SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

1. Identification of the Information Collection

1(a) Title of the Information Collection

Emission Guidelines and Compliance Times for Municipal Sol id Waste Landfills (40 CFR part 60, subpart Cf), EPA ICR Number 2522.01, OMB Control N umber 2060- NEW

.

1(b) Short Characterization/Abstract

The Emission Guidelines and Compliance Times for Existi ng Municipal Solid Waste Landfills (40 CFR part 60, subpart Cc) and the New Source Pe rformance standards (NSPS) (40 CFR part 60, subpart WWW) were proposed on May 30, 1991, and promu lgated on March 12, 1996. This proposal will update the emission guidelines in a new subpart Cf and will apply to existing municipal solid waste (MSW) landfills that acce pted waste since November 8, 1987 and commenced construction, reconstruction, or modificatio n on or before July 17, 2014. Once implementation of these revised emission guidelines are finalized, the burden associated with 40 CFR part 60, subpart Cf will replace the ICR burden estima tes for (40 CFR part 60, subpart Cc, ICR Number 1893.06) and (40 CFR part 60, subpart WWW, ICR Number 1557.09). MSW landfills that were constructed after July 17, 2014 or tha t were modified (had changes in design capacities) after July 17, 2014 are subject to EPA’s proposed revisions to the NSPS (see 40 CFR part 60, subpart XXX, ICR Number 2498.02).

The EPA is not statutorily obligated to review the emis sion guidelines, but has the discretionary authority to do so when circumstances ind icate that this is appropriate. Based on changes in the landfills industry and changes in size, o wnership, and age of landfills since the emission guidelines were promulgated in 1996, the EPA has con cluded that it is appropriate to review the landfills emission guidelines. EPA is proposi ng a new subpart (40 CFR part 60 subpart Cf), that will apply to municipal solid waste l andfills that have accepted waste since November 8, 1987 and were constructed, modified, or reconst ructed on or before July 17, 2014. All MSW landfills that are subject to the original NSPS (40 CFR part 60, subpart WWW), the federal plan (40 CFR part 62 subpart GGG), or a state plan i mplementing the original emission guidelines (40 CFR part 60, subpart Cc) would continue to comply with their current requirements unless and until they are covered by a more stringent state or federal plan implementing the emission guidelines in this new subpart C f.

This proposed subpart contains a revision to reduce the NMO C emission rate threshold from the current level of 50 megagrams per year (Mg/yr) to 34 Mg/yr for landfills that are not closed as of the date the proposed subpart Cf is published in the Federal Register. The proposed option retains the design capacity cutoff of 2.5 million Mg and 2.5 million cubic meters in the current emission guidelines. Closed landfills will retai n the same NMOC threshold of 50 Mg/yr, which is the level currently promulgated under subpart WWW. Closed landfills will also be exempted from the one time reporting requirements, provided the landfill fulfilled these requirements under the NSPS (40 CFR part 60, subpart WWW), the federal plan (40 CFR part2

62, subpart GGG), or a state plan implementing subpart 40 CFR part 60 subpart Cc. This information is being collected to assure compliance with 40 CFR part 60, subpart Cf.

In general, existing MSW landfills are required to submit initial notifications and reports and maintain records, and conduct initial performance test s and periodic monitoring. Landfill owners/operators must submit an initial design capacity report, initial performance test report, emission rate reports, and collection and control syst em design plans. Landfill closure and equipment removal reports are required when the landfill closes or the landfill meets the criteria for removing controls. Annual compliance reports must incl ude the following information: descriptions of any period in which the value of any of the monitored operating parameters fell outside the established ranges, and any period when the coll ection system or air pollution control equipment is not operating, or when the collected gas was diverted from the control device.

