STANDARD
FORM
83
SUPPORTING
STATEMENT
ICR
No.
1938.02
­­
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
FROM
MUNICIPAL
SOLID
WASTE
LANDFILLS
(
SUBPART
AAAA)

U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Research
Triangle
Park,
NC
27711
July
2002
1
PART
A
OF
THE
SUPPORTING
STATEMENT
FOR
STANDARD
FORM
83
Municipal
Solid
Waste
Landfills
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
(
a)
Title
of
the
Information
Collection.

"
Reporting
and
Recordkeeping
Requirements
for
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
from
Municipal
Solid
Waste
(
MSW)
Landfills."
The
ICR
Number
is
1938.02.

(
b)
Characterization
of
Information
Collection.

These
standards
regulate
emissions
of
hazardous
air
pollutants
(
HAP)
from
certain
MSW
landfills.
The
HAP
emitted
from
landfills
come
from
fugitive
emissions
that
can
be
captured
for
control.

Although
Subpart
AAAA
applies
to
all
landfills
at
major
sources
and
some
landfills
at
area
sources,
the
only
MSW
landfills
that
will
be
required
to
apply
controls
and
submit
reports
by
these
standards
are
landfills
that:
(
1)
have
a
design
capacity
of
2.5
million
megagrams
(
Mg)
and
2.5
million
cubic
meters
(
m3),
and,
(
2)
emit
equal
to
or
greater
than
50
tons
per
year
of
nonmethane
organic
compounds
(
NMOC)
or
operate
as
bioreactors.
Because
these
standards
specifically
regulate
HAP,
no
MSW
landfill
will
be
subject
to
the
requirements
of
this
NESHAP
unless
it
meets
these
emission
requirements.
In
these
standards,
NMOC
are
used
as
a
surrogate
for
HAP,
because
many
NMOC
are
also
HAP
and
NMOC
are
easier
to
measure
than
a
host
of
individual
HAP.

Landfills
of
this
size
and
NMOC
emission
level
are
currently
subject
to
NMOC
emission
control
under
the
Emission
Guidelines
(
EG)
and
New
Source
Performance
Standards
(
NSPS)

for
MSW
Landfills,
promulgated
on
March
12,
1996.
No
new
emission
control
requirements
will
be
imposed
on
these
landfills
by
these
standards,
although
bioreactors
may
be
required
to
apply
control
sooner
than
under
the
NSPS/
EG.
2
This
NESHAP
will
ensure
that
affected
sources
are
held
accountable
for
reducing
their
HAP
emissions,
by
requiring
them
to
provide
EPA
with
certain
records
and
reports
beyond
those
required
by
the
EG/
NSPS.

Each
owner
or
operator
of
an
MSW
landfill
affected
by
the
standard
would
be
required
to
submit
semiannual
compliance
reports
for
control
device
operating
parameters.

Owners
and
operators
of
affected
facilities
will
also
have
to
prepare
a
startup,
shutdown,
and
malfunction
(
SSM)
plan
and
prepare
semiannual
SSM
reports.

This
information
is
being
collected
by
EPA
in
order
to
ensure
that
affected
sources
meet
the
HAP
emission
control
requirements
specified
in
this
regulation.
It
will
be
stored
and
used
by
the
EPA
and
by
State
regulatory
agencies.

Collection
and
storage
of
information
may
be
in
either
paper
(
hardcopy)
or
electronic
formats.
This
information
collection
is
for
an
average
of
1,310
respondents
and
an
average
total
industry
cost
of
$
2,137,687
over
the
first
3
year
period
after
promulgation.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
(
a)
Need/
Authority
for
the
Collection.

The
EPA
needs
this
information
to
ensure
that
HAP
emissions
are
reduced
in
the
processes
and
operations
at
MSW
landfills.
The
EPA
is
required
under
section
112(
d)
of
the
Clean
Air
Act
(
CAA)
to
regulate
emissions
of
the
HAP
listed
in
section
112(
b)
of
the
CAA.
The
HAP
identified
by
EPA
as
being
emitted
from
MSW
landfills
include,
but
are
not
limited
to,
vinyl
chloride,
benzene,
toluene,
xylene,

methylene
chloride
(
dichloromethane),
methyl
chloroform
(
1,1,1­
trichloroethane),
methyl
ethyl
ketone
(
MEK),
mercury,

and
methyl
isobutyl
ketone
(
MIKB).

In
the
Administrator's
judgment,
HAP
emissions
from
MSW
landfills
cause
or
contribute
significantly
to
air
pollution
3
that
may
reasonably
be
anticipated
to
endanger
public
health.
Consequently,
NESHAP
for
this
source
category
have
been
developed.

Section
114
of
the
CAA
allows
the
Administrator
to
require
inspections,
monitoring,
and
entry
into
facilities
to
ensure
compliance
with
a
section
112
emission
standard.

Section
114(
a)(
1)
specifically
states:

"
The
Administrator
may
require
any
person
who
owns
or
operates
any
emission
source...
who
is
subject
to
the
provisions
of
the
CAA
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;

(
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."

Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
identify
sources
subject
to
the
standard
and
to
ensure
that
the
standard,
which
is
based
on
a
maximum
achievable
control
technology
(
MACT),
is
being
achieved.

(
b)
Practical
Utility/
Users
of
the
Data.

The
information
will
be
used
by
EPA
to:
(
1)
ensure
that
subpart
AAAA
is
being
properly
applied;
(
2)
ensure
that
the
sources
are
complying
with
emission
standards
on
a
continuous
basis
through
proper
operation
and
maintenance
of
the
emission
control
device;
and
(
3)
ensure
that
appropriate
4
procedures
are
being
followed
during
startup,
shutdown,
and
malfunction
events.

Records
and
reports
are
necessary
to
enable
EPA
to
identify
MSW
landfills
that
may
not
be
in
compliance
with
these
standards.
Based
on
reported
information,
EPA
will
decide
which
MSW
landfills
should
be
inspected
and
what
records
or
systems
should
be
inspected
at
the
facilities.

