1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
(
EPA)
STANDARDS
OF
PERFORMANCE
NSPS
Subpart
WWW
Municipal
Solid
Waste
Landfills
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NSPS
Subpart
WWW
Standards
of
Performance
for
Municipal
Solid
Waste
Landfills.
This
is
a
currently
approved
collection
that
has
been
assigned
EPA
tracking
number
1557.04.
The
Information
Collection
Request
(
ICR)
was
approved
under
OMB
Control
number
2060­
0220.

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
municipal
solid
waste
landfills
were
proposed
on
May
30,
1991
and
promulgated
on
March
12,
1996.
These
standards
apply
to
municipal
solid
waste
landfills
for
which
construction,
modification,
or
reconstruction
commences
on
or
after
May
30,
1991.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60
Subpart
WWW.

Owners
and
operators
of
the
affected
facilities
must
make
initial
reports
when
a
source
becomes
subject
to
this
standard:
(
1)
to
conduct
and
report
on
performance
tests,
(
2)
report
of
annual
or
periodic
emission
rates,
(
3)
report
on
design
plans,
(
4)
report
on
equipment
removal
and
closure,
(
5)
maintain
records
of
the
reports,
system
design
and
performance
tests,
monitoring
and
exceedances,
plot
map,
and
well
locations.
The
record
keeping
and
reporting
requirements
specific
to
municipal
solid
waste
landfills
are
detailed
in
section
4(
b)
"
Information
Collected"
of
this
supporting
statement.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
2
Part
60,
Subpart
WWW.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
the
applicable
reporting
and
record
keeping
requirements
for
at
least
5
years
following
the
collection
of
such
measurements,
maintenance
reports,
and
records.
Approximately
175
sources
are
currently
subject
to
the
standard,
which
includes
sources
that
will
become
subject
to
the
standard
in
the
next
3
years.
The
cost
of
this
ICR
will
be
$
107,000.

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
EPA
Regional
Office.

2.
Need
for
and
Use
of
the
Collection
TERMS
OF
CLEARANCE:
The
agency
has
updated
estimates
of
wages,
as
appropriate,
to
reflect
overhead
in
a
manner
consistent
with
guidance.
Furthermore,
the
agency
should
clarify
the
method
by
which
the
estimate
of
the
number
of
sources
has
been
updated.

2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
section
111
of
the
Clean
Air
Act
(
Act),
as
amended,
to
establish
standards
of
performance
for
new
stationary
sources
that
reflect:

...
application
of
the
best
technological
system
of
continuous
emission
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emission
reduction,
any
non­
air
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated
[
section
111(
a)(
1)].

EPA
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).
Section
111
also
requires
that
the
Administrator
review
and,
if
appropriate,
revise
such
standards
every
4
years.

In
addition,
Section
114(
a)
states
that:
3
.
.
.
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to
(
A)
establish
and
maintain
such
records,
(
B)
make
such
reports,
(
C)
install,
use,
and
maintain
such
monitoring
equipment
or
methods
(
in
accordance
with
such
methods
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
D)

sample
such
emissions,
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical,
(
F)
submit
compliance
certifications,
and
(
G)
provide
such
other
information
as
may
reasonably
required.

In
the
Administrator's
judgment,
methane,
carbon
dioxide,
and
nonmethane
organic
gas
compound
emissions
from
municipal
solid
waste
landfills
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NSPS
were
promulgated
for
this
source
category
at
40
CFR
Part
60
Subpart
WWW.

2(
b)
Practical
Utility/
Users
of
the
Data
The
operation
of
municipal
solid
waste
landfills
causes
the
emission
of
methane,
carbon
dioxide,
and
nonmethane
organic
gas
compound
emissions.
The
control
of
emissions
of
methane,

carbon
dioxide,
and
nonmethane
organic
gas
compound
emissions
from
municipal
solid
waste
landfills
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
proper
operation
and
maintenance
of
that
equipment.
These
standards
rely
on
the
capture
and
reduction
of
methane,

carbon
dioxide,
and
nonmethane
organic
gas
compound
emissions
by
combustion
devices
(
boilers,

internal
combustion
engines,
or
flares).

The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
4
pollution
control
devices
are
properly
installed
and
operated
and
the
standard
is
being
met.

Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
information
generated
by
the
monitoring,
record
keeping,
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
to
operate
the
control
equipment
and
achieve
compliance
with
the
regulation.