Landfill owners or operators must keep continuous monitori ng records of the parameters reported in the initial performance report; records of mont hly monitoring of wellhead temperature, pressure, and nitrogen or oxygen concentration; and records of quarterly monitoring of surface methane concentrations. In addition, owner s or operators are required to maintain records of the annual compliance reports, including the o ccurrence and duration of any startup, shutdown, or malfunction in the operation of an affect ed facility, or any period during which the monitoring system is inoperative. The recordkeeping and repo rting requirements specific to municipal solid waste landfills are detailed in Section 4(b) of this supporting statement. The notifications, reports, and records are essential in dete rmining compliance, and are required of all MSW landfills subject to the emission guidelines. Any o wner or operator subject to the provisions of proposed subpart Cf will maintain a file of t hese measurements, and retain the file for at least five years following the date of such measur ements, maintenance reports, and

records.

The landfills emission guidelines under subpart Cf are i mplemented through either state plans or a federal plan that EPA will develop for land fills located in states and Indian country that did not develop a state or tribal plan. States direct ly implement and enforce their state plan. EPA implements and enforces the federal plan.

All reports are sent to the state or local authority implementing the state plan. In the event that there is no state plan, the reports are sent direc tly to the United States Environmental Protection Agency (EPA) regional office.

Based on our consultations with industry representatives , there is an average of one affected facility at each plant site, and each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 988 MSW landfill s (the “Affected Public”) will be subject to the emission guidelines. No additional source s will become subject to this regulation. It is not possible for an additional facili ty to qualify as an existing source, since it would have to be operational and exceed the design capacity requirements on or before July 17,

2014.3

Of the 988 MSW landfills, 65 percent (645 facilities) are o wned and operated by the local government and 35 percent (343 facilities) are privately-owne d, for-profit businesses. The burden to the “Affected Public” may be found in Tables A1 through B3 in

Attachment A. The cost of this ICR to MSW landfills is $37,828,043 in labor costs, averaged over the first three years after the proposal is fina l.

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 sim ilar 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 i s not included on a list published under section 108(a)

. . . but (ii) to which a standard of performance under this section would appl y if such existing source were a new source, and (B) provides for the implementation and enforcement of such standards of performance.

Subpart B of 40 CFR part 60 requires state plans to include monitoring, recordkeeping, and reporting provisions consistent with the emission guide lines. In addition, CAA section 114(a)(1) states that:

...the Administrator may require any person who owns or oper ates any emission source, who manufactures emission control equipment or process equipment, who the Administrator b elieves may have information necessary for the purposes set for th in this subsection, or who is subject to any requirement of this A ct (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 equipment4

parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with section 114(a)(3); and (G) provide such other information, as the Administrator may reasonably require.

The Administrator has determined that landfill gas emis sions from municipal solid waste landfills either cause or contribute to air pollution t hat may reasonably be anticipated to endanger public health or welfare. Therefore, the emission guidel ines were promulgated for this source category at 40 CFR part 60, subpart Cc, and a federal plan was promulgated at 40 CFR pa rt 62, subpart GGG and a review of these emission guidelines is being proposed under new subpart 40 CFR part 60, subpart Cf.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations, which were promulgated in accordance with the CAA. In addition, the collected information is used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission standard. Contin uous 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 ma y be recorded and used to determine compliance in place of a continuous emission m onitor.

The notifications required in the standard are used to info rm the EPA or delegated authority of existing sources subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pol lution control devices are properly installed and operated, that leaks are being detected and repa ired, and that the standards are being met. The performance test may also be observed.

The required reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations.

3. Nonduplication, Consultations, and Other Collection Crit eria

The requested recordkeeping and reporting are required under pro posed 40 CFR part 60, subpart Cf, as implemented through state plans and the land fills federal plan.

3(a) Nonduplication5

If the subject standards have not been delegated, the info rmation is sent directly to the appropriate EPA regional office. Otherwise, the inform ation 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 sta te or local agency can be sent to the Administrator in lieu of the report required by the federal standards. Therefore, no duplication

exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

A public notice of this collection is provided in the Fede ral Register notice of proposed rulemaking published for the Emission Guidelines and Complian ce Times for Municipal Solid

Waste Landfills.

