  SEQ CHAPTER \h \r 1 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

Federal Plan Requirements For Municipal Solid Waste Landfills That
Commenced Construction Prior to May 30, 1991 and Have Not Been Modified
or Reconstructed Since May 30, 1991 (40 CFR part 62, subpart GGG)
(Renewal)

1(b)  Short Characterization/Abstract

	The Federal plan published at 40 CFR part 62, subpart GGG promulgated
on November 8, 1999, applies to any existing municipal solid waste (MSW)
landfill located in a state that is not covered by an approved and
effective state plan.  The United States Environmental Protection Agency
(EPA) Federal plan also applies to existing MSW landfills located on
Indian land.  EPA anticipates that fewer than 12 MSW landfills located
in Indian country will come under EPA’s Federal plan, which will be
large enough to warrant controls.  Additionally, the Federal plan
applies to existing landfills that handled everyday household waste and
were in operation from November 8, 1987, to May 30, 1991, or had
capacity available for future waste disposition.  MSW landfills
constructed on or after May 30, 1991 or MSW landfills which had changes
in design capacities on or after May 30, 1991, are subject to EPA’s
new source performance standards and not this rule.  This information is
being collected to assure compliance with 40 CFR part 62, subpart GGG.

	In general, all Federal plan standards require initial notifications,
performance tests, and periodic reports.  Owners or operators are also
required to maintain records of the occurrence and duration of any
startup, shutdown, or malfunction in the operation of an affected
facility, or any period during which the monitoring system is
inoperative.  These notifications, reports, and records are essential in
determining compliance, and are required of all sources subject to the
Federal plan.  For subpart GGG, it is expected that all potential
sources subject to this requirement have already performed all initial
performance tests and reports.  Since subpart GGG only applies to
existing sources and no more sources are expected to trigger the
requirements, only the routine reporting and recordkeeping requirements
currently apply.  Landfills that were required to install collection and
control systems must submit annual compliance reports.  Any owner or
operator subject to the provisions of this part shall maintain records
for at least 5 years.  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.

	Approximately 173 sources are subject to this regulation.  It is
estimated that no additional sources will become subject to this
regulation in the next three years.  It is not possible for a facility
to qualify as an existing source, since it would have to be operational
and exceed the design capacity requirements before May 30, 1991.

	Owners or operators are required to keep continuous monitoring records
of the parameters reported in the initial performance report, and
records of monthly monitoring of surface methane concentrations.  All
MSW landfills are required to maintain records for the time specified in
the recordkeeping chart in section 4(b) “data items.”  Annual
compliance reports include: descriptions of any period in which the
value of any of the monitored operating parameters fell outside the
established ranges, and any period when the collection system or air
pollution control equipment malfunctioned, or when the collected gas was
diverted from the control device.

	All reports are submitted to the respondent’s state or local agency. 
EPA delegated the enforcement authority to the state and local agencies.
 The information is used to determine that all sources subject to the
Federal emission guidelines are achieving the standards.

	The Office of Management and Budget (OMB) approved the currently active
Information Collection Request (ICR) with no Terms of Clearance.

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, as amended,
to establish procedures by which:

. . . each State shall submit to the Administrator a plan which (A)
establishes standards of performance for any existing source for any air
pollutant. . . to which a standard of performance would apply, if such
existing source were a new source; and (B) provides for the
implementation and enforcement of such standards of performance.

	In this case, the Administrator has authority to: (1) prescribe a plan
for a state in cases where the state fails to submit a satisfactory
plan..., and (2) enforce the provisions of such a plan where the state
fails to enforce them under sections 113 and 114, with respect to an
implementation plan.

	In addition, section 114(a)(1) states that: 

. . . the Administrator may require any person who owns or operates any
emission source or who is 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; (D)
sample such emissions (in accordance with such methods, at such
locations, at such intervals, and in such a manner as the Administrator
shall prescribe); and (E) provide other such information as may be
reasonably required.

