SUPPORTING STATEMENT 

ENVIRONMENTAL PROTECTION AGENCY 

NSPS Review for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart XXX) 

1. Identification of the Information Collection 

1(a) Title of the Information Collection 

NSPS Review for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart XXX) EPA 

ICR Number 2498.01, OMB Control Number [to be assigned]. 

1(b) Short Characterization/Abstract 

The New Source Performance Standards (NSPS) for Municipal Solid Waste Landfills 

were proposed on May 30, 1991, promulgated on May 12, 1996, and amended on June 16, 1998 

(63 FR 32753), February 24, 1999 (64 FR 9262), and April 10, 2000 (65 FR 18909). These 

standards apply to municipal solid waste landfills that commenced construction, modification, or 

reconstruction on or after May 30, 1991. 

Clean Air Act (CAA) section 111(b)(1)(B) requires the EPA to “at least every 8 years 

review and, if appropriate, revise” new source performance standards. In response to this 

mandate, EPA is proposing a new subpart that will apply to municipal solid waste landfills that 

commenced construction, modification, or reconstruction on or after the date the proposed new 

subpart XXX is published in the Federal Register. 

This proposed subpart includes provisions reducing the NMOC emission rate threshold that 

triggers the requirement to install controls to 40 megagrams per year (Mg/yr) from the current 

NSPS level of 50 Mg/yr (see 40 CFR part 60 subpart WWW). The proposed option retains the 

design capacity cutoff of 2.5 million Mg and 2.5 million cubic meters in the current NSPS. The 

proposed option is hereinafter referred to as “option 2.5/40.” This information is being collected 

to assure compliance with the proposed 40 CFR part 60 subpart XXX. 

In general, the landfills NSPS require initial notifications, performance tests, periodic 

reports, design plans, equipment removal reports, and closure reports by the owners/operators of 

the affected sources. They are also required to maintain records of 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, as well as maintain records of the reports, system 

design, performance tests, monitoring, exceedances, plot map, and well locations. The 

recordkeeping and reporting requirements specific to municipal solid waste landfills are detailed 

in Section 4(b) of this supporting statement. These notifications, reports, and records are 

essential in determining compliance and are required of all affected facilities subject to the 

NSPS. 

Any owner or operator subject to the provisions of proposed subpart XXX will maintain a 

file of these measurements, and retain the file for at least five years following the date of such 
2

measurements, maintenance reports, and records. All reports are sent to the delegated state or 

local authority. In the event that there is no such delegated authority, the reports are sent directly 

to the United States Environmental Protection Agency (EPA) regional office. 

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

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

owner/operator of the plant site). 

It is estimated that on average, five respondents per year will become subject to the 

regulation in the next three years based on a design capacity threshold of at least 2.5 million Mg 

or cubic meters. 

Approximately 17 new municipal solid waste facilities, which are owned and operated by 

the municipal solid waste industry (the “Affected Public”), would be subject to the regulation 

over the next three years. The cost of this Information Collection Request (ICR) will be 

$118,000 (rounded). It is unknown whether public or private sectors will own or operate new 

landfills expected to be subject to proposed subpart XXX; however, given the trend towards 

private ownership, it is estimated that all of the respondents in the next three years will be in the 

private sector. 

The burden to the “Affected Public” may be found in Tables 1.A through 1.C in 

Attachment A. The burden to the “Federal Government” is attributed entirely to work performed 

by federal employees or government contractors or to state or local agencies that have been 

delegated authority; this burden may be found in Tables 2.A through 2.C of Attachment B. 

2. Need for and Use of the Collection 

2(a) Need/Authority for the Collection 

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

establish standards of performance for new stationary sources that reflect: 

. . . the degree of emission limitation achievable through the 

application of the best system of emission reduction which (taking 

into consideration the cost of achieving such emissions reduction, 

or any non-air quality health and environmental impact and energy 

requirements) the Administrator determines has been adequately 

demonstrated. Section 111(a)(l). 

The EPA refers to this charge as selecting the best system of emission reduction (BSER) 

Section 111 also requires that the Administrator review and, if appropriate, revise such standards 

every eight years. 

In addition, CAA section 114(a) states that the Administrator may require any 

owner/operator subject to any requirement of this CAA to: 
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(A) Establish and maintain such records; (B) make such reports; 

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

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

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

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require. 

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 NSPS were promulgated for this source category at 40 

CFR part 60, subpart WWW and a review of these NSPS are being proposed under new subpart 

XXX. 

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

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

installed and operated, that leaks are being detected and repaired, and that the 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. Non-duplication, Consultations, and Other Collection Criteria 

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

XXX. 
4

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, 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 NSPS Review 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 database maintained by EPA’s Landfill Methane Outreach Program (LMOP), 

voluntary data submitted to the EPA by the landfill industry as part of this NSPS review, and 

data from 40 CFR part 98, subpart HH of the EPA Greenhouse Gas Reporting Program. 

