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 Solid Waste Landfills (40 

CFR part 60, subpart Cf), EPA ICR Number 2522.01, OMB Control Number 2060- NEW.

1(b) Short Characterization/Abstract 

The Emission Guidelines and Compliance Times for Existing Municipal Solid Waste 

Landfills (40 CFR part 60, subpart Cc) and the New Source Performance standards (NSPS) (40 

CFR part 60, subpart WWW) were proposed on May 30, 1991, and promulgated 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 accepted waste since November 8, 1987 and 

commenced construction, reconstruction, or modification 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 estimates 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 that 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 emission guidelines, but has the 

discretionary authority to do so when circumstances indicate that this is appropriate. Based on 

changes in the landfills industry and changes in size, ownership, and age of landfills since the 

emission guidelines were promulgated in 1996, the EPA has concluded that it is appropriate to 

review the landfills emission guidelines. EPA is proposing a new subpart (40 CFR part 60 

subpart Cf), that will apply to municipal solid waste landfills that have accepted waste since 

November 8, 1987 and were constructed, modified, or reconstructed 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 implementing 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 Cf. 

This proposed subpart contains a revision to reduce the NMOC 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 retain 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 part 
2

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 tests and periodic monitoring. Landfill 

owners/operators must submit an initial design capacity report, initial performance test report, 

emission rate reports, and collection and control system 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 include 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 collection 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 monitoring records of the parameters 

reported in the initial performance report; records of monthly monitoring of wellhead 

temperature, pressure, and nitrogen or oxygen concentration; and records of quarterly monitoring 

of surface methane concentrations. In addition, owners or operators are required to maintain 

records of the annual compliance reports, including the occurrence and duration of any startup, 

shutdown, or malfunction in the operation of an affected facility, or any period during which the 

monitoring system is inoperative. The recordkeeping and reporting 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 determining compliance, and are required of all 

MSW landfills subject to the emission guidelines. Any owner or operator subject to the 

provisions of proposed subpart Cf will 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. 

The landfills emission guidelines under subpart Cf are implemented through either state 

plans or a federal plan that EPA will develop for landfills located in states and Indian country 

that did not develop a state or tribal plan. States directly 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 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 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 landfills (the “Affected Public”) will 

be subject to the emission guidelines. No additional sources will become subject to this 

regulation. It is not possible for an additional facility 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 owned and operated by the local 

government and 35 percent (343 facilities) are privately-owned, 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 final. 

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. 

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

and reporting provisions consistent with the emission guidelines. In addition, CAA section 

114(a)(1) states that: 

...the 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 
4

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 emissions from municipal solid waste 

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

public health or welfare. Therefore, the emission guidelines were promulgated for this source 

category at 40 CFR part 60, subpart Cc, and a federal plan was promulgated at 40 CFR part 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. 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 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 pollution control devices are properly 

installed and operated, that leaks are being detected and repaired, 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 Criteria 

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

subpart Cf, as implemented through state plans and the landfills federal plan. 

 3(a) Nonduplication
5

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state 

or local agency. If a state or local agency has adopted its own similar standards to implement the 

federal standards, a copy of the report submitted to the state or local agency can be sent to the 

Administrator in lieu of the report required by the federal standards. Therefore, no duplication 

exists. 

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

 A public notice of this collection is provided in the Federal Register notice of proposed 

rulemaking published for the Emission Guidelines and Compliance Times for Municipal Solid 

Waste Landfills. 

 

3(c) Consultations

Industry experts have been consulted and the EPA’s internal data sources and projections 

of industry and growth over the next three years have been 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 database maintained by EPA’s 

Landfill Methane Outreach Program (LMOP), as well as information received from EPA 

Regional Offices and state authorities, and public comments regarding landfills expected to be 

built or modify between 2014-2018. New and modified sources were subtracted from the 

database of affected sources because they would become subject to subpart XXX upon 

modification instead of the state and federal plans implementing the emission guidelines. Based 

on these data sources, a dataset of approximately 1,839 landfills was created. 