3(c) Consultations

Industry experts have been consulted and the EPA’s inter nal data sources and projections of industry and growth over the next three years have b een considered. The primary source of information is the data from 40 CFR part 98, subpart HH of the EPA Greenhouse Gas Reporting Program (GHGRP). These data were supplemented with a datab ase maintained by EPA’s Landfill Methane Outreach Program (LMOP), as well as information received from EPA Regional Offices and state authorities, and public commen ts regarding landfills expected to be built or modify between 2014-2018. New and modified sources wer e subtracted from the database of affected sources because they would become subject to subpart XXX upon modification instead of the state and federal plans im plementing the emission guidelines. Based on these data sources, a dataset of approximately 1,839 land fills was created.

Given the numerous reporting and recordkeeping similarities between proposed subpart Cf, and the currently promulgated Emissions Guidelines sub part Cc and NSPS subpart WWW, many of the line item burden estimates in this ICR estim ate are the same as the burdens for the most recent ICR renewal, ICR number 1557.09 for subpart WWW. For the most recent subpart WWW ICR renewal, industry trade associations EPA consu lted with two trade groups: the Solid Waste Association of North America (SWANA) at (800) 467-9262 , and the National Waste & Recycling Association (NW&RA) at (202) 244-4700.

EPA received written comments from the Solid Waste As sociation of North America (SWANA) requesting that EPA adjust the line item estimat es for certain burden items. 1 While the estimated respondent universe and labor rates for subpart C f as well as some of burden line item estimates in subpart Cf are unique to this subpart, many of the comments on the ICR renewal for subpart WWW were relevant for improving the burden estima tes in this ICR. The burden table calculations provide notes on which burden line items refle ct public comments received on the ICR renewal for subpart WWW.

1 See Docket EPA-HQ-OECA-2014-0047 for a copy of the written com ments submitted by SWANA.6

The public was provided the opportunity to review and comment o n the burden estimated in the ICR for the July 17, 2014 proposed subpart XXX (79 FR 41796). The EPA received

comments that it did not account for the burden on MSW landfills that would become modified and thus become affected by subpart XXX. As a result of these comments, EPA has moved the impact on modified landfills out of the existing landfill impacts analysis and burden statement and incorporated these modified landfills into the impac ts and burden statement for new and modified MSW landfills in the subpart XXX ICR. The public will be provided the opportunity to

review and comment on the burden estimated in this Inform ation Collection Request during the comment period for the proposed rulemaking.

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. Require ments for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and that emission limitations are met. If the i nformation required by these standards was collected less frequently, the proper operation and mainte nance of control equipment and the possibility of detecting violations would be less likely. T he EPA will be considering mechanisms to further streamline recordkeeping and reporting requirement s as part of the notice and comment process on this proposal.

3(e) General Guidelines

None of these reporting or recordkeeping requirements viola te any of the regulations established by OMB at 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consist ent with the General Provisions as applied to the standards. EPA believes that the five-year records r etention requirement is consistent with the Part 70 permit program and the five-year statute of limita tions 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 t he appropriate level of enforcement

action. EPA has found that the most flagrant violators have violations extending beyond the five years. In addition, EPA would be prevented from pursuing th e violators due to the destruction or

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the EPA for which a claim of confidentiality is made will be safeguarded according to the EPA policies set forth i n Title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions7

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

4. The Respondents and the Information Requested

4(a) Respondents/NAICS Code

The respondents for recordkeeping and reporting requirements are the owners/operators of MSW landfills that are subject to the emission gui delines. The North American Industry Classification System (NAICS) code is 924110 for Air and Wa ter Resources and Solid Waste Management, and NAICS 562212 for Solid Waste Landfill. The r espondents include both publically and privately owned landfills. The breakdown of o wnership is shown in the burden

tables of this ICR.

4(b) Information Requested

None of these reporting or recordkeeping requirements viola te any of the regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i) Data Items, Including Recordkeeping Requirements

All data in this ICR that are recorded and/or reporte d are required by the emission guidelines reporting and recordkeeping requirements for existin g municipal solid waste landfills, 40 CFR part 60, subpart Cf.

