NSPS for Municipal Solid Waste Landfills - Publicly Owned

U.S. Environmental Protection Agency

Information Collection Request

Title: NSPS for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart XXX) (Renewal)

OMB Control Number: 2060-0697

EPA ICR Number: 2498.05

Abstract:

The New Source Performance Standards (NSPS) for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart XXX) were promulgated August 29, 2016 (81 FR 59368) and amended on March 26, 2020 (85 FR 17261). These standards apply to municipal solid waste landfills that commenced construction, modification, or reconstruction after July 17, 2014 with a design capacity threshold of 2.5 million Mg and 2.5 million cubic meters. This information is being collected to assure compliance with 40 CFR Part 60, Subpart XXX.

The “Affected Public” are municipal solid waste landfills operated by the public and private landfill owners. It is estimated that on average, 271 existing respondents (municipal solid waste landfills) per year will be subject to these regulations in the next three years based on a design capacity threshold of at least 2.5 million Mg and at least 2.5 million cubic meters. Approximately 2 new and 25 modified municipal solid waste landfills per year will also become subject to these same standards, for an overall total of 298 respondents per year.

The active (previous) ICR (2498.04) had the following Terms of Clearance (TOC):

“Upon resubmission, the program must use the standard 18 question Supporting Statement format.”

In response to the TOC, the EPA is using the standard 18 question Supporting Statement format for this ICR renewal.

Supporting Statement A

1. NEED AND AUTHORITY FOR THE COLLECTION

Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

. . . application of the best technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated. Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every eight years. 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, non-methane organic compound emissions from municipal solid waste landfill either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR Part 60, Subpart XXX.

2. PRACTICAL UTILITY/USERS OF THE DATA

Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

The recordkeeping and reporting requirements in these standards 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 these emission standards. Continuous emission monitors are used to ensure compliance with these standards 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 these standards are used to inform the Agency or its delegated authority when a source becomes subject to the requirements of these regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated, leaks are being detected and repaired, and that these same standards are being met. The performance test may also be observed.

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

3. USE OF TECHNOLOGY

Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

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

The rule was recently amended to include electronic reporting provisions on February 14, 2022. Respondents are required to use the EPA’s Electronic Reporting Tool (ERT) to develop performance test reports and performance evaluation reports and submit them through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI), which can be accessed through the EPA’s Central Data Exchange (CDX) (https://cdx.epa.gov/). The ERT is an application rather than a form, and the requirement to use the ERT is applicable to numerous subparts. The splash screen of the ERT contains a link to the Paperwork Reduction Act (PRA) requirements, such as the OMB Control Number, expiration date, and burden estimate for this and other subparts. The For purposes of this ICR, it is assumed that there is no additional burden associated with the requirement for respondents to submit the notifications and reports electronically. The supplemental files to this ICR renewal contain screenshots showing the CDX homepage for CEDRI login, the CEDRI PRA screen, the CEDRI interface for managing reports for various subparts, and the landing page of the ERT that shows the link to PRA information.

Electronic copies of records may also be maintained in order to satisfy federal recordkeeping requirements. For additional information on the Paperwork Reduction Act requirements for CEDRI and ERT for this rule, see: https://www.epa.gov/electronic-reporting-air-emissions/paperwork-reduction-act-pra-cedri-and-ert.

4. EFFORTS TO IDENTIFY DUPLICATION

Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

For reports required to be submitted electronically, the information is sent through the EPA's CDX, using CEDRI, where the appropriate EPA regional office can review it, as well as state and local agencies that have been delegated authority. If a state or local agency has adopted under its own authority its own standards for reporting or data collection, adherence to those non-Federal requirements does not constitute duplication. 

For all other reports, 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 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, duplication does not exist. 

5. MINIMIZING BURDEN ON SMALL BUSINESSES AND SMALL ENTITIES

If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

Although it is unknown how many new “greenfield” landfills will be owned or operated by small entities, recent trends in the waste industry have been towards consolidated ownership among larger companies. Based on landfills anticipated to modify and become subject to subpart XXX, and the ownership of recent greenfield landfills, the EPA has determined that, based on the percentage of small entities determined in 2016 final rule, approximately thirteen of the privately owned landfills and nine of the publicly owned landfills are small entities.

Subpart XXX does not contain any provisions reserved exclusively for the benefit of small entities. However, the design capacity threshold of less than 2.5 million megagrams and less than 2.5 million cubic meters in 40 CFR 60.762(a) limits the effect of this regulation on smaller landfills, which tend to be owned disproportionately by smaller entities.