Adequate
monitoring,
record
keeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Act.
The
information
collected
from
record
keeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
record
keeping
and
reporting
is
required
under
40
CFR
Part
60,
Subpart
WWW.
If
the
standard
has
not
been
delegated,
the
information
is
sent
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
their
own
similar
regulation
to
implement
the
federal
regulation,
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
standard.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
January
30,
2002
(
67
FR
4421).

3(
c)
Consultations
5
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.
The
number
of
landfills
subject
to
the
rule
was
based
on
EPA's
Office
of
Solid
Waste
data
on
the
number
and
size
distribution
of
existing
landfills
and
projections
of
the
annual
number
of
landfills
that
would
close
and
be
replaced
by
new
landfills.
The
data
and
analyses
are
described
in
the
following
three
documents:

Federal
Register
preamble
for
the
final
Subpart
WWW
rule
(
61
FR
9905,
March
12,
1996
);
Air
Emissions
for
Municipal
Solid
Waste
Landfills
­
Background
Information
for
Final
Standards
and
Guidelines
(
EPA­
453/
R­
94­
021
EPA/
OAQPS.
December
1995);
and
Air
Emissions
from
Municipal
Solid
Waste
Landfills
­
Background
Information
for
Proposed
Standards
and
Guidelines
(
EPA­
450/
3­
90­
011a
EPA/
OAQPS.
March
1991).

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
standards.
Requirements
for
information
gathering
and
record
keeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
the
reporting
or
record
keeping
requirements
contained
in
40
CFR
Part
60
,
Subpart
WWW
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
6
determined
not
to
be
private.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,

Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
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
None
of
the
reporting
or
record
keeping
requirements
contained
in
40
CFR
Part
60,
Subpart
WWW
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
record
keeping
and
reporting
requirements
are
municipal
solid
waste
landfills
subject
to
NSPS
Subpart
WWW,
Standards
of
Performance
for
Municipal
Solid
Waste
Landfills.
The
SIC
codes
include:
9511,
air
and
water
resources
and
solid
waste
management,
and
4953,
refuse
systems.

4(
b)
INFORMATION
REQUESTED
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
60
Subpart
WWW.
Records
are
required
to
be
retained
for
5
years.
7
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Regulation
reference
Record
keeping
Records
of
maximum
design
capacity,
refuse­
in­
place,
year­
by­
year
waste
acceptance
rate
(
maintain
for
5
years)
60.758(
a)

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)
60.758(
b)

Records
of
monitoring
(
maintain
for
5
years)
60.758(
c)

Records
of
a
plot
map
and
well
locations
for
the
life
of
the
landfill
(
maintain
for
life
of
collection
system)
60.758(
d)

Records
of
collection
and
control
system
exceedances
(
maintain
for
5
years)
60.758(
e)

Reporting
Report
of
initial
design
capacity
60.757(
a)

Report
of
annual
or
periodic
NMOC
emission
rate
60.757(
b)

Collection
and
control
system
design
plan
60.757(
c)

Report
of
initial
performance
test
results
and
annual
reports
60.757(
f)

Report
of
landfill
closure
60.757(
d)

Report
of
equipment
removal
60.757(
e)

(
ii)
Respondent
Activities
Respondent
activities
include
the
following
items:
8
1.
Complete
Applications
2.
Perform
Surveys
and
Studies
3.
Reporting
Requirements:
A.
Read
Instructions
B.
Required
Activities
­
Initial
performance
test
report
­
Annual
compliance
report
­
Quarterly
surface
methane
monitoring
­
Purchase
of
portable
monitor
($
8,100
each)
C.
Gather
Existing
Information
D.
Acquire
required
information
in
cases
where
it
has
not
been
gathered
before
E.
Write
Report
­
Initial
design
capacity
report
­
Annual
report
of
NMOC
flow
rate
(
Tier­
1
calculation)
­
Report
of
Tier
2
and
3
sampling
­
Report
of
Initial
performance
test
­
Annual
compliance
report
4.
Record
keeping
Requirements
A.
Read
Instructions
B.
Plan
Activities
C.
Implement
Activities
D.
Develop
Record
System
E.
Time
to
Enter
Information
­
Records
of
control
system
monitoring
­
Records
of
accumulated
refuse
F.
Time
to
Train
Personnel
G.
Time
for
Audits
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
information
required
under
40
CFR
Subpart
WWW:

­
Review
initial
design
capacity
report
­
Review
report
of
initial
performance
test
9
­
Observe
initial
performance
tests
­
Review
annual
NMOC
emission
rate
report
­
Review
Tier
2
and
Tier
3
calculations
­
Review
annual
compliance
report
­
Incur
travel
expenses
for
tests
attended
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
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
note
the
operating
conditions
(
temperature
or
specific
flow
requirement)
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.