A source must make the following reports:

Reports Standard Citation by Section
Initial and amended design capacity report 60.33f(d), 60.38f(a), 60.38f(b)
Initial and annual (or 5-year) non-methane organic compounds (NMOC) emission rate reports (or Tier 4 surface emiss ions report) 60.33f(e), 60.38f(c)

Initial and revised collection and control system design plans 60.38f(d), 60.38f(e)
Landfill closure report 60.38f(f)

Equipment removal report 60.38f(g)

Initial performance test report and annual operations repor ts 60.8, 60.38f(h),

60.38f(i)

A source must keep the following records:

Recordkeeping

Maintain records of maximum design capacity, refuse-in- place, year- 60.39f(a),8

Recordkeeping
by-year waste acceptance rate (maintain for 5 years)
Maintain records of system design and initial performan ce test/compliance determination (must be kept for life of t he control equipment; records of subsequent tests must be maintaine d for 5 years) 60.39f(b)

Maintain records of monitoring for five years 60.39f(c)

Maintain records of plot map and well locations for th e life of the landfill (for life of the collection system) 60.39f(d)

Maintain records of collection and control system exc eedances and monitoring data for 5 years 60.39f(e), 60.39f(h)

Maintain records of annual recalculation of site-speci fic density and design capacity 60.39f(f)

Maintain records of all surface emissions monitoring fo r 5 years (for landfills opting to use the Tier 4 approach) 60.39f(g)

Electronic Reporting

Currently, some of the respondents are using monitoring equ ipment that automatically records parameter data. Although personnel at the affected facility must evaluate the data, internal automation has significantly reduced the burden as sociated with monitoring and recordkeeping at the facility.

Also, regulatory agencies, in cooperation with the respo ndents, continue to create reporting systems to transmit data electronically. At thi s time, it is estimated that approximately 90 percent of the respondents will use electronic reportin g for subpart Cf. Further, most of the methods in the landfills emission guidelines are not s upported by the EPA Electronic Reporting Tool (ERT). Thus, electronic reporting of performance te sts may not be required for some landfills initially, but will be required when applicable methods are added to the ERT.

For data collected using test methods supported by the ERT as listed on the EPA’s ERT website (http://www.epa.gov/ttn/chief/ert/index.html), t he owner or operator must submit the results of the performance test to the Compliance and Emissions Data Reporting Interface (CEDRI), accessed through the EPA’s Central Data Exchan ge (CDX) (http://cdx.epa.gov/epa_home.asp), unless otherwise approved by t he Administrator.

Performance test data must be submitted in a file format generated through the use of the EPA’s ERT. NMOC emission rate reports and annual reports wil l be submitted using subpart specific

forms in the CEDRI.

(ii) Respondent Activities

Respondent Activities

Read instructions.
Calibrate and operate surface emission monitoring equipmen t for quarterly monitoring and portable LFG emission analyzer equipment for monthly we llhead monitoring.9

Respondent Activities
Estimate NMOC emission estimates using Tier 1, Tier 2, Tier 3, or Tier 4 procedures in the regulation.
Perform initial performance test, Reference Method 25, 25A, and 25C test, and repeat performance test if necessary.
Write the notifications and reports listed above.
Enter information required to be recorded above.
Submit the required reports developing, acquiring, installing, an d utilizing technology and systems for the purpose of collecting, validating, and ver ifying

. Develop, acquire, install, and utilize technology and syste ms for the purpose of processing and maintaining information.
Develop, acquire, install, and utilize technology and syste ms for the purpose of disclosing and providing information.
Adjust the existing ways to comply with any previously appl icable instructions and requirements.
Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

Currently, sources are using monitoring equipment that prov ides 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 monit oring equipment has significantly reduced the burden associated with monitoring and recordkeeping.

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

5(a) Agency Activities

For landfills covered by the federal plan, EPA is the i mplementing agency. EPA conducts the following activities in connection with the acquisit ion, analysis, storage, and distribution of the required information.