Based on these data sources, a consolidated database of 21 model landfills was created. 

The growth rate for the industry and attributes for the these model landfills are based on the 

assumption that the sizes and locations of landfills opening in the most recent complete 8 years 

of data (2003-2010) from the above three data sources would be similar to landfills opening in 

the next 8 years (2011-2018). A subset of these model landfills, those opening over the next five 

years (2014-2018) are expected be subject to subpart XXX and are included in the burden 

estimates for this ICR. 

Given the numerous reporting and recordkeeping similarities between proposed subpart 

XXX and the currently promulgated NSPS subpart WWW, many of the line item burden 

estimates in this ICR estimate are the same as the burdens currently approved under ICR number 

1557.08 for subpart WWW. For the most recent subpart WWW ICR renewal, industry trade 

associations and other parties were provided an opportunity to comment on the burden associated 

with the standard and EPA consulted with two trade groups: the Solid Waste Association of 

North America (SWANA) at (240) 494-2241, and the National Solid Waste Management 

Association at (202) 364-3773. 

The public will also 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. 
5

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

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

questions. 

4. The Respondents and the Information Requested 

4(a) Respondents/NAICS Codes 

The respondents to the recordkeeping and reporting requirements are municipal solid 

waste landfills which correspond to the North American Industry Classification System (NAICS) 
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924110 for Air and Water Resources and Solid Waste Management, and NAICS 562212 for 

Solid Waste Landfill. 

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 

In this ICR, all data recorded and/or reported are required by NSPS for Municipal Solid 

Waste Landfill (40 CFR Part 60, proposed Subpart XXX) and the general provisions of Part 60. 

A source must make the following reports: 

Reports Standard Citation 

by Section 

Initial design capacity report 60.7(a)(1), 60.767(a) 

Notification of actual startup 60.7(a)(3) 

Initial and annual (or 5-year) non-methane organic compounds 

(NMOC) emission rate reports 60.767(b) 

Initial and revised collection and control system design plans 60.767(c) , 60.767(h) 

Landfill closure report 60.767(d) 

Equipment removal report 60.767(e) 

Initial performance test report and annual operations reports 60.8, 60.767(f), 

60.767(g) 

A source must keep the following records: 

Recordkeeping 

Maintain records of maximum design capacity, refuse-in-place, yearby-year waste acceptance rate (maintain for 5 years) 60.768(a) 

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) 

60.768(b) 

Maintain records of monitoring for five years 60.768(c) 

Maintain records of plot map and well locations for the life of the 

landfill (for life of the collection system) 60.768(d) 

Maintain records of collection and control system exceedances for 5 

years 60.768(e) 

Maintain records of annual recalculation of site-specific density and 

design capacity 60.768(f) 
7

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. 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. Further, most of the methods in the landfills NSPS 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. 

Perform initial performance test, Reference Method 25, 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. 
8

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 

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. 

Input, analyze, and maintain data in Air Facility System (AFS). 

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 entered into the AFS which is operated and 

maintained by EPA's Office of Compliance. EPA uses the AFS 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, this 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 
9

Although it is unknown how many new landfills will be owned or operated by small 

entities, recent trends in the waste industry have been towards consolidated ownership among 

larger companies. The EPA has determined that approximately 10 percent of the existing 

landfills subject to similar regulations (40 CFR Part 60 subparts WWW and Cc or the 

corresponding State or Federal plan) are small entities. 

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

small entities. However, the proposed design capacity threshold of 2.5 million megagrams limits 

the effect of this regulation on smaller landfills which tend to be owned by disproportionately 

owned by smaller entities. 

5(d) Collection Schedule 

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

shown in Tables 1.A-1.C of Attachment A. 

6. Estimating the Burden and Cost of the Collection 

Tables 1.A through 1.C of Attachment A document the computation of individual 

burdens for the recordkeeping and reporting requirements applicable to the industry for the 

subpart included in this ICR. The individual burdens are expressed under standardized headings 

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 409 labor hours for the proposed option 2.5/40 

(Total Labor Hours from Tables 1.A through 1.C). During this initial three-year ICR period, 

there will be no controlled landfills. Controls are not anticipated to be installed until 2020 and 

therefore the reporting and records associated with controlled landfills are included as line items 

for completeness, but are not estimated for this period. These hours are based on EPA studies 

and background documents from the development of the regulation, EPA knowledge and 

experience with the NSPS 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: 
10

Managerial $109.43 ($52.11 + 110%) 

Technical $ 84.95 ($40.45 + 110%) 

Civil Engineer Technician $ 48.69 ($23.66 + 110%) 

Clerical $ 29.55 ($14.07 + 110%) 

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

May 2012, 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. 

(ii) Estimating Capital/Startup and Operation and Maintenance 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 conducting a Tier II NMOC emission rate test. The capital/startup costs are onetime costs when a facility becomes subject to the regulation. The capital costs have been 

annualized over the five-year period allowed before another Tier II test must be conducted. 