The
records
that
MSW
landfills
maintain
will
indicate
to
EPA
whether
landfill
personnel
are
operating
and
maintaining
control
equipment
properly.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
(
a)
Nonduplication.

The
EPA
does
not
anticipate
duplication
in
reporting
of
MSW
landfill
monitoring
data.
Landfills
regulated
under
this
NESHAP
will
also
be
subject
to
several
recordkeeping
and
reporting
requirements
under
the
EG
or
NSPS
for
MSW
landfills
(
40
CFR
part
60,
subparts
Cc
or
WWW).
The
burden
requested
for
this
NESHAP
does
not
duplicate
any
of
the
burden
accounted
for
in
the
recordkeeping
and
reporting
requirements
under
the
EG/
NSPS.
These
standards
will
require
new
records
and
reports
from
affected
sources,
that
is,
the
development
of
a
startup,
shutdown,
and
malfunction
(
SSM)
plan
and
submission
of
semiannual
SSM
report.
This
NESHAP
will
require
more
frequent
compliance
reporting
than
that
required
by
the
EG/
NSPS
to
ensure
compliance.
For
example,
two
compliance
reports
are
required
each
year.
One
compliance
report
is
already
required
by
sources
subject
to
the
collection
and
control
requirements
of
the
EG/
NSPS
(
40
CFR
part
60,
subpart
Cc
or
WWW).
Therefore,
this
NESHAP
requires
one
additional
compliance
report
each
year,
thereby
establishing
semiannual
compliance
reporting.
5
(
b)
Public
notice
prior
to
ICR
submission
to
OMB.

The
EPA
solicited
public
comments
on
the
need
for
this
information,
the
accuracy
of
the
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden
in
the
proposed
NESHAP
announced
in
the
Federal
Register.
This
information
collection
request
for
the
final
rule
includes
a
small
additional
burden
for
some
additional
landfills
identified
by
commenters.
No
other
comments
were
received
or
changes
made
that
affected
the
burden
calculation.

(
c)
Consultations.

The
EPA
held
meetings
with
representatives
of
the
landfill
industry
and
with
representatives
of
State
air
quality
agencies.
These
meetings
included
discussions
of
the
types
of
burden
that
might
be
associated
with
this
NESHAP.
Additionally,
EPA
discussed
burden
with
industry
representatives
during
visits
to
various
landfills
around
the
country.
The
EPA
has
considered
their
comments
and
concerns
while
developing
this
NESHAP.

(
d)
Effects
of
Less
Frequent
Data
Collection.

We
believe
that
requiring
semiannual
reporting
of
any
excursions
or
compliance
issues
is
appropriate.
Annual
reporting
was
not
selected
because
it
would
significantly
reduce
the
EPA's
ability
to
take
administrative
enforcement
actions.
Section
113(
d)
of
the
CAA
limits
assessment
of
administrative
penalties
to
violations
that
occur
no
more
than
12
months
prior
to
the
initiation
of
the
administrative
proceeding.
Periodic
reports
are
a
primary
means
of
identifying
possible
violations,
and
annual
submittal
would
not
give
the
enforcement
agency
time
to
review
the
report
and
take
action
on
a
violation
within
1
year
after
the
event
that
occurred
early
in
the
reporting
period.
Administrative
proceedings
are
far
less
costly
than
judicial
proceedings
for
both
the
EPA
and
the
regulated
community.
Therefore,

this
NESHAP
requires
semiannual
reports.
6
These
standards
also
require
continuous
monitoring
of
control
device
operating
parameters.
Rules
developed
under
section
112
of
the
Act
typically
include
monitoring
strategies
that
incorporate
the
concepts
of
enhanced
monitoring
that
were
established
in
section
114(
a)(
3)
of
the
Act.
This
approach
is
designed
to
ensure
that
monitoring
procedures
developed
for
section
112
standards
provide
data
that
can
be
used
to
determine
compliance
with
applicable
standards,
including
emission
standards.

For
this
standard,
continuous
emissions
monitoring
(
CEM)
is
not
appropriate.
We
considered
use
of
CEM
but
found
them
to
be
infeasible
due
to
the
lack
of
CEM
technology
for
the
section
112
HAP
or
the
NMOC
surrogate
pollutant
regulated
by
this
NESHAP.
Therefore,
we
established
operating
parameters
that
must
be
continuously
monitored
to
determine
a
facility's
compliance
status.
To
determine
compliance
status,
parameters
must
be
monitored
with
a
frequency
that
will
allow
the
source
owner
or
operator
to
certify
whether
compliance
is
continuous
or
intermittent
for
each
recordkeeping
period
associated
with
the
applicable
emission
limitation
or
standard.
For
this
standard,
control
device
operating
parameters
will
be
directly
enforceable
and
will
be
used
to
determine
a
source's
compliance
status.
Deviations
from
the
control
device
operating
parameters
will
be
considered
violations.

(
e)
General
Guidelines.

This
information
collection
meets
the
Office
of
Management
and
Budget's
(
OMB)
general
guidelines
for
information
collections
and
therefore
does
not
require
justification
for
any
deviation
from
OMB's
general
guidelines.

(
f)
Confidentiality
and
Sensitive
Questions.

(
i)
Confidentiality.
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
7
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
39999,
September
28,

1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,

March
23,
1979).

(
ii)
Sensitive
Questions.
This
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
(
a)
Respondents/
NAICS
Codes.

Respondents
are
owners
or
operators
of
MSW
landfills
that
are
major
sources
or
are
co­
located
with
major
sources
and
certain
area
source
landfills.
Area
source
landfills
are
affected
if
they:
(
1)
have
design
capacities
equal
to
or
greater
than
2.5
million
Mg
and
2.5
m3
and,
(
2)
emit
at
least
50
Mg
per
year
of
NMOC
or
operate
bioreactors.
The
promulgation
of
this
NESHAP
would
affect
the
North
American
Industrial
Classification
System
(
NAICS)
codes
and
Standard
Industrial
Classification
Systems
(
SIC)
codes
for
the
landfills
presented
in
the
following
table.