However, the final rule provided a non-numeric definition of treatment, which is expected to provide some flexibility for landfills with LFG energy recovery. Since treatment is one of the three compliance pathways for controlling LFG, this ICR does not estimate the number of landfills that may opt to use the treatment pathway for compliance. In addition, while these standards continue to require monthly monitoring of wellhead parameters, the EPA has removed the wellhead operating standards for oxygen/nitrogen, which will reduce the corrective actions, re-monitoring, and requests for alternative timelines. The final rule also included alternative site-specific emission thresholds for determining when a landfill must install (via Tier 4) or remove controls, which are expected to provide flexibility for landfill owners/operators required to control under subpart XXX. The ICR burden was estimated assuming 50% of landfills use Tier 1 and 50% use Tier 2, as industry experience suggests that no landfills are using the Tier 3 approach and it is unknown how many landfills would opt to use Tier 4.

6. CONSEQUENCES OF LESS FREQUENT COLLECTION

Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

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 proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

7. GENERAL GUIDELINES

Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five-year records retention requirement is consistent with the Part 70 permit program and the five-year statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five years. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records.

8. PUBLIC COMMENT AND CONSULTATIONS

8a. Public Comment

If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the Agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the Agency in response to these comments. Specifically address comments received on cost and hour burden.

An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (89 FR 63933) on August 6, 2024. No comments were received on the burden published in the Federal Register for this renewal.

8b. Consultations

Describe efforts to consult with persons outside the Agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately six respondents will be subject to the standard over the three-year period covered by this ICR.

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. In developing this ICR, we contacted both the National Waste & Recycling Association at (202) 244-4700, and the Solid Waste Association of North America at (240) 494-2243. In this case, no comments were received.

It is our policy to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were received.

9. PAYMENTS OR GIFTS TO RESPONDENTS

Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

No payments or gifts are made to respondents.

10. ASSURANCE OF CONFIDENTIALITY

Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.

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).

11. JUSTIFICATION FOR SENSITIVE QUESTIONS

Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the Agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

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

12. RESPONDENT BURDEN HOURS & LABOR COSTS

Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Generally, estimates should not include burden hours for customary and usual business practices.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form and the aggregate the hour burdens.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included as O&M costs under non-labor costs covered under question 13.

12a. Respondents/NAICS Codes

The respondents to the recordkeeping and reporting requirements are municipal solid waste landfills. The United States Standard Industrial Classification (SIC) codes and the corresponding North American Industry Classification System (NAICS) codes for the respondents affected by the standards are listed in the table below:

Standard (40 CFR Part 60, Subpart XXX)	SIC Codes	NAICS Codes
Solid Waste Landfill	4953	562212
Administration of Air and Water Resource and Solid Waste Management Programs	9511	924110

Based on our research for this ICR, on average over the next three years, approximately 271 existing respondents will be subject to the standard. It is estimated that an additional 2 new and 25 modified sources per year will become subject, for an overall total of 298 respondents per year. The number of respondents is calculated using the table Number of Respondents that addresses the three years covered by this ICR. Of the 298 facilities, 140 are owned by either state, local, or the tribal government entities, while 158 facilities are owned and operated by privately-owned, for-profit businesses. We assume that publicly-owned landfills will be operated and managed by private contractors. We assume that they will all respond to EPA inquiries. Based on our consultations with industry representatives, there is an average of one affected facility at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant site).

The total number of annual responses per year is calculated using the table Total Annual Responses shown below. The number of Total Annual Responses is 384.

12b. Information Requested

In this ICR, all the data that are recorded or reported is required by the NSPS for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart XXX). Any owner/operator subject to the provisions of this part shall maintain a file of these measurements and retain the file for at least five years following the date of such measurements, maintenance reports, and records.

A source must make the following reports:

Notifications
Notification of actual startup	§60.7(a)(3)
Notifications of SEM prior to Tier 4	§60.767(l)

Reports
Initial design capacity report and amended design capacity report	§60.7(a)(1), §60.767(a)
Initial and annual (or 5-year) non-methane organic compounds (NMOC) emission rate reports	§60.767(b)
Initial and revised collection and control system design plans	§60.767(c), §60.767(d)
Landfill closure report	§60.767(e)
Equipment removal report	§60.767(f)
Annual operations report	§60.767(g)
Initial performance test report	§60.8, §60.767(h)
Liquids addition (Wet Landfill Annual Report)	§60.767(k)
Electronic reporting	§60.767(i)
High temperature report for sources complying with NESHAP provisions	§60.767(m)
Corrective Action: Root cause analysis, Corrective action analysis, Implementation timeline	§60.767(j), §60.767(g)(7)

