SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Municipal Solid Waste Landfills (40 CFR part 63, subpart
AAAA) (Renewal)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

	NESHAP for Municipal Solid Waste Landfills (40 CFR part 63, subpart
AAAA) (Renewal)

	1(b)  Short Characterization/Abstract

	The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Municipal Solid Waste (MSW) Landfills were proposed on November 7,
2000 (65 FR 66672), and promulgated on January 16, 2003 (68 FR 2238). 
These regulations apply to all landfills at major sources and some
landfills at area sources.  The only MSW landfill 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.  Landfills of this size and NMOC emission level are
currently subject to NMOC control under the Emission Guidelines and New
Source Performance Standards (40 CFR part 60, subpart Cc or WWW) for MSW
Landfills.  Because these standards specifically regulate HAP, no MSW
landfill will be subject to NESHAP unless it meets these emission
requirements.  

	Any owner or operator of a MSW landfill affected by the standard would
be required to submit semiannual compliance reports.  They are also
required to maintain records of the occurrence and duration of any
startup, shutdown, or malfunction (SSM) plan and prepare semiannual SSM
reports.  These notifications, reports, and records are essential in
determining compliance, and are required of all sources subject to
NESHAP.

	Based on our consultations with industry representatives, there is an
average of one affected facilities at each plant site and each plant
site has only one respondent (i.e., the owner/operator of the plant
site).

	Approximately 1,119 respondents are currently subject to the
regulation, and it is estimated that one additional respondent per year
will become subject to the regulation in the next three years.  The
average number of respondents over the next three years will be 1,121.  

	The Office of Management and Budget (OMB) approved the current
Information Collection Request (ICR) without any “Terms of
Clearance.”

2.  Need for and Use of the Collection

	2(a)  Need/Authority for the Collection

	The EPA is charged under section 112 of the Clean Air Act (CAA), as
amended, to establish standards of performance for each category or
subcategory for major sources and area sources of hazardous air
pollutants.  There standards are applicable to new or existing sources
of hazardous air pollutants and shall require the maximum degree of
emission reduction.  In addition, section 114(a) states that the
Administrator may require any owner/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, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data when direct monitoring of emissions is
impractical; (F) submit compliance certifications in accordance with
Section 114(a)(3); and (G) provide such other information as the
Administrator may reasonably require.

	In the Administrator’s judgment, hazardous air pollutant (HAP)
emissions from MSW landfills cause or contribute to air pollution that
may reasonably be anticipated to endanger public health or welfare. 
Therefore, the NESHAP were promulgated for the source category at 40
CFR, part 63, subpart AAAA.

	2(b)  Practical Utility/Users of the Data

	The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which were promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

	Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance test, a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

	The notifications required in the standard are used to inform the
Agency or delegated authority when a source becomes subject to the
requirements of the regulations.  The reviewing authority may then
inspect the source to ensure that the pollution control devices are
properly installed and operated, that leaks are being detected and
repaired, and that the standards are being met.  The performance test
may also be observed.

	The required semiannual reports are used to determine periods of excess
emissions, identify problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

3.  Nonduplication, Consultations, and Other Collection Criteria

	The requested recordkeeping and reporting are required under 40 CFR
part 63, subpart  AAAA.

	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 its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, no duplication
exists.

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

	An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (70 FR 24020) on May 6, 2005.  No
comments were received on the burden published in the Federal Register.

	3(c)  Consultations

	For the information collection, we referenced the most recent ICR,
consulted with the preparer of the active ICR.  We reviewed information
available from the Occupational Safety and Health Administration (OSHA),
the Air facility System (AFS), and websites covering municipal solid
waste landfills.  We also consulted with the EPA’s Office of Air
Quality Planning and Standards, Information Transfer, the Program
Integration Division, and the Solid Waste Association of North America
(SWANA), Ms. Amanda King, (800) 467-9262, the National Solid Waste
Management Association (NSWMA), Mr. Edward Repa, (703) 299-5139 Ext 11,
and Waste Business Journal, Mr. Jim Thompson, (619-793-5190).