Category
NAICS
Code
SIC
Code
Examples
of
potentially
regulated
entities
Industry:
Air
and
water
resource
and
solid
waste
management
924110
9511
Solid
waste
landfills
Industry:
Refuse
systems
­
solid
waste
landfills
562212
4953
Solid
waste
landfills
State,
local,
and
Tribal
government
agencies
562212
924110
4953
Solid
waste
landfills;
Air
and
water
resource
and
solid
waste
management
8
(
b)
Information
Requested.

(
i)
Data
items.
This
NESHAP
requires
the
following
reports.
No
additional
records
are
required
above
what
would
already
be
maintained
under
the
EG/
NSPS.

°
Startup,
shutdown,
and
malfunction
plan
­
A
startup,

shutdown,
and
malfunction
(
SSM)
plan
is
required
at
initial
compliance.

°
Semiannual
SSM
reports
­
One
report
is
required
semiannually.

°
SSM
notifications
­
This
notification
is
required
each
time
an
SSM
event
occurs
and
the
source
does
not
follow
the
SSM
plan.

°
Compliance
Reports
­
Two
compliance
reports
are
required
each
year.
An
initial
compliance
report
and
annual
compliance
reports
are
already
required
by
sources
subject
to
the
collection
and
control
requirements
of
the
EG/
NSPS
(
40
CFR
part
60,
subpart
Cc
or
WWW).
Therefore,
this
NESHAP
requires
one
additional
compliance
report
each
year,
thereby
establishing
semiannual
compliance
reporting.

(
ii)
Respondent
activities.
The
respondent
activities
required
by
the
standards
are
provided
under
the
first
column
of
tables
1­
3
(
see
Attachment
1).
All
burden
items
are
included
in
tables
1­
3.
9
5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,

COLLECTION,
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
(
a)
Agency
Activities.

Tables
5,
6,
and
7
(
see
Attachment
2)
provide
a
list
of
Agency
activities.

(
b)
Collection
Methodology
and
Management.

Respondents
will
most
likely
submit
hard
copy
reports,

although
some
may
submit
electronic
versions.
(
The
rule
allows
records
to
be
retained
in
hard
copy
or
electronic
format
to
allow
flexibility
and
minimize
burden.)
EPA
engineers
will
review
the
information
submitted
in
the
reports
to
determine
whether
each
landfill
is
in
compliance
with
the
rule.

(
c)
Small
Entity
Flexibility.

The
EPA
does
not
expect
small
MSW
landfills
to
be
adversely
affected
by
these
standards.
The
design
capacity
exemption
of
2.5
million
Mg
and
2.5
million
m3
is
expected
to
exempt
landfills
that
serve
communities
of
fewer
than
125,000
people
from
reporting.
Section
601
of
the
Regulatory
Flexibility
Act
defines
a
"
small
governmental
jurisdiction"
as
the
government
of
cities,
counties,
town,

or
other
districts
with
a
population
less
than
50,000.
The
design
capacity
exemption
will
exempt
landfills
that
serve
small
governmental
jurisdictions.
Likewise,
privately­
owned
10
and
operated
landfills
that
might
qualify
as
small
businesses
would
be
exempted
by
the
design
capacity
cutoff.

(
d)
Collection
Schedule.

Compliance
with
these
standards
will
begin
in
2002
(
year
1
in
the
collection
schedule).
All
respondents
will
have
to
read
the
regulation,
which
is
a
one
time
activity.

Based
on
analysis
of
landfills
in
our
database,
we
anticipate
1,331
respondents
in
year
one,
one
of
which
will
be
one
new
source,
22
existing
small
landfills
co­
located
with
major
sources,
and
the
remainder
(
1,308)
will
be
existing
sources
(
including
major
source
landfills
and
area
sources
landfills
with
design
capacities
of
at
least
2.5
million
Mg
and
2.5
million
M3).
One
new
source
will
be
added
to
the
collection
in
each
of
years
2
and
3
according
to
our
data
analysis.
However,
the
22
co­
located
sources
will
not
be
required
to
respond
after
the
first
year.

Because
these
co­
located
landfills
are
below
the
design
capacity
and
NMOC
emissions
criteria,
they
are
not
required
to
apply
controls,
prepare
an
SSM
plan,
or
submit
semiannual
reports.
Therefore,
the
total
number
of
respondents
for
year
2
will
be
1,310
and
for
year
3
of
the
collection
will
be
1,311.

Each
source
(
except
the
small
co­
located
sources),

whether
new
or
existing,
must
produce
a
one­
time
SSM
plan.

In
year
one
of
this
collection,
compliance
times
will
only
11
require
that
the
one
new
source
produce
this
plan.
In
year
two,
the
1,308
existing
sources
that
are
not
co­
located
must
produce
the
plan,
and
the
one
new
source
must
also
produce
the
plan.
In
year
three,
only
the
one
new
source
must
produce
the
plan.

In
year
one,
the
one
anticipated
new
source
will
be
required
to
comply
with
the
requirements
of
the
NESHAP.

This
source
will
prepare
and
submit
two
semiannual
SSM
reports
and
two
semiannual
compliance
reports.
At
no
time
will
the
22
landfills
co­
located
with
major
sources
be
required
to
comply
with
the
NESHAP
control
and
reporting
requirements.
The
1,308
sources
existing
in
year
one
will
not
be
required
to
comply
with
these
requirements
until
year
2
of
the
collection;
additionally,
one
new
source
must
also
comply
with
the
requirements
in
year
2
and
the
new
source
from
year
1
must
comply.
Year
3
of
the
collection
will
include
the
1310
sources
in
year
2
and
will
add
one
new
source.
These
1311
sources
will
have
to
produce
two
SSM
reports
and
two
compliance
reports
in
year
3.