A source must keep the following records:

Recordkeeping
Maintain records of maximum design capacity, refuse-in-place, year-by-year waste acceptance rate (maintain for 5 years)	§60.768(a)
Maintain records of system design and initial performance test/compliance determination (must be kept for life of the control equipment; records of subsequent tests must be maintained for 5 years)	§60.768(b)
Maintain records of monitoring of equipment operating parameters for five years	§60.768(c)
Maintain records of collection system plot map and well locations for the life of the landfill (for life of the collection system)	§60.768(d)
Maintain records of collection and control system exceedances of operational standards	§60.768(e)(1), §60.768(e)(2)
Maintain records of root cause analysis conducted, corrective action, and implementation timeline	§60.768(e)(3), §60.768(e)(4), §60.768(e)(5)
Maintain records of date of compliance with NESHAP provisions	§60.768(e)(6)
Maintain records of annual recalculation of site-specific density and design capacity	§60.768(f)
Maintain records of all surface emissions monitoring and information related to instrument calibrations for 5 years (for landfills opting to use the Tier 4 approach)	§60.768(g)
Maintain records of all collection and control system monitoring data for parameters measured	§60.768(h)
Maintain electronic records	§60.768(i)
Maintain records of any engineering calculations or company records used to estimate the quantities of leachate or liquids added	§60.768(j)

12c. Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Calibrate and operate surface emission monitoring equipment for quarterly monitoring and portable LFG emission analyzer equipment for monthly wellhead monitoring.

Estimate NMOC emission estimates using Tier 1, Tier 2, Tier 3 or Tier 4 procedures in the regulation.

Perform initial performance test, Reference Method 25, Method 25A or 25C test, and repeat performance test if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

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

Transmit, or otherwise disclose the information.

12d. Respondent Burden Hours and Labor Costs

Tables 1a and 1b document the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings 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 average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 250,000 hours (Total Labor Hours from Tables 1a and 1b). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NSPS program, the previously approved ICR, and any comments received.

This ICR uses the following labor rates:

Managerial $147.74 ($70.35 + 110%)

Technical - Civil Engineer $102.14 ($48.64 + 110%)

Technical - Civil Engineering Technician $64.39 ($30.66 + 110%)

Clerical $43.97 ($20.94 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2023, “National Occupational Employment and Wage Estimates United States”. The rates are for: Managers, All Other for Managerial Labor; Civil Engineers; Civil Engineer Technicians; and Office Clerks, General for Clerical Labor. The rates are increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

13. Respondent CAPITAL AND O&m CostS

Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).

The cost estimate should be split into two components: (a) a total capital and start-up cost

component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should consider costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling, and testing equipment; and record storage facilities.

If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate.

Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

The type of industry costs associated with the information collection activities in the subject standard(s) are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one-time costs when a facility becomes subject to this regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) and other costs such as photocopying and postage.

The total capital/startup costs for this ICR are $94,400. This is the total of column D shown below in the table Capital/Startup vs. Operation and Maintenance (O&M) Costs.

The total operation and maintenance (O&M) costs for this ICR are $1,090,000. This is the total of column G shown below in the table Capital/Startup vs. Operation and Maintenance (O&M) 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 $1,180,000.

14. AGENCY COSTS

Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

14a. Agency Activities

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

• Observe initial performance tests, repeat performance tests and quarterly surface emissions monitoring (or Tier 4) if necessary.

• Review notifications and reports, including performance test reports, excess emissions reports, root cause and corrective action analysis, implementation timeline, and wet landfill monitoring report required to be submitted by industry.

• Audit facility records.

• Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) and ICIS.

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard, and note the operating conditions under which compliance was achieved. 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 reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. EPA uses ICIS 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.

14b. Agency Labor Cost

The ‘burden’ to the Federal Government is attributed entirely to work performed by either Federal employees or government contractors. The only costs to the Agency are those costs associated with analysis of the reported information. The EPA's overall compliance and enforcement program includes such activities 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 burden and cost during the three years of the ICR is estimated to be 3,100 hours at a cost of $247,000. See Table 2: Average Annual EPA Burden and Cost – NSPS for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart XXX) (Renewal).

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

Managerial $76.91 (GS-13, Step 5, $48.07 + 60%)

Technical $57.07 (GS-12, Step 1, $35.67 + 60%)

Clerical $30.88 (GS-6, Step 3, $19.30+ 60%)

These rates are from the Office of Personnel Management (OPM), 2024 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear at the end of this document in Table 2: Average Annual EPA Burden and Cost – NSPS for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart XXX) (Renewal).