	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.

	3(e)  General Guidelines

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

	3(f)  Confidentiality

	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 contain sensitive
questions.

	4.  The Respondents and the Information Requested

	4(a)  Respondents/SIC Codes

	The respondents to the recordkeeping and reporting requirements are
lime manufacturing plants.  The United States Standard Industrial
Classification (SIC) codes for the respondents affected by the
standards, which corresponds to the North American Industry
Classification System (NAICS) codes, are listed below for source
category descriptions.

Standard (40 CFR Part 60, Subpart DD)	SIC Codes	NAICS Codes

Administration of Air and Water Resource and Solid Waste Management
Programs	9511	924110

Refuse Systems (solid waste landfills)	4953	562212



	4(b)  Information Requested

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

		(i)  Data Items

	All data in this ICR that is recorded and/or reported is required by
NESHAP for Municipal Solid Waste Landfills (40 CFR part 63, subpart
AAAA).

	

A source must make the following reports:

Notifications	Standard Citation by Sections

Notification of startup, shutdown, and malfunction plan	63.5(b) and
63.1980(b)

Notification of startup, shutdown, and malfunction plan reports	63.6(e)
and 63.1980(b)

Semiannual report of deviation	63.10(d)(5) and 63.1965

Semiannual report of compliance	63.1980(f)



	A source must make the following reports:

Recordkeeping

Record of startup, shutdown, and malfunctions	63.10(b)(1)

Records are required to be retained for five years	63.10(b)(2)



Electronic Reporting

	At the present, respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must evaluate the data, this internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at the plant site.

	Also, regulatory agencies in cooperation with the respondents continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

		(ii)  Respondent Activities

Respondent Activities

Read instructions.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.

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

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

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

Transmit, or otherwise disclose the information.



5.  The Information Collected: Agency Activities, Collection
Methodology, and Information Management

	5(a)  Agency Activities

	EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

Agency Activities

Observe initial performance tests and repeat performance tests if
necessary.

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

Audit facility records.

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

	

5(b)  Collection Methodology and Management

	Following notification of startup, the reviewing authority might
inspect the source to determine whether the pollution control devices
are properly installed and operated.  Performance test reports are used
by the Agency to discern a sources initial capability to comply with the
emission standard.  Data and records maintained by the respondents are
tabulated and published for use in compliance and enforcement programs. 
The semiannual reports are used for problem identification, as a check
on source operation and maintenance, and for compliance determinations.

	Information contained in the reports is entered into the AFS which is
operated and maintained by EPA's Office of Compliance.  AFS is EPA’s
database for the collection, maintenance, and retrieval of compliance
data for approximately 125,000 industrial and government-owned
facilities.  EPA uses the AFS for tracking air pollution compliance and
enforcement by local and state regulatory agencies, EPA regional offices
and EPA headquarters.  EPA and its delegated Authorities can edit,
store, retrieve and analyze the data.

	The records required by this regulation must be retained by the
owner/operator for five years.

	5(c)  Small Entity Flexibility

	A majority of the respondents are large entities (i.e., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  The Agency considers these requirements the minimum
needed to ensure compliance and, therefore, cannot reduce them further
for small entities.  To the extent that larger businesses can use
economies of scale to reduce their burden, the overall burden will be
reduced.

	5(d)  Collection Schedule

	The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NESHAP for
Municipal Solid Waste Landfills (40 CFR Part 63, Subpart AAAA).

6.  Estimating the Burden and Cost of the Collection

	Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where it is appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

	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 three years from
these recordkeeping and reporting requirements is estimated to be 18,234
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of this
regulation, Agency knowledge and experience with the NESHAP program, the
previously approved ICR, and any comments received.

	6(b)  Estimating Respondent Costs

		(i)  Estimating Labor Costs 

 

	This ICR uses the following labor rates: 

		Managerial	$97.46   ($46.41 + 110%)

		Technical	$83.71   ($39.86 + 110%)

		Clerical	$42.55   ($20.26 + 110%)

	These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, “Table 2. Civilian Workers, by
occupational and industry group.”  The rates are from column 1,
“Total compensation.”  The rates have been increased by 110 percent
to account for the benefit packages available to those employed by
private industry.