The
compliance
report
is
a
semiannual
report.
However,

all
sources
complying
with
this
NESHAP
must
comply
with
the
collection
and
control
requirements
of
40
CFR
part
60,

subparts
Cc
and
WWW,
which
require
annual
submission
of
a
compliance
report.
To
accomplish
semiannual
compliance
reporting,
this
NESHAP
will
increase
the
required
compliance
12
reports
by
one
each
year,
thereby
establishing
semiannual
reporting.
Therefore,
this
NESHAP
increases
the
burden
for
each
landfill
by
one
compliance
report
per
year
above
that
already
required
by
40
CFR
part
60,
subparts
Cc
and
WWW.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
(
a)
Estimating
Respondent
Burden.

Based
on
extensive
experience
with
other
NESHAPs
and
specific
information
gathered
from
the
landfill
industry,

the
EPA
expects
this
regulation
to
affect
1,308
existing
MSW
landfills
plus
one
new
landfill
each
year
for
the
first
3
years
after
promulgation.
Tables
1­
3
(
see
Attachment
1)

present
an
itemized
breakdown
of
the
reporting
and
recordkeeping
requirements
for
the
respondents
affected
by
these
standards.
(
It
also
includes
time
for
the
22
small
landfills
co­
located
with
major
sources
to
review
the
rule
in
year
1
and
determine
that
on­
going
reporting
does
not
apply
to
them.)

(
b)
Estimating
Respondent
Costs.

The
information
collection
activities
for
sources
subject
to
these
requirements
are
presented
in
tables
1­
3.

The
total
cost
for
each
respondent
activity
includes
labor
costs,
and
operating
and
maintenance
(
O&
M)
costs.
Operating
and
maintenance
costs
include
the
costs
of
photocopying
and
13
base
labor
rate
x
1.10
=
loading
rate
base
labor
rate

loading
rate

loaded
wage
rate
postage.
Capital
and
startup
costs
are
not
included
because
this
NESHAP
does
not
require
any
new
equipment
to
be
installed.

(
i)
Estimating
Labor
Costs.
Labor
rates,
on
a
per
hour
basis,
are
based
on
those
posted
on
the
Bureau
of
Labor
Statistics
(
BLS)
web
site
(
http://
stats.
bls.
gov/).
The
specific
publication
from
which
the
numbers
were
taken
is
the
"
United
States
Department
of
Labor
NEWS"
released
June
24,
1999.
Table
10
of
that
publication
contains
"
Employer
costs
per
hour
worked
for
employee
compensation
and
costs
as
a
percent
of
total
compensation:
Private
industry
workers,
by
occupational
and
industry
group,
March
1999."
The
total
compensation
labor
rates
are
$
26.16
for
technical
personnel,
$
35.20
for
management
personnel,
and
$
16.39
for
clerical
personnel.
These
labor
rates
include
compensation
for
benefits
such
as
leave,
insurance,
etc.

The
labor
rates
are
further
adjusted
by
including
an
overhead
and
profit
rate
of
110
percent.
Therefore,
the
total
"
loaded"
wage
rates
are
calculated
by
the
following
equations:
14
Given
the
overhead
adjustments,
the
final
"
loaded"
wage
rates
are
$
54.94
for
technical
personnel,
$
73.93
for
management
personnel,
and
$
34.42
for
clerical
personnel.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs.
The
EPA
does
not
anticipate
any
capital
costs
associated
with
these
standards.
Monitoring
of
control
device
operating
parameters
is
already
a
requirement
of
the
EG/
NSPS
for
MSW
landfills.
These
standards
will
not
require
MSW
landfills
to
purchase
or
operate
additional
control
equipment
or
monitoring
devices
other
than
those
already
required
under
the
EG/
NSPS
for
MSW
landfills.

The
average
annual
operating
and
maintenance
costs
for
the
industry's
recordkeeping
and
reporting
to
EPA
are
estimated
at
$
13,128.
The
total
operating
and
maintenance
cost
for
the
3­
year
information
collection
request
is
$
39,384.
Operation
and
maintenance
costs
include
photocopying
and
postage
costs.

(
c)
Estimating
Agency
Burden
and
Cost.

Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
information
collection
requirements.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA,
no
additional
operational
costs
would
be
incurred
by
the
Federal
15
Government.
Examination
of
records
to
be
maintained
by
the
respondents
would
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
EPA's
overall
compliance
and
enforcement
program
and,
therefore,
could
not
be
attributable
to
the
ICR.
The
only
costs
that
the
Federal
Government
would
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information.
These
are
presented
in
tables
5­
7.

Labor
rates
for
the
Federal
employees
are
based
on
the
estimated
hourly
rates
of
$
40.34
for
technical
personnel
(
GS­
12,
Step
5);
$
66.66
for
management
personnel
(
GS­
15,

Step
5);
and
$
22.74
for
clerical
personnel
(
GS­
7,
Step
5).

These
values
represent
the
inclusion
of
a
1.6
multiplier
to
account
for
overhead
and
fringe
benefit
costs.

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

The
total
number
of
respondents
also
is
referred
to
as
the
respondent
universe.
As
explained
in
sections
1(
b)
and
4(
a)
respondents
to
this
request
are
MSW
landfills
of
a
certain
size
and
NMOC
emission
rate,
that
is,
those
that
are
required
to
collect
and
control
their
landfill
gas
emissions
under
the
EG/
NSPS.
The
EPA
estimates
that
1,309
landfills
will
meet
these
conditions
in
2002,
1,310
landfills
in
2003,

and
1,311
landfills
in
2004.
Compliance
with
these
standards
will
begin
in
2002.
However,
in
the
first
year
of
16
this
collection
(
2002)
only
one
new
source
will
be
subject
to
the
recordkeeping
and
reporting
burden
associated
with
this
NESHAP.
Existing
sources
will
not
have
to
comply
with
the
requirements
of
this
rule
until
the
second
year
of
the
collection
(
2003).
In
2003,
the
second
year
of
the
collection,
one
additional
new
source
and
1,308
existing
sources
will
incur
recordkeeping
and
reporting
burden
(
1
new
source
+
1,308
existing
sources
from
the
first
year
+
the
one
source
that
was
new
in
the
first
year
=
1,310
sources
total).
In
year
3
of
the
collection,
one
additional
new
source
will
incur
the
burden
for
a
total
of
1,311
sources.