14c. Agency Non-Labor Costs

There are no non-labor costs to the Agency associated with this information collection.

15. REASONS FOR CHANGE IN BURDEN

Explain the reasons for any program changes or adjustments reported in the burden or capital/O&M cost estimates.

The increase in burden from the most recently approved ICR is due to an increase in the number of respondents. The increased number of respondents is based on the assumption that the growth rate will continue to be two new sources per year and 25 modified sources per year that will become subject to this rule. There is an increase in labor costs, which is due to the increased number of respondents and the use of updated labor rates. This ICR uses labor rates from the most recent United States Department of Labor, Bureau of Labor Statistics, “National Occupational Employment and Wage Estimates United States” (May 2023) to calculate respondent burden costs. Similarly, there is an increase in the estimated capital and operation & maintenance costs due to the increased number of respondents.

15. PUBLICATION OF DATA

For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

All non-CBI data submitted electronically to the Agency through CEDRI are available to the public for review and printing and are accessible using WebFIRE. Electronically submitted emissions data from performance testing or performance evaluations using the Electronic Reporting Tool or templates attached to CEDRI, as well as data from reports from regulations with electronic templates, are tabulated; data submitted as portable document format (PDF) files attached to CEDRI are neither tabulated nor subject to complex analytical techniques. Electronically submitted emissions data used to develop emissions factors undergo complex analytical techniques and the draft emissions factors are available on the Clearinghouse for Inventories and Emission Factors listserv at https://www.epa.gov/chief/chief-listserv for public review and printing. Electronically submitted emissions data, as well as other data, obtained from one-time or sporadic information collection requests often undergo complex analytical techniques; results of those activities are included in individual rulemaking dockets and are available at https://www.regulations.gov/ for public review and printing.

15. DISPLAY OF EXPIRATION DATE

If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

EPA will display the expiration date for OMB approval of the information collection.

15. CERTIFICATION STATEMENT

Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

There are no exceptions to the topics of the certification statement.

Table 1A: Annual Respondent Burden and Cost: Privately-Owned Municipal Solid Waste Landfills - NSPS for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart XXX) (Renewal)