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

	The type of industry costs associated with the information collection
activities in the subject standard are labor costs which are addressed
elsewhere in this ICR.  The capital/startup costs are not included
because this NESHAP does not require MSW landfills to purchase or
operate additional control equipment or monitoring devices.  The annual
operation and maintenance costs are the ongoing costs associated with
photocopying and postage.

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

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

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondents	(D)

Total Capital/Startup Cost, 

(B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents with O&M	(G)

Total O&M,

(E X F)

N/A	N/A	N/A	N/A	$15	1,121	$16,815



	The total capital/startup costs for this ICR are zero.  This is the
total of column D in the above table.  These costs are shown on the OMB
83-I form in block 14(a), Total annualized capital/startup costs.

	The total operation and maintenance (O&M) costs for this ICR are
$16,815.  This is the total of column G.  These costs are shown on the
OMB 83-I form in block 14(b), Total annual costs (O&M).

	The total respondent costs in block 14 have been calculated as the
addition of the capital/startup costs, and the annual operation and
maintenance costs.  The average annual cost for capital/startup and
operation and maintenance costs to industry over the next three years of
the ICR is estimated to be $17,000 (rounded).  This cost is shown on the
OMB 83-I form in block 14(c), Total annualized cost requested.  The
numbers in block 14 of the OMB 83-I form are rounded to show the cost in
thousands of dollars.

	6(c)  Estimating Agency Burden and Cost

	The only costs to the Agency are those costs associated with analysis
of the reported information.  EPA's overall compliance and enforcement
program includes activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
emissions, and the publication and distribution of collected
information.

	The average annual Agency cost during the three years of the ICR is
estimated to be $777,452.

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

		Managerial	$56.02   (GS-13, Step 5, $35.01 x 1.6)

		Technical	$41.57   (GS-12, Step 1, $25.98 x 1.6)

		Clerical	$22.50   (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2005
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2:  Average Annual EPA
Burden for NESHAP for Municipal Solid Waste Landfills (40 CFR Part 60,
Subpart AAAA), attached.

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

	Based on our research for this ICR, there are approximately 1,119
existing respondents that are subject to the standard.  It is estimated
that one additional respondent per year will become subject over the
next three years.  The overall average number of respondents, as shown
in the table below is 1,121 per year.

	The number of respondents is calculated using the following table which
addresses the three years covered by this ICR.

Number of Respondents

	Respondents That Submit Reports	Respondents That Do Not Submit Any
Reports

	Year	(A)

Number of New Respondents 	(B)

Number of Existing Respondents	(C)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	(D)

Number of Existing Respondents That Are Also New Respondents	

(E)

Number of Respondents

(E=A+B+C-D)

1	1	1,119	0	0	1,120

2	1	1,120	0	0	1,121

3	1	1,121	0	0	1,122

Average	1	1,120	0	0	1,121



	To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 1,121.  This number appears on the OMB 83-I form in block
13(a), Number of respondents.

 

	The total number of annual responses per year is calculated using the
following table: 

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(E)

Total Annual Responses 

E=(BxC)+D

Semiannual compliance reports 	1,121	11	0	1,121

Semiannual SSM reports	1,121	2	0	2,242



	Total	3,363

	1Under the NESHAP rule semiannual compliance reports are required,
however, since one annual compliance report is already under 40 CFR,
part 60, subpart Cc or WWW, this rule required that we increase the
annual burden by one report instead of two for this subpart.

	The number of Total Annual Responses is 3,363.  This number is shown on
the OMB 83-I form in block 13(b), Total annual responses.

		6(e)  Bottom Line Burden Hours and Cost Tables

	The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

		(i) Respondent Tally

	The Total Hours Requested is shown on the OMB 83-I form in block 13(c).
 The total annual labor costs are $1,472,837.  The annual labor costs
are not shown on the OMB 83-I form.  Details regarding these estimates
may be found in Table1.  Annual Respondent Burden and Cost,  NESHAP for
Municipal Solid Waste Landfills (40 CFR Part 63, Subpart AAAA). 
Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 5 hours per
response. 