Note
that
22
additional
landfills
below
the
design
capacity
cuttoff
that
are
co­
located
at
major
sources
will
have
the
burden
of
reading
the
rule
in
year
1,
but
will
not
be
subject
to
control
and
ongoing
reporting
requirements.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.

(
i)
The
Respondent
Tally.
A
presentation
for
each
collection,
reporting,
and
recordkeeping
activity
required
by
this
NESHAP
is
found
in
tables
1­
3.
The
estimate
of
total
annual
hours
and
annualized
cost
requested
for
the
respondents
were
based
on
the
assumptions
outlined
in
section
6(
d)
of
this
supporting
statement.
The
EPA
estimates
the
annual
respondent
burden
by
totaling
the
hours
per
year
for
technical,
managerial,
and
clerical
staff
for
the
first
3
years
after
the
implementation
of
this
NESHAP
17
and
then
by
dividing
that
total
by
three.
Table
4
presents
the
3­
year
summary
results.
For
the
first
three
years
after
the
implementation
of
this
NESHAP,
EPA
estimates
that
the
total
landfill
industry
would
expend
an
average
of
39,360
hours
(
34,226
technical,
1,711
managerial,
and
3,423
clerical)
annually
and
an
average
of
$
2,137,687
per
year
to
meet
the
monitoring,
recordkeeping,
and
reporting
requirements.

(
ii)
The
Agency
Tally.
The
bottom
line
Agency
burden
hours
and
costs,
presented
in
tables
5­
7
(
see
Attachment
2),

are
calculated
by
totaling
the
hours
per
year
for
technical,

managerial,
and
clerical
staff,
and
by
totaling
the
cost
column.
Table
8
(
Attachment
2)
summarizes
the
agency
burden
for
each
of
the
first
3
years
and
calculates
the
average
annual
burden
by
dividing
the
3
year
total
by
3.
The
estimated
average
annual
burden,
over
the
first
three
years,

for
the
Agency
would
be
21,105
hours
at
a
cost
of
$
843,150
(
including
travel
expenses)
per
year.

(
iii)
Variations
in
the
Annual
Bottom
Line.

Calculating
the
average
annual
costs
underestimates
costs
in
a
typical
year
for
a
NESHAP.
Calculating
each
year
individually
provides
a
more
accurate
account
of
how
facilities
will
be
affected
in
the
first
3
years
following
promulgation.
During
the
first
year
of
the
collection,

existing
sources
will
not
incur
recordkeeping
or
reporting
18
burden.
For
these
sources,
this
burden
will
begin
in
year
2
of
the
collection.
This
is
why
the
industry
and
agency
burden
is
much
higher
in
years
2
and
3
than
in
year
1.

(
f)
Reasons
for
Change
in
Burden.

This
is
a
new
collection.
There
is
no
change
in
burden.

(
g)
Burden
Statement.

Burden
means
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.
19
The
average
industry
burden
expected
from
the
recordkeeping
and
reporting
requirements
of
this
NESHAP
is
39,360
hours
per
year
for
all
respondents.
The
average
agency
burden
expected
is
21,105
hours
per
year
for
all
agency
offices.
This
burden
will
include
preparation,

submission,
and
review
of
plans,
notifications
and
reports
listed
in
section
4(
b).

Comments
are
requested
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,

including
through
the
use
of
automated
collection
techniques.
Send
comments
on
this
ICR
to
the
Director,

Collection
Strategies
Division;
U.
S.
Environmental
Protection
Agency
(
2822T);
1200
Pennsylvania
Ave.
NW;

Washington,
DC
20460
and
to
the
Office
of
Management
and
Budget,
725
17th
St.,
NW,
Washington,
DC
20503,
marked
"
Attention:
Desk
Officer
for
EPA."
Include
the
ICR
number,

1938.02
in
any
correspondence.
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
ATTACHMENT
1
TABLES
1,
2,
3,
and
4
Table
1:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
from
Municipal
Solid
Waste
Landfills
Subject
to
Subpart
AAAA
­
Year
1
Table
2:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
from
Municipal
Solid
Waste
Landfills
Subject
to
Subpart
AAAA
­
Year
2
Table
3:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
from
Municipal
Solid
Waste
Landfills
Subject
to
Subpart
AAAA
­
Year
3
Table
4:
Summary
of
Respondent
Burden
for
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
from
Municipal
Solid
Waste
Landfills
­
Years
1
through
3
and
Average
1
Table
1.
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
for
First
Year
Burden
Item
Facility
hours
per
occurrence
(
A)
Number
of
occurrences
per
facility
per
year
(
B)
Facility
hours
per
occurrence
per
year
(
C=
AxB)
Number
of
plants
per
year
(
D)
a
Technical
personnel
hours
per
year
(
E=
CxD)
Management
personnel
hours
per
year
(
F=
Ex0.05)
Clerical
personnel
hours
year
(
G=
Ex0.1)
Total
labor
costs
($)
b
Total
nonlabor
costs
(
O&
M)
Footnotes
1.
Read
and
understand
rule
requirements
10
1
10
1,331
13,310
6,655
1,331
826,258
2.
Prepare
startup,

shutdown,
and
malfunction
plan
40
1
40
1
40
2.0
4
2,483
c
3.
Notification
requirements
A.
Startup,
shutdown,

malfunction
events
­

notification
of
not
following
SSM
plan
n/
a
d
4.
Reporting
requirements
A.
Semiannual
compliance
reports
for
all
sources
2
1
2
1
2
0.1
0.2
124
8
c,
e
B.
Semiannual
startup,

shutdown,
malfunction
reports
6
2
12
1
12
0.6
1
745
15
c
Total
non­
labor
cost
Total
burden
(
salary
and
non­
labor
costs)

Total
annual
hours
13,364
668
1,336
15,368
829,633
23
f
Footnotes:

(
a)
Based
on
the
yearly
number
of
landfills
with
2.5
million
Mg
and
2.5
million
m3
design
capacity
and
NMOC
emissions
of
50
Mg/
yr
that
are
subject
to
the
compliance
requirements.