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 is rented and not purchased. Further, no 

landfills are expected to install controls during the first three years of this ICR period and 

therefore there is not any capital costs associated with monitoring at controlled sites. 

The annual operation and maintenance costs are the ongoing costs to maintain the 

monitor and other costs such as photocopying and postage, which are expected to be minimal 

compared to the other reporting and recordkeeping costs for this proposed rule. 

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

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

(A) 

Continuous 

Monitoring 

Device 

(B) 

Capital/Startup 

Cost for One 

Respondent

(C) 

Annualized 

Capital/Sta

rtup Cost 

for One 

Respondent 

(D) 

Average 

Number of 

New 

Respondent

s per Year

(E) 

Total 

Capital / 

Startup 

Cost, (C X 

D) per Year

(F) 

Annual 

O&M Costs 

for One 

Respondent

(G) 

Number of 

Respondents 

with O&M

(H) 

Total 

O&M, 

(F X G)

Sampling probe 

and Method 25 

or 25C testing 

costs

$10,067 $2,455 2.5 $6,138 $0 0 $0 

The average annualized capital/startup costs for this ICR are $6,138. This is the total of 

column E in the above table. 
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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 

$127,888. In subsequent years, the agency costs will be slightly higher because it will require 

more landfills to install controls beginning in 2020, and it is expected that more inspections will 

occur at these controlled landfills. 

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

Managerial $62.90 (GS-13, Step 5, $39.61 + 60%) 

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

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

These rates are from the Office of Personnel Management (OPM), 2014 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 2.A through 2.C of Attachment B. 

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

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

five existing respondents per will become subject to the standard under the proposed option 

2.5/40 based on exceeding the design capacity threshold of at least 2.5 million Mg or cubic 

meters. It is estimated that an additional two respondents will submit a one-time design capacity 

report in the first year of this ICR to demonstrate they are below the design capacity threshold. 

The overall average number of respondents, as shown in the table below is 12 per year. 

The number of respondents is calculated using the following table, which addresses the 

three years covered by this ICR. 

Number of Respondents 

Year 

(A) 

Number of 

New 

Respondents1

(B) 

Number of 

Existing 

Respondents 

(C) 

Number of Existing 

Respondents That 

Keep Records But 

Do Not Submit 

Reports 

(D) 

Number of Existing 

Respondents That 

Are Also New 

Respondents 

(E) 

Number of 

Respondents 

(E=A+B+C-D) 

1 9 0 0 0 9 

2 2 7 2 0 11 

3 6 9 2 0 17 

Average 5.7 5.3 1.3 0 12.3 
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1 New respondent include sources with constructed, reconstructed and modified affected facilities. 

To avoid double-counting respondents, column D is subtracted. As shown above, the 

average Number of Respondents over the three-year period of this ICR is 12. 

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 2 1 N/A 2 

Report of NMOC rate (Tier 1) 15.5 1 N/A 15.5 

Report of NMOC rate (Tier 2) 7.5 1 N/A 7.5 

Landfill Closure Report 0 1 N/A 0 

Equipment Removal Report 0 1 N/A 0 

Collection and Control System Design 

Plan 0 1 N/A 0 

Initial Performance Test Report 0 1 N/A 0 

Annual Report 0 1 N/A 0 

Total Number of Annual Responses 25 

The number of Total Annual Responses is 25 responses over the three-year period, or 8 

responses per year (rounded). 

The total labor costs are $99,534, or $33,178 per year. Details regarding these estimates 

may be found in Tables 1.A through 1.C of Attachment A. 

6(e) Bottom Line Burden Hours and Cost Tables 

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

agency are shown in Tables 1.A through 2.C of Attachment A and Tables 2.A through 2.C of 

Attachment B and summarized below. 

(i) Respondent Tally 

The total annual labor hours are 1,226 over this initial three-year period, or an average of 

409 hours per year. Details regarding these estimates may be found in Tables 1.A through 1.C of 

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

collection of information is estimated to average 51 hours per response. 
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The total annual capital/startup and O&M costs to the regulated entity are $18,414 over 

the three-year period or an average of $6,138 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 each compliance 

option is estimated to be 2,810 labor hours at a cost of $127,888. See Tables 2.A through 2.C of 

Attachment B.

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 

NSPS Review for Municipal Solid Waste Landfills and is considered new burden. 

6(g) Burden Statement 

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

for the proposed option 2.5/40 is estimated to average 51 hours per response. Burden means the 

total time, effort, or financial resources expended by persons to generate, maintain, retain, 

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

To comment on the EPA'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 the proposed NSPS 

Review for Municipal Solid Waste Landfills under Docket ID Number EPA-HQ-OAR-2003-

0215. 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), WJC 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 
14

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-2003-0215 and ICR 

Number 2498.01 in any correspondence. 

Part B of the Supporting Statement 

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

information.