	The total annual capital/startup and O&M costs to the regulated entity
are $17,000.  This number is shown on the OMB 83-I form in block 14(c),
Total annualized cost requested.  The cost calculations are detailed in
Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M)
Costs.

		(ii) The Agency Tally

	The average annual Agency burden and cost over next three years is
estimated to be 19,177 labor hours at a cost of $777,452.  See Table 2.
Annual Agency Burden and Cost, NESHAP for Municipal Solid Waste
Landfills (40 CFR Part 60, Subpart AAAA).

	6(f)  Reasons for Change in Burden

	The adjustment decrease in burden from the most recently approved ICR
is due to a decrease in the number of sources. After we conducted a
thorough analysis with the municipal solid waste landfills industry and
obtained their spreadsheet that depicts MSW landfills whose 

capacity met or exceeded 2.5 million Mg, we were able to determine that
there are 1,119 active landfills with a projection of one additional
landfill per year over the next three years, for a total average of
1,121 per year, as compared to 1,330 in the previous ICR.  In addition,
the startup, shutdown and malfunction plan has been completed for
existing facilities.  This only applies to a facility when it first
becomes subject to the rule.  The plans were completed, by in large,
during the last ICR cycle.

	There is however, an increase in the reporting and recordkeeping burden
cost.  Even though there is a decrease in the number of sources, the
previous ICR averaged the reporting and recordkeeping burden over the
three years of the active ICR with the first year only accounting for
one source.

	6(g)  Burden Statement

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

	An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
Control Number.  The OMB Control Numbers for EPA’s regulations are
listed at 40 CFR part 9 and 48 CFR chapter 15.

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2005-0031, which is available for public viewing at the
Enforcement and Compliance Docket and Information Center in the EPA
Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Avenue,
NW, Washington, D.C.  The EPA Docket Center Public Reading Room is open
from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal
holidays.  The telephone number for the Reading Room is (202) 566-1744,
and the telephone number for the Enforcement and Compliance Docket and
Information Center is (202) 566-1752.  An electronic version of the
public docket is available at www.regulations.gov. Use
www.regulations.gov to submit or view public comments, to access the
index listing of the contents of the public docket, and to access those
documents in the public docket that are available electronically.  When
in the system, select “search”, then key in the Docket ID Number
identified above.  Also, you can send comments to the Office of
Information and Regulatory Affairs, Office of Management and Budget, 725
17th 

Street, N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA. 
Please include the EPA Docket ID Number EPA-HQ-OECA-2005-0031 and OMB
Control Number 2060-0505 in any correspondence.

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 and Cost – NESHAP for Municipal
Solid Waste Landfills (40 CFR Part 63, Subpart AAAA) 

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per 	year

(Ex0.1)	

(H)

Cost, $  b



1.  Applications	

N/A	

	

	

	

	

	

	





2.  Survey and Studies	

N/A	

	

	

	

	

	

	





3.  Reporting Requirements











    A.  Read instructions c	

10	

1	

10	

1	

10	

0.5	

1	

$1,012.09



    B.  Required activities











     Prepare startup, shutdown d               and malfunction (SSM)
plan	

40	

1	

40	

1	

40	

2	

4	

$3,713.52



    C.  Notification requirements	

	

	

	

	

	

	

	





    Deviation of SSM plan e	

1	

2	

2	

56	

112	

5.6	

11.2	

$10,397.86



    D.  Write report











    Semiannual compliance reports f, g	

2	

1	

2	

1,121	

2,242	

112.1	

224.2	

$208,142.80

      

    Semiannual SSM reports h	

6	

2	

12	

1,121	

13,452	

672.6	

1,345.2	

$1,248,856.76



Subtotals Labor Burden and Cost  	

	

	

	

	