(
b)
Costs
are
based
on
the
following
hourly
rates
(
the
costs
are
loaded
rates):
Technical
$
54.94,
Management
$
73.92,
and
Clerical
$
34.42.

(
c)
Because
of
compliance
times
specified
in
the
NESHAP,
only
new
sources
will
have
to
submit
these
plans
and
reports
in
the
first
year.

Only
one
new
source
is
anticipated.

(
d)
Assumed
that
100
percent
of
sources
would
have
an
SSM
event
and
that
5
percent
would
not
follow
their
SSM
plan,
eliciting
the
need
for
an
SSM
notification.
However,
because
there
is
only
one
new
source
anticipated
in
the
first
year,
it
was
assumed
that
this
source
would
follow
the
SSM
plan
during
any
SSM
event
in
this
year.

(
e)
Semiannual
compliance
reports
are
required
under
this
NESHAP.
However,
this
NESHAP
only
increases
the
annual
burden
by
one
report
because
one
annual
compliance
report
is
already
required
under
40
CFR
part
60,
subpart
Cc
or
WWW.

(
f)
Operation
and
maintenance
costs
include
photocopying
and
postage
costs.
Approximately
$
7.50
per
report
to
copy
and
send.
2
Table
2.
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
for
Second
Year
Burden
Item
Facility
hours
per
occurrence
(
A)
Number
of
occurrences
per
facility
per
year
(
B)
Facility
hours
per
occurrence
per
year
(
C=
AxB)
Number
of
plants
per
year
(
D)
a
Technical
personnel
hours
per
year
(
E=
CxD)
Management
personnel
hours
per
year
(
F=
Ex0.05)
Clerical
personnel
hours
year
(
G=
Ex0.1)
Total
labor
costs
($)
b
Total
nonlabor
costs
(
O&
M)
Footnote
1.
Read
and
understand
rule
requirements
10
1
10
1
10
0.5
1
621
c
2.
Prepare
startup,

shutdown,
and
malfunction
plan
40
1
40
1,309
52,360
2,618
5,236
3,250,189
d
3.
Notification
requirements
A.
Startup,
shutdown,

malfunction
events
­

notification
of
not
following
SSM
plan
1
2
2
66
68
3.4
7
4,221
e
4.
Reporting
requirements
A.
Semiannual
compliance
reports
for
all
sources
2
1
2
1,310
2,620
131
262
162,634
9,833
f
B.
Semiannual
startup,

shutdown,
malfunction
reports
6
2
12
1,310
15,720
786
1,572
975,802
9,840
Total
non­
labor
cost
Total
burden
(
salary
and
non­
labor
costs)

Total
annual
hours
70,778
3,539
7,078
81,395
4,413,139
19,673
g
Footnotes:

(
a)
Based
on
the
yearly
number
of
landfills
with
2.5
million
Mg
and
2.5
million
m3
design
capacity
and
NMOC
emissions
of
50
Mg/
yr
that
are
subject
to
the
compliance
requirements.

(
b)
Costs
are
based
on
the
following
hourly
rates
(
the
costs
are
loaded
rates):
Technical
$
54.94,
Management
$
73.92,
and
Clerical
$
34.42.

(
c)
Existing
sources
will
have
familiarized
themselves
with
the
requirements
in
year
one.
Second
year
new
sources
will
need
to
familiarize
themselves
with
the
requirements.
Only
one
new
source
is
anticipated
in
the
send
year.

(
d)
Because
of
compliance
times
specified
in
the
NESHAP,
existing
sources
will
need
to
prepare
an
SSM
plan.

(
e)
Assumed
that
100
percent
of
sources
would
have
an
SSM
event
and
that
5
percent
would
not
follow
their
SSM
plan,
thereby
eliciting
the
need
for
an
SSM
notification.

(
f)
Semiannual
compliance
reports
are
required
under
this
NESHAP.
However,
this
NESHAP
only
increases
the
annual
burden
by
one
report
because
one
annual
compliance
report
is
already
required
under
40
CFR
part
60,
subpart
Cc
or
WWW.

(
g)
Operation
and
maintenance
costs
include
photocopying
and
postage
costs.
Approximately
$
7.50
per
report
to
copy
and
send.
3
Table
3.
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
for
Third
Year
Burden
Item
Facility
hours
per
occurrence
(
A)
Number
of
occurrences
per
facility
per
year
(
B)
Facility
hours
per
occurrence
per
year
(
C=
AxB)
Number
of
plants
per
year
(
D)
a
Technical
personnel
hours
per
year
(
E=
CxD)
Management
personnel
hours
per
year
(
F=
Ex0.05)
Clerical
personnel
hours
year
(
G=
Ex0.1)
Total
labor
costs
($)
b
Total
nonlabor
costs
(
O&
M)
Footnote
1.
Read
and
understand
rule
requirements
10
1
10
1
10
0.5
1
621
c
2.
Prepare
startup,

shutdown,
and
malfunction
plan
40
1
40
1
40
2.0
4
2,483
d
3.
Notification
requirements
A.
Startup,
shutdown,

malfunction
events
­

notification
of
not
following
SSM
plan
1
2
2
66
132
6.6
13
8,194
e
4.
Reporting
requirements
A.
Semiannual
compliance
reports
for
all
sources
2
1
2
1,311
2,622
131.1
262
162,758
9,840
B.
Semiannual
startup,

shutdown,
malfunction
reports
6
2
12
1,311
15,732
786.6
1,573
976,547
9,848
Total
non­
labor
cost
Total
burden
(
salary
and
non­
labor
costs)

Total
annual
hours
18,536
927
1,854
21,316
1,170,289
19,688
f
Footnotes:

(
a)
Based
on
the
yearly
number
of
landfills
with
2.5
million
Mg
and
2.5
million
m3
design
capacity
and
NMOC
emissions
of
50
Mg/
yr
that
are
subject
to
the
compliance
requirements.