	Burden Item	(A) Person Hours per Occurrence	(B) Number of Occurrences Per Respondent Per Year	(C) Technical Person-Hours per Respondent Per Year (A x B)	(D) Average Number of Respondents Per Year a	(E) Civil Engineer Technician Hours per Year (C x D)	(F) Civil Engineer Hours per Year (C x D)	(G) Management Person-Hours per Year (F x .05)	(H) Clerical Person-Hours per Year (F x 0.1)	(I) Total Labor Costs Per Year b	Footnotes
	1. Applications	NA
	2. Surveys and Studies	NA
	3. Reporting Requirements
	A. Read and Understand Rule Requirements
	1. Existing Sources	4	1	4	144	0	576	29	58	$65,623	c
	2. New sources	40	1	40	1	0	40	2	4	$4,557	c
	B. Required Activities
	1. Initial performance test report	12	1	12	5	0	60	3	6	$6,836	d
	2. Surface methane monitoring quarterly	44	4	176	173	30,448	0	0	0	$1,960,425	e
	3. Wellhead monitoring monthly	40	12	480	173	83,040	0	0	0	$5,346,613	e
	C. Create Information	Included in 3B
	D. Gather Information	Included in 3B
	E. Report Preparation
	1. Initial design capacity report	2	1	2	0	0	0	0	0	$0	f
	2. Amended design capacity report	2	1	2	0	0	0	0	0	$0	g
	3. Report of NMOC rate (Tier 1)	8	1	8	10	0	80	4	8	$9,114	h
	4. Report of NMOC rate (Tier 2)	12	1	12	10	0	120	6	12	$13,671	h
	5. Landfill Closure Report	1	1	1	0	0	0	0	0	$0	i
	6. Equipment Removal Report	36	1	36	0	0	0	0	0	$0	i, j
	7. Collection and Control System Design Plan	80	1	80	5	0	400	20	40	$45,571	d, k
	8. Revised C&C System design plan	20	1	20	0.5	0	10	1	1	$1,167	l
	9. Initial Performance Test	Included in 3B
	10. Compliance Report	Included in 3B
	11. Annual Report	27	1	27	173	0	4,671	234	467	$532,158	m
	12. Corrective Action Analysis	15	1	15	1	0	15	1	2	$1,709	n
	13. Implementation Timeline	15	1	15	1	0	15	1	2	$1,709	n
	14. Root Cause Analysis	15	1	15	1	0	15	1	2	$1,709	n
	15. Wet Landfill Monitoring Report	15	1	15	15	0	225	11	23	$25,634	o
	Subtotal for Reporting Requirements					120,649				$8,016,496
	4. Recordkeeping Requirements
	A. Read Instructions	Included in 3A
	B. Plan Activities	NA
	C. Implement Activities	NA
	D. Develop Record System	NA
	E. Record Information
	1. Data Compilation and Review (controllers)	5	12	60	173	0	10,380	519	1,038	$1,182,574	p
	2. Recordkeeping and Data Storage (controllers)	11	12	132	173	0	22,836	1,142	2,284	$2,601,663	p
	3. Recordkeeping and Data Storage (others)	4	1	4	0	0	0	0	0	$0	q
	E. Personnel Training	NA
	F. Time for Audits	NA
	Subtotal for Recordkeeping Requirements					38,198				$3,784,237
	Total Labor Burden and Costs (rounded)					159,000				$11,800,000	r
	Total Capital and O&M Cost (rounded)									$732,000	r
	Grand Total (rounded)									$12,530,000	r
Assumptions:
a	We assume that an average of 271 respondents will be subject to this rule, and that 2 new sources and 25 modified sources will become subject to the rule each year over the three-year period of the ICR.
b	This ICR uses mean hourly wage for the following labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2023, “National Occupational Employment and Wage Estimates United States” for employees at privately-owned landfills: Managers, All Other for Managerial Labor, Civil Engineers, Civil Engineer Technicians, and Office Clerks, General for Clerical Labor. The rates have been increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c	We have assumed that each existing respondent will take 4 hours to read instructions as part of their reporting requirements. We estimate that, over the three-year period of this ICR, an average of 2 new respondents per year (1 privately-owned and 1 publicly-owned) will need to familiarize with the requirements of the rule. We have assumed that each new respondent will take 40 hours to read instructions as part of their reporting requirements.
d	We estimate that, over the three-year period of this ICR, an average of 8 respondents per year (5 privately-owned and 3 publicly-owned) will need to install controls, perform the initial performance test, and submit an initial performance test report. We assume that each respondent will take 12 hours to attend the test, review the report (written by the testing company), and submit the report. Based on the regulatory database, 64% of these respondents are private and 36% are public.
e	For surface monitoring, the average acreage of controlled sites is estimated to be 174 acres and we estimate monitoring labor at 0.25 hours per acre for a total of 44 labor hours (174 acres x 0.25 hr/acre = 43.5 hours, rounded to 44) per monitoring event. For wellhead monitoring, the estimated burden was based on industry consultation of $2000 per month during the most recent ICR renewal for subpart WWW (ICR# 1557.09), or approximately 40 hours of technician labor time. Cost of re-monitoring for exceedances of surface monitoring or wellhead monitoring are not included because the rule does not require re-monitoring unless an exceedance is found. Landfills can minimize the number of exceedances found by ensuring the GCCS is well-operated and the surface is well sealed.