15,856	

792.8	

1,585.6	

$1,472,836.99



TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	

18,234	

$1,472,837



Assumptions:

a  We have assumed that the average number of respondents that will be
subject to the rule will be 1,121.  There will be one additional new
source that will become subject to the rule over the three-year period
of this ICR. 

b  This ICR uses the following labor rates: $97.46 per hour for
Executive, Administrative, and Managerial labor; $83.71 per hour for
Technical labor, and $42.55 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, (Table 2. Civilian Workers, by occupational
and industry group.(  The rates are from column 1, (Total compensation.(
 The rates have been increased by 110% to account for the benefit
packages available to those employed by private industry.

c  We have assumed that it will take 10 hours for a new respondent to
read instructions.

d  It will take respondent 40 hours to prepare SSM plan.   

e  We have assumed that 5 percent of  respondents will deviate from the
SSM plan.  

f  We have assumed that it will take 2 hours for each respondent to
complete the semiannual report.  

g  Under the NESHAP rule semiannual compliance reports are required,
however, since one annual compliance report is already required under 40
CFR part 60, subpart Cc or WWW , this rule requires that we increase the
annual burden by one report instead of two for this subpart. 

h  We have assumed that it will take 6 hours for respondents to complete
the SSM reports.

Table 2:  Average Annual EPA Burden - NESHAP for Municipal Solid Waste
Landfills (40 CFR Part 63, Subpart AAAA) 

	Activity	(A)

EPA person-

hours per

occurrence	(B)

No. of

occurrences

per Agency

and State per year	(C)

Person

hours per

Respondent

(C=AxB)	(D)

Number of Agency and State Personnel  	(E)

Technical

person-hours

per year

(E=CxD)	(F)

Management

person-hours

per year

(Ex0.05)

	(G)

Clerical

person-

hours per year

(Ex0.1)	(H)

Cost, $ a



1.  Read instructions 	

8	

1	

8	

60 b	

480	

24	

48	

$22,378.08



2.  Enter and update information 	

4 c	

1	

4	

1	

4	

0.2	

0.4	

$186.48



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/inspections 	8 d	

1.12 e

	8.96	

50

	

448

	

22.4

	

44.8

	

$20,886.21



5.  Review of SSM notification of deviation 	1 f	1.12 e	1.12	50	56	2.8
5.6	

$2,610.78



 6.  Reporting requirements











   a.  Review compliance report	

6	

22.4 g	

134.4	

50	

6,720	

336	

672	

$313,293.12



   b.  Review SSM plan 	

8 h	

1	

8	

1	

8	

0.4	

0.8	

$372.97



   c.  Review semiannual SSM               reports	4 i	44.8	179.2	50
8,960	448	896	

$417,724.16



TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	19,177	

$777,452

Assumptions:

a  This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $56.02 (GS-13, Step 5, $35.01 x 1.6),
Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical
rate of $22.50 (GS-6, Step 3, $14.06 x 1.6).  These rates are from the
Office of Personnel Management (OPM) (2005 General Schedule( which
excludes locality rates of pay.

b  Due to attrition of personnel and program or agency reorganization,
we have assumed that one agency person in each state and one agency
person in each EPA Region will have to read the regulation each year

c  One respondent will take 4 hours to enter and update information into
agency system. 

    d  We have assumed that  it will take each of the 50 states 8 hours
to conduct an excess emission enforcement activities.

    e  We have assumed that the average occurrences per agency or state
(1.12) is derived from the number of landfills (1,121) subject to the
requirements, divided by the            number of states (50) and
multiply by the percentage of sources that are assumed to have excess
emissions (0.05), thereby eliciting the need for enforcement activities.
 

    f  We have assumed that each of the 50 states will take 1 hour to
review the SSM notification.

    g  We have assumed that the average occurrences per agency or state
(22.4) is derived from the number of landfills (1,121) subject to the
requirements, divided by the             number of states (50) that must
conduct this activity.

    h  We have assumed that the one new source will take 8 hours to
review the SSM plan. 

    i  We have assumed that each of the 50 states will take 4 hours
twice a year to review the SSM reports. 

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