Agency Activities

Observe initial performance tests, repeat performance test s and quarterly surface emissions monitoring if necessary.

Review notifications and reports, including performance te st reports, excess emissions reports, required to be submitted by industry.

Audit facility records.10

Agency Activities

Input, analyze, and maintain data in Enforcement and Comp liance History Online (ECHO)

and ICIS..

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance tests reports are used by the EPA to determine a source’s initial capability to comply with the emission standard. Data and records maintained by the respon dents are tabulated and published for use in compliance and enforcement programs. The annua l reports are used for problem identification, as a check on source operation and maint enance, and for compliance

determinations.

Information contained in the reports is reported by state and local governments in the ICIS Air database, which is operated and maintained by EP A's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and ret rieval of compliance data for industrial and government-owned facilities. EPA uses ICIS for tracki ng air pollution compliance and enforcement by local and state regulatory agencies, EPA r egional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retri eve and analyze the data.

As more of the methods used in the NSPS are added to the ERT, these data will also be stored and accessible through the EPA’s Central Data Ex change (CDX) ( http://cdx.epa.gov/epa_home.asp ).

The records required by this regulation must be retained i n a readily accessible format by the owner/operator for five years.

5(c) Small Entity Flexibility

The EPA has determined that approximately 46 of the private ly-owned existing landfills and 52 of the publically-owned existing landfills subject to sim ilar regulations (40 CFR Part 60 subparts WWW and Cc or the corresponding state or federal plan) are small entities based on the ownership profiles of landfills in its regulatory databa se.

Subpart Cf does not contain any provisions reserved exclusive ly for the benefit of small entities. However, there are several compliance flexi bilities that will benefit all landfills, including small entities. First, the proposal includes a s eparate subcategory for closed landfills. This subcategory retains an emission threshold of 50 Mg/yr , which is currently promulgated in similar regulations. Landfills in this category are al so exempt from many of the one-time reporting requirements, provided those reports were submitted unde r 40 CFR part 60, subparts WWW and Cc or the corresponding state or federal plan. Se cond, while the standard continues to require monthly monitoring of wellhead parameters, the EPA has proposed to remove the wellhead operating standards for temperature and oxygen/nitrogen , which will reduce the corrective actions, re-monitoring, and requests for alter native timelines. Third, the rule has11

provided a proposed non-numeric definition of treatment, w hich is expected to provide some flexibility for landfills with LFG energy recovery. F inally, the landfill has included alternative site-specific emission thresholds for determining when a landfill must install (Tier 4) or remove controls, which are expected to provide flexibility for l andfill owners/operators required to control under subpart Cf.

In addition to these compliance flexibilities, EPA als o notes that it has retained the same size based criteria, 2.5 million Mg and 2.5 million cubic me ters design capacity as the regulatory cutoff for annual reporting. Small landfills will be requi red to submit only a one-time design capacity report. In choosing 2.5 million Mg and 2.5 million cubic meters design capacity as the regulatory cutoff for annual reporting, EPA exempted landfi lls that are very unlikely to emit 50 Mg or more of NMOC per year (see 61 FR 9918, March 12, 1996).

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown in Tables 1.A through 3.B of Attachments A and B.

6. Estimating the Burden and Cost of the Collection

Tables 1.A through 3.A of Attachment A document the computatio n of individual burdens for the recordkeeping and reporting requirements appli cable to publically-owned landfills for the subpart included in this ICR. Tables 1.B to 3.B presents the burden on privatelyowned MSW landfills.