f	The initial design capacity report applies to new landfills with a design capacity smaller than 2.5 million Mg. We assume that all new landfills will have a design capacity exceeding 2.5 million Mg. Therefore, this one-time requirement will not apply to new landfills. We assume that the existing NSPS landfills with design capacity less than 2.5 million Mg have submitted this report, and are therefore exempt from this requirement.
g	We assume that no landfills currently subject to Subpart XXX will submit an amended design capacity report during the three-year period of this ICR.
h	We estimate that, over the three-year period of this ICR, an average of 29 respondents per year (10 privately-owned and 19 publicly-owned) will submit Tier 1 reports and another 29 respondents will submit Tier 2 reports. We assume that 50 percent of uncontrolled landfills will use Tier 1 calculations annually and 50 percent will use Tier 2 calculations once every 5 years for their NMOC reports. Of the landfills estimated to remain uncontrolled in the regulatory database 64% are public and 36% are private.
i	We have assumed that no controlled landfill will close or remove equipment during this ICR period. None of the greenfields or modified sources are predicted to close during this ICR period.
j	Equipment Removal Report requires inclusion of 3 successive NMOC rates using Tier 2 calculations to demonstrate landfill is below the NMOC threshold.
k	Prior to installing a collection and control system, a landfill is required to submit a Collection and Control System Design Plan for approval. This requirement applies only to landfills controlling under the revised 34 Mg/yr requirement. This requirement does not apply to landfills that are "legacy" controllers (i.e. those landfills already subject to controls under the original 50 Mg/yr requirement).
l	We have assumed that 10% of landfills installing a collection and control system will revise their design plan. We estimate that, over the three-year period of this ICR, an average of 8 respondents per year (5 privately-owned and 3 publicly-owned) will submit a Collection and Control System Design Plan. This results in submittal of 0.8 C&C System Design Plan revisions per year (5 x 0.1 + 3 x 0.1 = 0.8 revisions/year).
m	All controlled landfills are required to submit an annual report. The estimated burden was based on industry consultation of $5000 per year for compliance reporting (see comment on recent ICR renewal for subpart WWW, ICR# 1557.09). Since this estimate included an assumption of a semi-annual report to satisfy the requirements of the landfills NESHAP, we adjusted this estimate by half to account for the single report required by this NSPS, or $2500, which is approximately 27 technical hours per occurrence.
n	We assume that, during the three-year period of this ICR, an average of one privately-owned landfill per year and one publicly-owned landfill per year will be required to conduct a root cause analysis, corrective action analysis, and implementation timeline. These items are not required by the rule for controlling landfills. A root cause analysis is only required if the landfill has an exceedance of a wellhead parameter that is identified and cannot be corrected within 15 days. If the exceedance cannot be corrected within 60 days the owner or operator must also conduct a corrective action analysis and develop and implementation schedule. These items must only be submitted for approval if the corrective action will take longer than 120 days to correct.
o	Landfills with a design capacity equal to or greater than 2.5 million megagrams and 2.5 million cubic meters that have employed leachate recirculation or added liquids based on a Research, Development, and Demonstration permit must file this report.
p	The estimated burden was based on industry consultation of $1000 per month for recordkeeping and data storage per month and $500 for data compilation and review per month (see comment on recent ICR renewal for subpart WWW, ICR# 1557.09). This is approximately 5 technical hours per occurrence for data compilation and review and 11 hours for recordkeeping and data storage.
q	The respondents subject to this recordkeeping requirement (0) have a reporting requirement but are not required to control.
r	Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Table 1B: Annual Respondent Burden and Cost: Publicly-Owned Municipal Solid Waste Landfills - NSPS for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart XXX) (Renewal)