Information
contained
in
the
reports
is
entered
into
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
is
EPA's
database
for
the
collection,

maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.

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

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
5
years.

5(
c)
Small
Entity
Flexibility
There
are
no
small
businesses
affected
by
this
standard.
10
5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
each
of
the
record
keeping
and
reporting
requirements
applicable
to
the
industry.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.

Responses
to
this
information
collection
are
mandatory
under
40
CFR
Part
60
Subpart
WWW.
The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
3
years
from
these
record
keeping
and
reporting
requirements
is
estimated
at
3,390
person­
hours.
These
numbers
were
derived
from
estimates
based
on
modeling
analyses
performed
to
estimate
the
nationwide
control
costs
of
the
rule,

EPA's
experience
with
other
standards,
and
the
previously
approved
ICR.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
Labor
rates
and
associated
costs
in
Table
1
are
based
on
the
Comprehensive
Assessment
and
Information
Rule
(
CAIR)
economic
analysis,
and
estimated
hourly
rates
are
as
follows:
technical
at
$
57.12,
management
at
$
85.81,
and
clerical
at
$
36.27.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
11
The
industry
cost
associated
with
the
information
collection
activity
in
the
standards
is
the
cost
of
the
portable
methane
monitors
for
performing
surface
methane
concentration
testing.
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
The
capital
start
up
costs
for
this
regulation
are
$
105,300.
This
is
based
on
13
new
sources
per
year
multiplied
by
$
8,100
per
monitor,
using
a
7%
annual
interest
rate
and
a
3­
year
service
life
(
the
capital
recovery
rate
is
.381).
The
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs
of
$
1,530
per
year.
The
average
annual
burden
for
capital
and
operations
and
maintenance
costs
to
industry
over
the
next
3
years
of
the
ICR
is
estimated
to
be
$
106,830.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Monitoring
device
Start
Up
Cost
($)
Annual
O&
M
Costs
($)

portable
methane
monitor
$
8,100
$
1,530
(
rounded:
2,000)

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.

Publication
and
distribution
of
the
information
are
part
of
the
AIRS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
federal
government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
29,411
(
from
Table
2).
This
cost
is
based
on
an
average
wage
of
a
GS­
10
step
1
employee
rate
and
travel
associated
with
compliance
activities.
Details
upon
which
this
estimate
is
based
12
appear
in
Table
2:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
new
sources
subject
to
40
CFR
Subpart
WWW
is
175.
The
total
annual
labor
costs
are
$
144,453
and
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
106,830.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
Please
see
Tables
1
and
2.
13
TABLE
1.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
MUNICIPAL
SOLID
WASTE
LANDFILLS
NSPS
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
C
x
D)
(
F)
Management
person­
hours
per
year
(
E
X
0.05)
(
G)

Clerical
personhours
per
year
(
E
x
0.1)
(
H)

Cost
per
year
($)
a
1.
Applications
2.
Surveys
and
Studies
3.
Reporting
Requirements
A.
Read
Instructions
b
B.
Required
Activities
­
Initial
performance
test
report
b
­
Annual
compliance
report
­
Quarterly
surface
methane
monitoring
­
Purchase
of
portable
monitor
b
($
8,100
each)

C.
Create
Information
b
D.
Gather
Existing
Information
E.
Write
Report
­
Initial
design
capacity
report
b
­
Annual
report
of
NMOC
flow
rate
(
Tier­

1
calculation)

­
Report
of
tier
2
and
3
sampling
b
­
Report
of
Initial
performance
test
b
­
Annual
compliance
report
4.
Recordkeeping
Requirements
A.
Read
Instructions
B.
Plan
Activities
C.
Implement
Activities
D.
Develop
Record
System
N/
A
N/
A
1
2
2
14
See
3B
See
3E
2
2
12
See
3B
See
3B
See
3A
N/
A
N/
A
N/
A
1
1
1
4
1
1
1
1
2
2
56
2
2
12
175
13
13
13
175
18
31
175
26
26
728
350
36
372
8.75
1.3
1.3
36.4
17.5
1.8
18.6
17.5
2.6
2.6
72.8
35
3.6
37.2
11,381.57
1,690.97
1,690.97
47,347.30
107,000
22763.13
2,341.35
24,193.95
14
TABLE
1.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORD
KEEPING
REQUIREMENTS
OF
THE
MUNICIPAL
SOLID
WASTE
LANDFILLS
NSPS
(
CONTINUED)

Burden
item
(
A)