The individual burdens are expressed under standardized headings consistent with the concept of burden under the Paperwork Reduction Act. Whereve r appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

The EPA may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currentl y 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 621,947 labor hou rs (Total Labor Hours from Tables 1.A through 3.B). These hours are based on Agency stud ies and background documents from the development of the regulation, Agency knowledge and experience with the emission guideline program, the most recent ICR renewal for subpart WWW, and any comments received and any comments received on the ICR for the July 17, 2014 pro posal for subpart XXX.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs This ICR uses the following labor rates:12

Managerial $109.43 ($52.11 + 110%) Technical $ 86.46 ($41.17 + 110%) Civil Engineer Technician $ 49.85 ($23.74 + 110%) Clerical $ 30.28 ($14.42 + 110%)

These rates are from the United States Department of L abor, Bureau of Labor Statistics, May 2013, National Occupational Employment and Wage Estimates United States. The rates are from column 1, “Total Compensation.” The rates have b een increased by 110 percent to account for the benefit packages available to those employed by pri vate industry. For public-sector respondents (i.e., publicly-owned or -operated landfills), it was assumed that the work performed will be completed by private contractors.

(ii) Estimating Capital and Operation and Maintenance (O&M) Costs

The types of industry costs associated with the informa tion collection activities in the subject standard are both labor costs, which are addressed e lsewhere in this ICR, and the costs associated with continuous monitoring at the flare stati on, quarterly surface monitoring, monthly wellhead monitoring, and conducting a Tier II NMOC emission rate test. The capital/startup costs are one-time costs when a facility becomes subj ect to the regulation or when the facility first installs controls. The capital costs have bee n annualized over the five-year period allowed

before another Tier II test must be conducted. While this proposal allows landfills to conduct Tier 3 or Tier 4, industry experience suggest that no landfi lls are using the Tier 3 approach and it is unknown how many landfills would use the Tier 4 alte rnative. The capital costs for the initial performance testing and continuous monitoring equipment are annualized over a 15-year period, consistent with the expected lifetime of the flare, a nd an estimated annual O&M for these equipment were also estimated based on recent consultat ion with industry on the subpart WWW

ICR renewal.

For landfills that must install gas collection and cont rol systems, there are additional nonlabor costs associated with conducting an initial (and re peat, if necessary) performance test on the flare or other destruction device, conducting quarterly surface emission monitoring (SEM), and conducting monthly wellhead monitoring. However, the propo sed rule cost analysis assumes that the portable equipment used to complete the SEM and w ellhead is rented and not purchased. Based on industry experience, many landfills contract ou t monitoring services. Therefore no capital/startup costs are estimated. The table below inc ludes rental cost and calibration and hydrogen fuel costs for the annual O&M of SEM equipment. F or wellhead monitoring, the comments received on the most recent ICR renewal provi ded a cost per month for monitoring, but the costs did not break out labor vs. equipment cost s and this ICR applies the full cost in terms of burden hours. Therefore, the table below only sh ows the O&M costs associated with the calibration gases for the wellhead monitoring device. The c osts to monitor surface emissions and wellheads are also included in the annualized cost impacts analysis for the supplemental proposal.13

The annual operation and maintenance costs are the ongo ing costs to maintain, calibrate, and operate the purchased monitoring equipment, rent monitor ing equipment, and other costs such as photocopying and postage.

(iii) Capital/Startup Operation and Maintenance Costs

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

(A)
Monitoring

Device (B)

Capital/Start up Cost for

One Respondent (C)

Annualized Capital/Start up Cost for

One Respondent (D)

Average

Number of Respondents per Year (E)

Total Capital / Startup Cost, (C X D) per Year (F)

Annual

O&M Costs

for One Respondent (G)

Number of Respondent

s with

O&M (H)

Total O&M, (F X G)

Method 25 or 25C testing

costs for initial performance

test $10,067 $1,105 572 $632,060 $0 0 $0

Sampling probe

and Method 25 or 25C testing

costs for Tier 2

test $10,067 $2,455 109 $267,595 $0 0 $0

Method 21

Surface

Emission

Monitor 0 0 0 $0 $1,814 645 $1,169,30

4

Portable

Wellhead

Monitor 0 0 0 $0 $204 645 $131,498

Flow Meter $3,000 $330 572 $188,760

$1000 645 $644,600 Thermocouple $500 $55 107 $5,902

Data Recorder $4,500 $494 572 $31,460

The average annualized capital/startup costs for this ICR a re $1.4 million. This is the total

of column E in the above table. The annual O&M costs fo r this ICR are $1.9 million. The total non-labor costs are $3.3 million.