Given the numerous reporting and recordkeeping similarities between proposed subpart 

Cf, and the currently promulgated Emissions Guidelines subpart Cc and NSPS subpart WWW, 

many of the line item burden estimates in this ICR estimate 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 consulted 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 Association of North America 

(SWANA) requesting that EPA adjust the line item estimates for certain burden items.1 While the 

estimated respondent universe and labor rates for subpart Cf 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 estimates in this ICR. The burden table 

calculations provide notes on which burden line items reflect public comments received on the 

ICR renewal for subpart WWW. 

 

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

The public was provided the opportunity to review and comment on 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 impacts 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 Information 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. Requirements 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 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. The EPA will be considering mechanisms 

to further streamline recordkeeping and reporting requirements as part of the notice and 

comment process on this proposal. 

3(e) General Guidelines

None of these reporting or recordkeeping requirements violate 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 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 the 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 EPA for which a claim of confidentiality is made will 

be safeguarded according to the EPA policies set forth in Title 40, chapter 1, part 2, subpart B - 

Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, 

March 23, 1979). 

3(g) Sensitive Questions
7

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 guidelines. The North American Industry 

Classification System (NAICS) code is 924110 for Air and Water Resources and Solid Waste 

Management, and NAICS 562212 for Solid Waste Landfill. The respondents include both 

publically and privately owned landfills. The breakdown of ownership is shown in the burden 

tables of this ICR. 

4(b) Information Requested 

None of these reporting or recordkeeping requirements violate 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 reported are required by the emission 

guidelines reporting and recordkeeping requirements for existing 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 emissions 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 reports 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 performance 

test/compliance determination (must be kept for life of the control 

equipment; records of subsequent tests must be maintained 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 the life of the 

landfill (for life of the collection system) 60.39f(d) 

Maintain records of collection and control system exceedances and 

monitoring data for 5 years 60.39f(e), 60.39f(h) 

Maintain records of annual recalculation of site-specific density and 

design capacity 60.39f(f) 

Maintain records of all surface emissions monitoring for 5 years (for 

landfills opting to use the Tier 4 approach) 60.39f(g) 

Electronic Reporting 

Currently, some of the respondents are using monitoring equipment that automatically 

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

internal automation has significantly reduced the burden associated with monitoring and 

recordkeeping at the facility. 

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

reporting systems to transmit data electronically. At this time, it is estimated that approximately 

90 percent of the respondents will use electronic reporting for subpart Cf. Further, most of the 

methods in the landfills emission guidelines are not supported by the EPA Electronic Reporting 

Tool (ERT). Thus, electronic reporting of performance tests 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), the 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 Exchange (CDX) 

(http://cdx.epa.gov/epa_home.asp), unless otherwise approved by the 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 will be submitted using subpart specific 

forms in the CEDRI. 

(ii) Respondent Activities 

Respondent Activities

Read instructions. 

Calibrate and operate surface emission monitoring equipment for quarterly monitoring and 

portable LFG emission analyzer equipment for monthly wellhead 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, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying. 

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information. 

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information. 

Adjust the existing ways to comply with any previously applicable instructions and 

requirements. 

Train personnel to be able to respond to a collection of information. 

Transmit, or otherwise disclose the information. 

Currently, sources are using monitoring equipment that provides 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

 For landfills covered by the federal plan, EPA is the implementing agency. EPA conducts 

the following activities in connection with the acquisition, analysis, storage, and distribution of 

the required information. 

Agency Activities

Observe initial performance tests, repeat performance tests and quarterly surface emissions 

monitoring if necessary. 

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

required to be submitted by industry. 

Audit facility records. 
10

Agency Activities

Input, analyze, and maintain data in Enforcement and Compliance 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 properly 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 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 reported by state and local governments in the 

ICIS Air database, 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 industrial 

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

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

EPA and its delegated Authorities can edit, store, retrieve and analyze the data. 

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 Exchange (CDX) 

(http://cdx.epa.gov/epa_home.asp). 

The records required by this regulation must be retained in 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 privately-owned existing landfills 

and 52 of the publically-owned existing landfills subject to similar 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 database. 