(
b)
Costs
are
based
on
the
following
hourly
rates
(
the
costs
are
loaded
rates):
Technical
$
54.94,
Management
$
73.92,
and
Clerical
$
34.42.

(
c)
Existing
sources
will
have
familiarized
themselves
with
the
requirements
in
year
one.
Only
new
sources
will
need
to
familiarize
themselves
with
the
requirements
in
the
third
year.
Only
one
new
source
is
anticipated
in
the
third
year.

(
d)
All
existing
sources
will
have
prepared
their
SM
plan
in
the
first
or
second
years.
Any
new
source
is
anticipated
in
the
third
year.

(
e)
Assumed
that
100
percent
of
sources
would
have
an
SSM
event
and
that
5
percent
would
not
follow
their
SSM
plan,
thereby
eliciting
the
need
for
an
SSM
notification.

(
f)
Operation
and
maintenance
costs
include
photocopying
and
postage
costs.
Approximately
$
7.50
per
report
to
copy
and
send.
4
Table
4.
Summary
of
Industry
Burden
for
the
Standards
for
MSW
Landfills
(
Year
1
Through
3
and
Average)

Year
Technical
Hours
Management
Hours
Clerical
Hours
Total
Hours
Labor
Costs
Non­
Labor
O&
M
Costs
Total
Costs
Year
1
13,364
668
1,336
15,368
829,610
23
829,633
Year
2
70,778
3,539
7,078
81,395
4,393,466
19,673
4,413,139
Year
3
18,536
927
1,854
21,316
1,150,602
19,688
1,170,289
Average
Burden
34,226
1,711
3,423
39,360
2,124,559
13,128
2,137,687
ATTACHMENT
2
TABLES
5,
6,
7,
and
8
Table
5:
Annual
Federal
Government
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
from
Municipal
Solid
Waste
Landfills
Subject
to
Subpart
AAAA
­
Year
1
Table
6:
Annual
Federal
Government
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
from
Municipal
Solid
Waste
Landfills
Subject
to
Subpart
AAAA
­
Year
2
Table
7:
Annual
Federal
Government
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
from
Municipal
Solid
Waste
Landfills
Subject
to
Subpart
AAAA
­
Year
3
Table
8:
Summary
of
Federal
Government
Burden
for
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
from
Municipal
Solid
Waste
Landfills
­
Years
1
through
3
and
Average
1
Table
5.
Agency
Burden
and
Cost
of
Reporting
and
Recordkeeping
for
First
Year
Burden
Item
Facility
hours
per
occurrence
(
A)
Average
occurrences
per
Agency
and
State
(
B)
Personhours
per
Respondent
(
C)=
AxB)
Number
of
Agency
and
State
Personnel
(
D)
Technical
personnel
hours
per
year
(
E=
CxD)
Management
personnel
hours
(
F=
Ex0.05)
Clerical
hours
per
year
(
G=
Ex0.1)
Costs
($)
(
H)
Footnotes
1.
Read
and
understand
rule
requirements
8
1
8
60
480
24
48
22,052
a
2.
Enter
and
update
information
into
agency
recordkeeping
system
4
1
4
1
4
0.2
0.4
184
3.
Required
activities
for
sources
with
add­
on
control
devices
A.
Review
operating
parameters
included
in
6.

B.
Review
continuous
parameter
monitoring
included
in
6.

4.
Excess
emissions
enforcement
activities
and
inspections
8
1
8
0
0
0
0
0
b
5.
Notification
requirements
A.
Review
SSM
notification
­

source
did
not
follow
SSM
plan
during
SSM
n/
a
6.
Reporting
requirements
A.
Review
semiannual
compliance
report
6
1
6
1
6
.3
0.60
276
c,
d
B.
Review
SSM
plan
8
1
8
1
8
0.4
0.80
368
c
C.
Review
semiannual
SSM
reports
4
2
8
1
8
0.40
0.80
368
c
Total
Burden
and
Cost
(
Salary)
506
25
51
23,247
Total
Annual
Hours
582
Footnotes:

(
a)
Assumed
one
agency
person
in
each
State
and
one
agency
person
in
each
EPA
Region
will
have
to
read
the
regulation
each
year.

(
b)
Assumed
that
100
percent
of
sources
would
have
an
SSM
event
and
that
5
percent
would
not
follow
their
SSM
plan,
therefore,
eliciting
the
need
for
an
SSM
notification.
However,
because
of
the
compliance
times,
no
SSM
notifications
are
anticipated
in
the
first
year
for
the
one
new
source.

(
c)
In
the
first
year,
only
new
sources
will
produce
an
SSM
plan,
semiannual
SSM
reports,
and
compliance
reports.
Only
one
new
source
is
anticipated
in
the
first
year.
SSM
notification
of
not
following
the
SSM
plan
is
not
anticipated
for
the
one
new
source
in
the
first
year.

(
d)
Semiannual
compliance
reports
are
required
under
this
NESHAP.
However,
this
NESHAP
only
increases
the
annual
burden
by
one
report
because
one
annual
compliance
report
is
already
required
under
40
CFR
part
60,
subpart
Cc
or
WWW.
2
Table
6.
Agency
Burden
and
Cost
of
Reporting
and
Recordkeeping
for
Second
Year
Burden
Item
Facility
hours
per
occurrence
(
A)
Average
occurrences
per
Agency
and
State
(
B)
Personhours
per
Respondent
(
C)=
AxB)
Number
of
Agency
and
State
Personnel
(
D)
Technical
personnel
hours
per
year
(
E=
CxD)
Management
personnel
hours
(
F=
Ex0.05)
Clerical
hours
per
year
(
G=
Ex0.1)
Costs
($)

(
H)
Footnotes
1.
Read
and
understand
rule
requirements
8
1
8
60
480
24
48
22,052
a
2.
Enter
and
update
information
into
agency
recordkeeping
system
4
26.2
104.8
50
5240
262
524
240,738
b
3.
Required
activities
for
sources
with
add­
on
control
devices
A.
Review
operating
parameters
included
in
6.