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, period ic inspection of sources of emissions, and the publication and distribution of collec ted information.14

The average annual agency cost during the three years of th e ICR is estimated to be $1,029,658. In subsequent years, the agency costs will be lowe r because it will require less review of initial tests and reports.

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

Managerial $63.52 (GS-13, Step 5, $39.70 + 60%) Technical $47.14 (GS-12, Step 1, $29.46 +60%) Clerical $25.50 (GS-6, Step 3, $15.94 + 60%)

These rates are from the Office of Personnel Manageme nt (OPM), 2015 General Schedule, which excludes locality rate of pay. The rates have been increased by 60 percent to account for the benefit packages available to government e mployees. Details upon which this estimate is based appear in Tables 1.C through 3.C of Attac hment C.

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

Based on the regulatory database used to estimate the imp acts for this proposal, the number of respondents is 988 landfill owners/operators per year. The number of respondents does not vary by year.

The total number of responses over the three-year perio d is calculated using the following

table:

Total Responses

(A) Information Collection Activity (B)

Number of Respondents (C)

Number of Responses

per Respondent (D)

Number of Existing Respondents That Keep

Records But Do

Not Submit Reports (E)

Total Responses E=(BxC)+D

Initial design capacity report 203 1 N/A 203

Amended design capacity report 80 1 N/A 80

Report of NMOC rate (Tier 1) 277 1 N/A 277

Report of NMOC rate (Tier 2) 109 1 N/A 109

Landfill Closure Report 69 1 N/A 69

Equipment Removal Report 0 1 N/A 0

Collection and Control System Design

Plan 635 1 N/A 635

Initial Performance Test Report 635 1 N/A 635
Revised design plan 63 1 N/A 63

Annual Report 1,934 1 N/A 1,934

Total Number of Annual Responses 4,00415

The number of Total Annual Responses is 4,004 responses over t he three-year period, or 1,335 responses per year (rounded).

The total labor costs are $113.5 million or $37.8 million pe r year. Details regarding these estimates may be found in Tables 1.A through 3.B of Attachm ents A and B.

6(e) Bottom Line Burden Hours Burden Hours and Cost Table s

The detailed bottom line burden hours and cost calculation s for the respondents and the agency are shown in Tables 1.A through 3.B of Attachments A and B and Tables 1.C through

3.C of Attachment C and summarized below.

(i) Respondent Tally

The total annual labor hours are 541,536 over this initial th ree-year period, or an average of 180,512 hours per year. Details regarding these estimates m ay be found in Tables A1 through B3 of Attachment A. Furthermore, the annual public report ing and recordkeeping burden for this collection of information is estimated to average 466hour s per response.

The total annual capital/startup and O&M costs to the regul ated entity are $9,822,654over the three-year period or an average of $3,274,218 per year. The cost calculations are detailed in Section 6(b)(iii) of this supporting statement, Capital/St artup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally The average annual agency burden and cost over next three y ears for is estimated to be 16,054 labor hours at a cost of $1,029,658. See Tables 1.C through 3.C of Attachment C.

6(f) Reasons for Change in Burden

There is no change in the labor hours or cost in this ICR because it is for the proposed new subpart Cf for the Emission Guidelines and Complian ce Times for Municipal Solid Waste

Landfills and is considered new burden.

6(g) Burden Statement

The annual reporting and recordkeeping burden for this collect ion of information is estimated to average 466 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 r eview 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 data16

sources; complete and review the collection of informat ion; 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 OM B 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, t he accuracy of the provided burden estimates, and any suggested methods for minimizing res pondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OAR-2014-0451. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy of the draft collection of information, submit or view public comments , access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the docket ID number identified

in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Do cket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is ( 202) 566-1744, and the telephone number for the docket center is (202) 566-1927. Also, you can sen d 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. Plea se include the EPA Docket ID Number EPA-HQ-OAR-2014-0451 and OMB Control Number 2060-NEW in any correspondence.

Part B of the Supporting Statement

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

information.