Subpart Cf does not contain any provisions reserved exclusively for the benefit of small 

entities. However, there are several compliance flexibilities that will benefit all landfills, 

including small entities. First, the proposal includes a separate 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 also exempt from many of the one-time 

reporting requirements, provided those reports were submitted under 40 CFR part 60, subparts 

WWW and Cc or the corresponding state or federal plan. Second, 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 alternative timelines. Third, the rule has 
11

provided a proposed non-numeric definition of treatment, which is expected to provide some 

flexibility for landfills with LFG energy recovery. Finally, 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 landfill owners/operators required to 

control under subpart Cf. 

In addition to these compliance flexibilities, EPA also notes that it has retained the same 

size based criteria, 2.5 million Mg and 2.5 million cubic meters design capacity as the regulatory 

cutoff for annual reporting. Small landfills will be required 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 landfills 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 computation of individual 

burdens for the recordkeeping and reporting requirements applicable 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. Wherever 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 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 621,947 labor hours (Total Labor Hours from 

Tables 1.A through 3.B). 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 most recent ICR renewal for subpart WWW, and any comments received 

and any comments received on the ICR for the July 17, 2014 proposal 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 Labor, 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 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), 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 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 at the flare station, 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 subject to the regulation or when the facility 

first installs controls. The capital costs have been 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 landfills are using the Tier 3 approach and it 

is unknown how many landfills would use the Tier 4 alternative. 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, and an estimated annual O&M for these 

equipment were also estimated based on recent consultation with industry on the subpart WWW 

ICR renewal. 

For landfills that must install gas collection and control systems, there are additional nonlabor costs associated with conducting an initial (and repeat, if necessary) performance test on 

the flare or other destruction device, conducting quarterly surface emission monitoring (SEM), 

and conducting monthly wellhead monitoring. However, the proposed rule cost analysis assumes 

that the portable equipment used to complete the SEM and wellhead is rented and not purchased. 

Based on industry experience, many landfills contract out monitoring services. Therefore no 

capital/startup costs are estimated. The table below includes rental cost and calibration and 

hydrogen fuel costs for the annual O&M of SEM equipment. For wellhead monitoring, the 

comments received on the most recent ICR renewal provided a cost per month for monitoring, 

but the costs did not break out labor vs. equipment costs and this ICR applies the full cost in 

terms of burden hours. Therefore, the table below only shows the O&M costs associated with the 

calibration gases for the wellhead monitoring device. The costs 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 ongoing costs to maintain, calibrate, 

and operate the purchased monitoring equipment, rent monitoring 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 are $1.4 million. This is the total 

of column E in the above table. The annual O&M costs for 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, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 
14

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

$1,029,658. In subsequent years, the agency costs will be lower 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 Management (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 employees. Details upon which this 

estimate is based appear in Tables 1.C through 3.C of Attachment C. 

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

 

 Based on the regulatory database used to estimate the impacts 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 period 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 4,004
15

The number of Total Annual Responses is 4,004 responses over the three-year period, or 

1,335 responses per year (rounded). 

The total labor costs are $113.5 million or $37.8 million per year. Details regarding these 

estimates may be found in Tables 1.A through 3.B of Attachments A and B. 

6(e) Bottom Line Burden Hours 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.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 three-year period, or an average 

of 180,512 hours per year. Details regarding these estimates may be found in Tables A1 through 

B3 of Attachment A. Furthermore, the annual public reporting and recordkeeping burden for this 

collection of information is estimated to average 466hours per response. 

The total annual capital/startup and O&M costs to the regulated 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/Startup vs. Operation and Maintenance 

(O&M) Costs. 

(ii) The Agency Tally 

The average annual agency burden and cost over next three years 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 Compliance Times for Municipal Solid Waste 

Landfills and is considered new burden. 

6(g) Burden Statement 

The annual reporting and recordkeeping burden for this collection 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 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 
16

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information. 

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. 

 To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-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 Docket Center (EPA/DC), EPA West, 

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

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

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

number for the docket center is (202) 566-1927. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-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 methods were used in collecting this 

information.