	Burden Item	(A) Person Hours per Occurrence	(B) Number of Occurrences Per Respondent Per Year	(C) Technical Person-Hours per Respondent Per Year (A x B)	(D) Average Number of Respondents Per Year a	(E) Civil Engineer Technician Hours per Year (C x D)	(F) Civil Engineer Hours per Year (C x D)	(G) Management Person-Hours per Year (F x .05)	(H) Clerical Person-Hours per Year (F x 0.1)	(I) Total Labor Costs Per Year b	Footnotes
	1. Applications	NA
	2. Surveys and Studies	NA
	3. Reporting Requirements
	A. Read and Understand Rule Requirements
	1. Existing Sources	4	1	4	127	0	508	25	51	$57,876	c
	2. New sources	40	1	40	1	0	40	2	4	$4,557	c
	B. Required Activities
	1. Initial performance test report	12	1	12	3		36	2	4	$4,101	d
	2. Surface methane monitoring quarterly	44	4	176	98	17,248	0	0	0	$1,110,530	e
	3. Wellhead monitoring monthly	40	12	480	98	47,040	0	0	0	$3,028,717	e
	C. Create Information	Included in 3B
	D. Gather Information	Included in 3B
	E. Report Preparation
	1. Initial design capacity report	2	1	2	0	0	0	0	0	$0	f
	2. Amended design capacity report	2	1	2	0	0	0	0	0	$0	g
	3. Report of NMOC rate (Tier 1)	8	1	8	19	0	152	8	15	$17,317	h
	4. Report of NMOC rate (Tier 2)	12	1	12	19	0	228	11	23	$25,976	h
	5. Landfill Closure Report	1	1	1	0	0	0	0	0	$0	i
	6. Equipment Removal Report	36	1	36	0	0	0	0	0	$0	i, j
	7. Collection and Control System Design Plan	80	1	80	3	0	240	12	24	$27,343	d, k
	8. Revised C&C System design plan	20	1	20	0.3	0	6	0	1	$656	l
	9. Initial Performance Test	Included in 3B
	10. Compliance Report	Included in 3B
	11. Annual Report	27	1	27	98	0	2,646	132	265	$301,454	m
	12. Corrective Action Analysis	15	1	15	1	0	15	1	2	$1,709	n
	13. Implementation Timeline	15	1	15	1	0	15	1	2	$1,709	n
	14. Root Cause Analysis	15	1	15	1	0	15	1	2	$1,709	n
	15. Wet Landfill Monitoring Report	15	1	15	17	0	255	13	26	$29,052	o
	Subtotal for Reporting Requirements					69,067				$4,612,705
	4. Recordkeeping Requirements
	A. Read Instructions	Included in 3A
	B. Plan Activities	NA
	C. Implement Activities	NA
	D. Develop Record System	NA
	E. Record Information
	1. Data Compilation and Review (controllers)	5	12	60	98	0	5,880	294	588	$669,898	p
	2. Recordkeeping and Data Storage (controllers)	11	12	132	98	0	12,936	647	1,294	$1,473,775	p
	3. Recordkeeping and Data Storage (others)	4	1	4	0	0	0	0	0	$0	q
	E. Personnel Training	NA
	F. Time for Audits	NA
	Subtotal for Recordkeeping Requirements					21,638				$2,143,672
	Total Labor Burden and Costs (rounded)						90,700			$6,760,000	r
	Total Capital and O&M Cost (rounded)									$451,000	r
	Grand Total (rounded)									$7,210,000	r
Assumptions:
a	We assume that an average of 271 respondents will be subject to this rule, and that 2 new sources and 25 modified sources will become subject to the rule each year over the three-year period of the ICR.
b	This ICR uses mean hourly wage for the following labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2023, “National Occupational Employment and Wage Estimates United States” for employees at privately-owned landfills: Managers, All Other for Managerial Labor, Civil Engineers, Civil Engineer Technicians, and Office Clerks, General for Clerical Labor. The rates have been increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees. We assume that publicly-owned landfills will be operated and managed by private contractors.
c	We have assumed that each existing respondent will take 4 hours to read instructions as part of their reporting requirements. We estimate that, over the three-year period of this ICR, an average of 2 new respondents per year (1 privately-owned and 1 publicly-owned) will need to familiarize with the requirements of the rule. We have assumed that each new respondent will take 40 hours to read instructions as part of their reporting requirements.
d	We estimate that, over the three-year period of this ICR, an average of 8 respondents per year (5 privately-owned and 3 publicly-owned) will need to install controls, perform the initial performance test, and submit an initial performance test report. We assume that each respondent will take 12 hours to attend the test, review the report (written by the testing company), and submit the report. Based on the regulatory database, 64% of these respondents are private and 36% are public.
e	For surface monitoring, the average acreage of controlled sites is estimated to be 174 acres and we estimate monitoring labor at 0.25 hours per acre for a total of 44 labor hours (174 acres x 0.25 hr/acre = 43.5 hours, rounded to 44) per monitoring event. For wellhead monitoring, the estimated burden was based on industry consultation of $2000 per month during the most recent ICR renewal for subpart WWW (ICR# 1557.09), or approximately 40 hours of technician labor time. Cost of re-monitoring for exceedances of surface monitoring or wellhead monitoring are not included because the rule does not require re-monitoring unless an exceedance is found. Landfills can minimize the number of exceedances found by ensuring the GCCS is well-operated and the surface is well sealed.
f	The initial design capacity report applies to new landfills with a design capacity smaller than 2.5 million Mg. We assume that all new landfills will have a design capacity exceeding 2.5 million Mg. Therefore, this one-time requirement will not apply to new landfills. We assume that the existing NSPS landfills with design capacity less than 2.5 million Mg have submitted this report, and are therefore exempt from this requirement.
g	We assume that no landfills currently subject to Subpart XXX will submit an amended design capacity report during the three-year period of this ICR.
h	We estimate that, over the three-year period of this ICR, an average of 29 respondents per year (10 privately-owned and 19 publicly-owned) will submit Tier 1 reports and another 29 respondents will submit Tier 2 reports. We assume that 50 percent of uncontrolled landfills will use Tier 1 calculations annually and 50 percent will use Tier 2 calculations once every 5 years for their NMOC reports. Of the landfills estimated to remain uncontrolled in the regulatory database 64% are public and 36% are private.
i	We have assumed that no controlled landfill will close or remove equipment during this ICR period. None of the greenfields or modified sources are predicted to close during this ICR period.
j	Equipment Removal Report requires inclusion of 3 successive NMOC rates using Tier 2 calculations to demonstrate landfill is below the NMOC threshold.
k	Prior to installing a collection and control system, a landfill is required to submit a Collection and Control System Design Plan for approval. This requirement applies only to landfills controlling under the revised 34 Mg/yr requirement. This requirement does not apply to landfills that are "legacy" controllers (i.e. those landfills already subject to controls under the original 50 Mg/yr requirement).
l	We have assumed that 10% of landfills installing a collection and control system will revise their design plan. We estimate that, over the three-year period of this ICR, an average of 8 respondents per year (5 privately-owned and 3 publicly-owned) will submit a Collection and Control System Design Plan. This results in submittal of 0.8 C&C System Design Plan revisions per year (5 x 0.1 + 3 x 0.1 = 0.8 revisions/year).
m	All controlled landfills are required to submit an annual report. The estimated burden was based on industry consultation of $5000 per year for compliance reporting (see comment on recent ICR renewal for subpart WWW, ICR# 1557.09). Since this estimate included an assumption of a semi-annual report to satisfy the requirements of the landfills NESHAP, we adjusted this estimate by half to account for the single report required by this NSPS, or $2500, which is approximately 27 technical hours per occurrence.
n	We assume that, during the three-year period of this ICR, an average of one privately-owned landfill per year and one publicly-owned landfill per year will be required to conduct a root cause analysis, corrective action analysis, and implementation timeline. These items are not required by the rule for controlling landfills. A root cause analysis is only required if the landfill has an exceedance of a wellhead parameter that is identified and cannot be corrected within 15 days. If the exceedance cannot be corrected within 60 days the owner or operator must also conduct a corrective action analysis and develop and implementation schedule. These items must only be submitted for approval if the corrective action will take longer than 120 days to correct.
o	Landfills with a design capacity equal to or greater than 2.5 million megagrams and 2.5 million cubic meters that have employed leachate recirculation or added liquids based on a Research, Development, and Demonstration permit must file this report.
p	The estimated burden was based on industry consultation of $1000 per month for recordkeeping and data storage per month and $500 for data compilation and review per month (see comment on recent ICR renewal for subpart WWW, ICR# 1557.09). This is approximately 5 technical hours per occurrence for data compilation and review and 11 hours for recordkeeping and data storage.
q	The respondents subject to this recordkeeping requirement (0) have a reporting requirement but are not required to control.
r	Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Table 2: Average Annual EPA Burden and Cost – NSPS for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart XXX) (Renewal)