Personhours
per
occurrence
(
B)
Occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
C
x
D)
(
F)
Management
person­
hours
per
year
(
E
X
0.05)
(
G)

Clerical
personhours
per
year
(
E
x
0.1)
(
H)

Cost
per
year
($)
a
E.
Time
to
Enter
Information
­
Records
of
control
system
monitoring
­
Records
of
accumulated
refuse
F.
Time
to
train
personnel
G.
Time
for
Audits
TOTAL
BURDEN
AND
COST
0.5
8
N/
A
12
1
6
8
13
18
78
144
1,935
3.9
7.2
97
7.8
14.4
194
3822
7056
111,409
a.
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
57.12,
management
at
$
85.81,
and
clerical
at
$
36.27.

b.
One­
time
only
burden.

C.
The
estimated
purchased
cost
of
each
portable
monitor
is
$
8,100
and
the
estimated
service
life
is
expected
to
be
about
3
years.
The
annualized
capital
cost
was
estimated
using
an
interest
rate
of
7%.

Average
annual
burden
for
3
years:

Year
Technical
Management
Clerical
Cost
of
portable
Total
1
1,935
97
194
­
­
2,226
(
one­
time
+
recurrent
burden)

2
1,935
97
194
­
­
2,226
(
one­
time
+
recurrent
burden)

1,012
51
101
­
­
1,164
(
first
year
respondent's
second
year
annual
burden)

3
1,935
97
194
­
­
2,226
(
one­
time
+
recurrent
burden)

1,012
51
101
­
­
1,164
(
first
year
respondent's
third
year
annual
burden)

1,012
51
101
­
­
1,164
(
Second
year
respondent's
second
year
annual
burden)

8,841
444
885
­
­
10,170
Total
Hour
Burden
Over
3
years
2947
148
295
­
­
3,390
Average
Annual
Burden
for
3
years
$
168,333
$
12,700
$
10,700
$
107,000
$
272,733
Average
Annual
cost
Burden
for
3
Years
15
TABLE
2.
ANNUAL
BURDEN
AND
COST
FOR
THE
FEDERAL
GOVERNMENT
Activity
(
A)

EPA
hours
per
occurrenc
e
(
B)
Occurrenc
es
per
responden
t
per
year
(
C)

Personhours
per
responden
t
per
year
(
A
X
B)
(
D)
Responden
ts
per
yeara
(
E)
Technical
personhours
per
year
C
X
D)
(
F)
Managemen
t
personhours
per
year
(
E
x
0.05)
(
G)
Clerical
personhours
per
year
(
E
x
0.1)
(
H)

Cost
per
year
($)
b
Review
initial
design
capacity
report
2
1
2
175
350
17.5
35
$
16,783.55
Review
report
of
initial
performance
test
8
1
8
13
104
5.2
10.4
4,987.11
Observe
initial
performance
testsc
24
1
24
1
24
1.2
2.4
1,393.29
Review
annual
NMOC
emission
rate
report
2
1
2
18
36
1.8
3.6
1726.31
Review
Tier
2
calculationsd
2
1
2
18
36
1.8
3.6
1,726.31
Review
Tier
3
calculationse
2
1
2
13
26
1.3
2.6
1,246.78
Review
annual
compliance
report
1
1
1
13
13
0.65
1.3
623,39
Travel
expenses
for
tests
attendedc,
f
550
TOTAL
BURDEN
AND
COST
590
29.5
58.9
28,486.74
aAssume
an
average
of
175
new
or
reconstructed
facilities
per
year
(
872
in
the
first
5
years).

bCosts
are
based
on
the
following
hourly
rates:
technical
at
$
38.30,
management
at
$
51.62,
and
clerical
at
$
70.72.
cAssume
EPA
personnel
attend
about
8
percent
of
initial
performance
tests.

dAssume
all
landfills
submitting
NMOC
emission
rate
reports
will
perform
Tier
2
calculations.

eAssume
the
number
of
landfills
performing
Tier
3
calculations
is
75%
of
the
number
performing
Tier
2
16
6(
f)
Reasons
for
Change
in
Burden
There
is
a
change
in
burden
of
an
additional
three
respondents
anticipated
from
the
last
ICR
approval.
The
universe
of
respondents
affected
by
the
rule
is
not
expected
to
change
significantly
in
the
projected
3
year
effective
period
of
this
ICR.

6(
g)
Burden
Statement
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
by
mail
or
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
Mail
Code
2822T),
1200
Pennsylvania
Avenue,

NW,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,

Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
17
ATTENTION:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