B.
Review
continuous
parameter
monitoring
included
in
6.

4.
Excess
emissions
enforcement
activities
and
inspections
8
1.3
10.5
50
524
26.2
52.4
24,074
c
5.
Notification
requirements
A.
Review
SSM
notification
­
source
did
not
follow
SSM
plan
during
SSM
1
1.3
1.3
50
65.5
3.3
6.6
3,009
d
6.
Reporting
requirements
A.
Review
semiannual
compliance
report
6
26.2
157.2
50
7,860
393
786
361,107
e
B.
Review
SSM
plan
8
26.2
209.6
50
10,480
524
1,048
481,476
C.
Review
semiannual
SSM
reports
4
52.4
209.6
50
10,480
524
1,048
481,476
Total
Burden
and
Cost
(
Salary)
35,130
1,756
3,513
1,613,934
Total
Annual
Hours
40,399
Footnotes:

(
a)
Due
to
attrition
of
personnel
and
program
or
agency
reorganization,
we
assumed
one
agency
person
in
each
State
and
one
agency
person
in
each
EPA
Region
will
have
to
read
the
regulation
each
year.

(
b)
The
average
occurrences
per
agency
or
State
(
26.2)
is
derived
from
the
number
of
landfills
subject
to
the
requirements
in
year
two
(
1,310)
divided
by
50
(
the
number
of
States
that
must
conduct
the
activity)

(
c)
The
average
occurrences
per
agency
or
State
(
1.3)
is
derived
from
the
number
of
landfills
subject
to
the
requirements
in
year
two
(
1,310)
divided
by
50
(
the
number
of
States
that
must
conduct
the
activity)
and
multiplied
by
0.05,
the
percentage
of
sources
that
are
assumed
to
have
excess
emissions,
thereby
eliciting
the
need
for
enforcement
and
inspection
activity.

(
d)
Assumed
that
100
percent
of
sources
would
have
an
SSM
event
and
that
5
percent
would
not
follow
their
SSM
plan,
thereby
eliciting
the
need
for
an
SSM
notification.

(
e)
Semiannual
compliance
reports
are
required
under
this
NESHAP.
However,
this
NESHAP
only
increase
the
annual
burden
by
one
report
because
one
annual
compliance
report
is
already
required
under
40
CFR
part
60,
subpart
Cc
or
WWW.
3
Table
7.
Agency
Burden
and
Cost
of
Reporting
and
Recordkeeping
for
Third
Year
Burden
Item
Facility
hours
per
occurrence
(
A)
Average
occurrences
per
Agency
and
State
(
B)
Personhours
per
Respondent
(
C)=
AxB)
Number
of
Agency
and
State
Personnel
(
D)
Technical
personnel
hours
per
year
(
E=
CxD)
Management
personnel
hours
(
F=
Ex0.05)
Clerical
hours
per
year
(
G=
Ex0.1)
Costs
($)

(
H)
Footnotes
1.
Read
and
understand
rule
requirements
8
1
8
60
480
24
48
22,052
a
2.
Enter
and
update
information
into
agency
recordkeeping
system
4
1
4
1
4
0.2
0.4
184
3.
Required
activities
for
sources
with
add­
on
control
devices
A.
Review
operating
parameters
included
in
6.

B.
Review
continuous
parameter
monitoring
included
in
6.

4.
Excess
emissions
enforcement
activities
and
inspections
8
1.3
10.5
50
524
26.2
52.4
24,074
b
5.
Notification
requirements
A.
Review
SSM
notification
­
source
did
not
follow
SSM
plan
during
SSM
1
1.3
1.3
50
65.5
3.3
6.6
3,009
b,
c
6.
Reporting
requirements
A.
Review
semiannual
compliance
report
6
26.2
157.2
50
7,860
393
786.00
361,107
d
B.
Review
SSM
plan
8
1
8
1
8
0.4
0.80
368
C.
Review
semiannual
SSM
reports
4
52.4
209.6
50
10480
524
1,048
481,476
Total
Burden
and
Cost
(
Salary)
19,422
971
1,942
892,270
Total
Annual
Hours
22,335
Footnotes:

(
a)
Due
to
attrition
of
personnel
and
program
or
agency
reorganization,
we
assumed
one
agency
person
in
each
State
and
one
agency
person
in
each
EPA
Region
will
have
to
read
the
regulation
each
year.

(
b)
The
average
occurrences
per
agency
or
State
(
26.2)
is
derived
from
the
number
of
landfills
subject
to
the
requirements
in
year
three
(
1,311)
divided
by
50
(
the
number
of
States
that
must
conduct
the
activity)

(
c)
The
average
occurrences
per
agency
or
State
(
1.3)
is
derived
from
the
number
of
landfills
subject
to
the
requirements
in
year
three
(
1,311)
divided
by
50
(
the
number
of
States
that
must
conduct
the
activity)
and
multiplied
by
0.05,
the
percentage
of
sources
that
are
assumed
to
have
excess
emissions,
thereby
eliciting
the
need
for
enforcement
and
inspection
activity.

(
d)
Assumed
that
100
percent
of
sources
would
have
an
SSM
event
and
that
5
percent
would
not
follow
their
SSM
plan,
thereby
eliciting
the
need
for
an
SSM
notification.

(
e)
Semiannual
compliance
reports
are
required
under
this
NESHAP.
However,
this
NESHAP
only
increase
the
annual
burden
by
one
report
because
one
annual
compliance
report
is
already
required
under
40
CFR
part
60,
subpart
Cc
or
WWW.
Table
8.
Summary
of
Federal
Government
Burden
for
the
Standards
for
MSW
Landfills
(
Years
1
Through
3
and
Average)

Agency
Burden
Summary
Technical
Hours
Management
Hours
Clerical
Hours
Total
Hours
Total
Costs
Year
1
506
25
50
580
23,247
Year
2
35,130
1,756
3,513
40,399
1,613,934
Year
3
19,422
971
1,942
22,335
892,270
Average
Burden
18,352
918
1,835
21,105
843,150