	In the Administrator's judgment, emissions from MSW landfills that
cause or contribute to air pollution may be reasonably anticipated to
endanger public health or welfare.  Therefore, Federal emission
guidelines were promulgated for the control of existing MSW landfills
for States in which the state failed to submit an approved plan. 
Certain reports are necessary to enable the Administrator to identify
existing sources subject to the emission guidelines and to determine if
the standards are achieved.

	2(b)  Practical Utility/Users of the Data

	The information generated by the monitoring, recordkeeping and
reporting requirements described in this ICR is used by the Agency to
ensure that facilities affected by the NES continue to operate the
control equipment and achieve compliance with the regulation.  Adequate
monitoring, recordkeeping, and reporting is necessary to ensure
compliance with the applicable regulations, as required by the Clean Air
Act.  The information collected from recordkeeping 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

	The requested recordkeeping and reporting are required under 40 CFR
part 62, subpart GGG.

	3(a)  Nonduplication

	 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 their 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

	An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register on June 21, 2006, 71 FR 35652.  No
comments were received on the burden published in the Federal Register.

				

	3(c)  Consultations

	It is our policy to review carefully any comment received since the
last ICR renewal including those submitted in response to the first
federal register notice and respond appropriately.  In this case, no
comments were received.  The Agency’s internal industry experts have
been consulted.  The Agency’s internal data sources and projections of
industry growth over the next three years have also been considered.

	The primary source of information was the information provided by the
industry.  Information provided in the industry reports is housed in the
EPA’s AFS (Air Facility Subsystem) database.  Approximately 173
respondents are currently subject to the regulation. The Agency’s
information indicates that no new sources will be subject to this
standard in the future.

It should be noted that the industry trade association(s) and other
interested parties were provided an opportunity to comment on the burden
associated with the standard as it was being developed and the standard
has been previously reviewed to determine the minimum information needed
for compliance purposes.

	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 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.  The Federal plan requirements included a
one-time design capacity report and an annual Non-Methane Organic
Compound (NMOC) emissions report (for landfills that exceed the design
capacity threshold and quarterly surface monitoring for landfills that
were required to install collection and control devices).

	3(e)  General Guidelines

	None of these reporting or recordkeeping requirements violates any of
the regulations established by OMB at 5 CFR 1320.5.

	3(f)  Confidentiality

	The required information has been determined as non-confidential. 
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 recordkeeping requirements contains 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

	4(a)  Respondents/SIC Codes

	The respondents for recordkeeping and reporting requirements are MSW
landfills that are located in those States that do not have an
EPA-approved and effective state plan.  The North American Industry
Classification System (NAICS) code is 92411 (Air and Water Resource and
Solid Waste Management) and 562212 (Refuse Systems, Solid Waste
Landfills).  Under the old Standard Industrial Classification (SIC)
reference system, landfills affected by the emission guidelines are code
4953.

	4(b)  Information Requested 

These standards require affected facilities to maintain all records,
including the submitted reports and notifications for at least 5 years. 
This is consistent with the General Provisions as applied to the
standards.  EPA believes that the 5-year records retention requirement
is consistent with the part 70 permit program and the 5-year statute of
limitations on which the permit program is based.  In addition, the
retention of records for 5 years would allow EPA to establish the
compliance history of a source and any pattern of compliance for
purposes of determining the appropriate level of enforcement action. 
Historically, EPA has found that the most flagrant violators frequently
have violations extending beyond 5 years.  EPA would be prevented from
pursuing the worst violators due to the destruction or nonexistence of
records if records were retained for less than 5 years.

		(i)  Data Items

	All data in this ICR that is recorded and/or reported is required by
Federal plan reporting and recordkeeping requirements for existing
municipal solid waste landfills, 40 CFR part 62, subpart GGG.

