, $38.92 + 

60%); and Clerical $25.01 (GS-6, Step 3, $15.63 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 

percent of Technical hours. These rates are from the OPM, 2012 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 assumes that all landfills affected by a State plan or the Federal plan have already exceeded the 50 Mg/yr NMOC emission threshold and are no longer 

submitting annual NMOC emission rate reports.

d.

 This ICR assumes 5 percent of landfills will submit an amended design capacity report per year.

e.

 We estimate that 33% of landfills are subject to the Federal plan and 67% of landfills are subject to a State plan. Our estimate of 157 landfills subject to the 
25

Federal plan includes 52 private landfills and 105 public landfills.

f.

 This ICR assumes 3 percent of landfills will submit a landfill closure report per year.

g.

 This ICR assumes no landfills will submit an equipment removal report over the 3-year period of this ICR.