	A source must make the following reports:

Notifications and Reports for 40 CFR part 62, subpart GGG

Reporting of initial design capacity (Year 1 only: reports were
submitted).  This requirement no longer applies.	62.14355 (a)(1)

60.757(a)

Reporting the initial and annual NMOC emission rate.  The initial report
requirement no longer applies.	62.14355(a)(2)

Collection and control system design plan.  This requirement no longer
applies.	62.14355

60.757(b) 

Report increments of progress.  This requirement no longer applies.
62.14355(b) and (c)

Annual compliance report	60.757(f)

Reporting of landfill closure	60.757(d)

Reporting of equipment removal	60.757(e)

	

	A source must maintain the following records:

Recordkeeping for 40 CFR part 62, subpart GGG

Records of maximum design capacity, refuse-in-place, year-by-year waste
acceptance (maintain 5 years)	62.14355

60.758 

Records of system design and initial performance test/compliance
determination (maintain 5 years)	62.14355

60.758

Records of monitoring (maintain 5 years)	62.14355; 60.758

 Record of a plot map and well locations for the life of the landfill
(maintain for life of collection system)	62.14355

60.758

Records of collection & control system exceedances (maintain 5 years) 
62.14355; 60.758(c)



	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.

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 performance tests if necessary.

Review notifications and reports, including performance test reports,
and other reports required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Air Facility Subsystem (AFS)
database.



	5(b)  Collection Methodology and Management

	Some respondents were required to submit a one-time only design
capacity report to EPA.  Others also were required to submit additional
reports, including annual emission rate reports, control system design
plans, progress reports, and annual compliance reports.  EPA engineers
review the submitted information in the reports to determine whether
each landfill is in compliance with the rule.  EPA staff reviews the
calculations included in those reports to ensure that landfills used the
required methodology and that the NMOC emission rate is correctly
calculated.  Files of hard copy reports are kept at EPA regional
offices.

Landfill location and design information contained in the reports is
entered into AFS which is operated and maintained by EPA's Office of Air
Quality Planning and Standards.  AFS 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 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.

5(c)  Small Entity Flexibility

	There are no small businesses affected by this regulation.  The EPA
does not expect that small MSW landfills will be adversely impacted by
the Federal plan.  Small landfills only were required to submit a
one-time design capacity report.  In choosing 2,500,000 Mg and 2,500,000
cubic meters design capacity as the regulatory cutoff for annual
reporting, the EPA exempted landfills that are very unlikely to emit 50
Mg or more of NMOC per year.  The EPA also developed a computer model
version of the Tier system on floppy disk that is available to any owner
or operator subject to the Federal plan.  Such tools significantly
reduced the burden of the NMOC emission rate calculation.

	5(d)  Collection Schedule

	The specific frequency for each information collection activity within
this request is quarterly.  Reporting is done on an annual basis.

6.  Estimating the Burden and Cost of the Collection

	Table 1 documents the computation of annual burdens for the
recordkeeping and reporting requirements applicable to the industry for
40 CFR part 62, subpart GGG included in this ICR.  The individual
burdens are expressed under standardized headings are 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.

	The Federal plan for MSW landfills affects 173 landfills.  All 173
landfills need to submit annual compliance reports.

	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 for these recordkeeping and
reporting requirements is estimated to be 12,456 hours (the number of
hours was corrected on August 3, 2006, because there was a mathematical
error).  These hours are based on Agency studies and background
documents from the development of the regulation, Agency knowledge and
experience with the program, and the previously approved ICR.

	6(b)  Estimating Respondent Costs

	It is estimated that the annual costs to respondents is $242,000 for
monitoring activities.  Operating and maintenance costs for the year are
estimated at $1,400 per monitor.

		(i)  Estimating Labor Costs 

	This ICR uses the following labor rates: $85.81 per hour for Executive,
Administrative, and Managerial labor; $57.12 per hour for Technical
labor, and $36.27 per hour for Clerical labor.  These rate(s) are from
the United States Department of Labor, Bureau of Labor Statistics, March
2001, “Table 10. Private industry, by occupational and industry
group.”  The rates are from column 1, “Total compensation.”  The
wage rates have been increase by 110 percent to account for the benefit
packages available to those employed by private industry.  It is
estimated that 85 percent of the respondent burden hours is technical; 5
percent management; 10 percent clerical.

	Managerial	$85.81  ($40.86 + 110%)

Technical	$57.12  ($27.20 + 110%)

	Clerical	$36.27  ($17.27 + 110%)

Using the above labor rates, the average cost is $56.47 ($4.29
management; $48.55 technical; $3.63 clerical).

		(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

	

	Since all requirements for initial design capacity reports and
activities were required to be only completed in the first year, there
are no startup costs for the remaining years.  Operation and maintenance
costs for the year are estimated at $1,400/monitor.

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

	Since all the monitors have been previously purchased, there are no
more capital costs associated with this ICR.  There are operation and
maintenance costs for the monitors which are estimated to be $1400 per
monitor/year.

	6(c)  Estimating Agency Burden and Cost

	The only costs to the Agency are those costs associated with analysis
of the reported information.  Publication and distribution of the
information are part of the AFS 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 Agency cost during the three years of the ICR is
estimated to be $25,749.32 (see Table 2).  This cost is based on the
average hourly labor rate at a GS-12, Step 1, times a 1.6 benefits
multiplication factor to account for government overhead expenses for a
total of 729 hours as follows:

	Managerial	$51.62   (GS-13, Step 5, $32.26 x 1.6):

			 	Total 35 management person hours

Technical	$38.30   (GS-12, Step 1, $23.94 x 1.6):

				 Total technical person hours 692

	Clerical	$20.72   (GS-6, Step 3, $12.95 x 1.6)]

				Total clerical person hours 2

Using these rates, it is estimated that the average cost is $37.21. 
These rates are from the Office of Personnel Management (OPM) “2002
General Schedule” which excludes locality rates of pay.

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

Respondent Universe and Number of Responses Per Year

Regulation Citation	(A)

Average Number of New Respondents per Year	(B)

Number of Reports for New Sources	(C)

Number of Existing Respondents	(D)

Number of Reports for Existing Sources	(F)

Number of Respondents that keep records but do not submit reports	(E)

Total Annual Responses =

(AxB)+(CxD)+ F

40 CFR, part 62, subpart GGG	0	0	173	1	N/A	173

	

	The number of total respondents is 173.  This number is the sum of
column A and column C of the Respondent Universe and Number of Responses
Per Year table.  This represents the number of existing sources and no
new sources averaged over the three-year period (i.e., number of new
respondents per year multiplied by 3 years divided by two).

	The number of Total Respondents is 173.  This is the number in column D
of Table 1: Annual Respondent Burden & Cost of Monitoring/Record
Keeping/Reporting.

	The total annual labor hours are 12,456.  Details upon which this
estimate is based appear in Table 1. Annual Respondent Burden and Cost.

 

	The total annual capital and O&M costs to the regulated entity are
$242,000.

6(e)  Bottom Line Burden Hours Burden Hours And Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents appear in the two tables attached to this supporting
statement.

6(f)  Reasons for Change in Burden

	There has not been any change in burden except for corrections due to a
mathematical error.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 72 hours per response.
 Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency.  This includes the time needed
to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data 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.

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2006-0440, which is available for public viewing at the
Enforcement and Compliance Docket and Information (ECDIC), Email:  
HYPERLINK mailto:docket@oeca@epa.gov; docket.oeca@epa.gov;  mail code
2220T in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301
Constitution Avenue, NW, Washington, DC.  The EPA Docket Center Public
Reading Room is open from 8:00 a.m. to 4:30 p.m., Monday through Friday,
excluding legal holidays.  The telephone number for the Reading Room is
(202) 566-1744, and the telephone number for the Enforcement and
Compliance Docket and Information (ECDIC), Docket is (202) 566-1514.  An
electronic version of the public docket is available through   HYPERLINK
"http://www.regulations.gov"  www.regulations.gov  .  Use   HYPERLINK
"http://www.regulations.gov"  www.regulations.gov  to submit or view
public comments, access the index listing of the contents of the public
docket, and to access those documents in the public docket that are
available electronically.  Once in the system, select “search”, then
key in the docket ID number identified above.  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 Office for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2006-0440 and OMB control number 2060-0430 in any
correspondence.

NOTE:  The EPA Docket Center suffered damage due to flooding during the
last week of June 2006.  The Docket Center is continuing to operate. 
However, during the cleanup, there will be temporary changes to Docket
Center telephone numbers, addresses, and hours of operation for people
who wish to visit the Public Reading Room to view documents.  Consult
EPA's Federal Register notice at 71 FR 38147 (July 5, 2006) or the EPA
website at   HYPERLINK "http://www.epa.gov/epahome/dockets.htm" 
www.epa.gov/epahome/dockets.htm  for current information on docket
status, locations and telephone numbers.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in
collecting this information.TABLE 1: ANNUAL RESPONDENT BURDEN & COST OF
MONITORING/RECORD KEEPING/REPORTING



Person-	Occurrences	Person-

Total

	Burden Item	hours per	per	hours per

person-



occurrence	Respondents	respondent	Respondents	hours	Cost$ 

	 (A) 	 (B) 	 (C)=(AxB) 	 (D) 	 (E)=(CxD) 	(H)a

1. Applications	 N/A 	 	 	 	 	 

2. Surveys and Studies	 N/A 





	3.  Reporting Requirements







   A.  Read Instructions	 N/A 





	   B.  Required Activities







      - Submit Design Plan	 N/A 





	      - Initial performance test report	 N/A 





	      - Annual Compliance Report	       2 	     1 	      2 	  173 	   
346 	   19,538.62 

      - Quarterly surface methane monitoringb	      14 	     4 	     56 
173 	  9,688 	  547,081.36 

      - O&M of portable monitorc







   C.  Create Information	 See 3B 





	   D.  Gather Existing Information	 See 3E 





	   E.  Write Report







      - Initial design capacity report	 N/A 





	      - Annual report of NMOC flow rate	 N/A 





	        (Tier 1 calculation)	 N/A 





	      - Report of Tier 2 and 3 Sampling	 N/A 





	      - Report of initial performance test	 See 3B 





	      - Semi-annual compliance report 	 See 3B 





	4.  Recordkeeping Requirements







   A.  Read Instructions	 See 3A 





	   B.  Plan Activities	 N/A 





	   C.  Implement Activities	 N/A 





	   D.  Develop Record System	 N/A 





	   E.  Time to Enter Information







      - Records of control system monitoringb	     0.5 	    12 	      6 
  173 	 1,038 	   58,616.00 

      - Records of accumulated refuse	       8 	     1 	      8 	  173 	
 1,384 	   78,154.48 

   F.  Time to train Personnel







   G.  Time for Audits	 N/A 	 	 	 	 	 

Total BURDEN AND COST	 	 	 	 	 12,456 	     703,390 

a It's estimated that 85% of the respondent burden hours is technical;
5% management; 10% clerical.  The average cost is $56.47.  Costs are
based on 1989 CAIR labor rates adjusted using the latest Employment Cost
Index which yields the following March 1998 hourly rates: technical at
$57.12, management at $85.81 and clerical at $36.27.







b Monitoring hours include operating and maintenance time.







c Operating and maintenance costs for the year is estimated at
$1400/monitor.





Column F Row 31 corrected on 08/03/06







Table 2.  Annual Burden and Cost for the Federal Government









	EPA hours	Occurences	Person-hours





per	per	per

Total

	Activity	occurrence	Respondent	Respondent	Respondents	person-hours	Cost
$ Yr 

 	(A)	(B)	(C)=(AxB)	(D)	(E)=(CxD)	(H)a









Review initial design capacity report	N/A













	Review report of initial performance	N/A





	test.

 













Review Design Plan	N/A













	Observe initial performance tests	N/A













	Review annual NMOC emission rate

 





report	2	1	2	     173 	     346 	  12,874.66 









Review Tier 2 Calculations	N/A













	Review Tier 3 Calculations	N/A













	Review annual compliance report	2	1	2	     173 	     346 	  12,874.66 









Travel expenses for tests attended	N/A





	 	 	 	 	 	 	 

 	 	 	 	 	     692 	  25,749.32 

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