Burden Item			(A) EPA hours per occurrence	(B) Number of occurrences per plant per year	(C) EPA person-hours per plant per year (C=AxB)	(D) Plants per year a	(E) Technical hours per year (CxD)	(F) Management hours per year (F=Ex0.05)	(G) Clerical hours per year (G=Ex0.1)	(H) Costs, $ b	Footnotes
1.	Read and understand rule requirements (10 EPA Regions)		4	1	4	10	40	2	4	$2,560	c
2.	Enter and update information into agency recordkeeping system		2	1	2	271	542	27	54	$34,691	d
3.	Required activities									$0
	A.	Observe initial performance test	12	0.2	2	8	19	1	2	$1,229	e
	B.	Observe surface methane monitoring quarterly	20	0.2	4	271	1,084	54	108	$69,382	e
	C.	Review operating parameters	1	1	1	8	8	0	1	$512	f
	D.	Review continuous parameter monitoring	1	1	1	8	8	0	1	$512	f
	E.	Review notification of performance test	2	1	2	8	16	1	2	$1,024	f
4	Excess Emissions Enforcement Activities		24	0.1	2	8	19	1	2	$1,229	g
5.	Reporting requirements									$0
	A.	Review initial design capacity report	1	1	1	0	0	0	0	$0	h
	B.	Review amended design capacity report	2	0	0	0	0	0	0	$0	i
	C.	Review annual NMOC emission rate report	2	1	2	58	116	6	12	$7,425	j
	D.	Review landfill closure report	1	1	1	0	0	0	0	$0	k
	E.	Review equipment removal report	1	1	1	0	0	0	0	$0	k
	F.	Review Collection and Control System Design Plan	15	1	15	8	120	6	12	$7,681	e, l
	G.	Review Revised Collection and Control System Design Plan	5	0.1	1	1	0	0	0	$26	m
	H.	Review Initial Performance Test Report	12	1	12	8	96	5	10	$6,145	e
	I.	Review Annual Report	2	1	2	271	542	27	54	$34,691	n
	J.	Review Corrective Action Analysis	3.75	1	4	2	8	0	1	$480	o
	K.	Review Implementation Timeline	3.75	1	4	2	8	0	1	$480	o
	L.	Review Root Cause Analysis	3.75	1	4	2	8	0	1	$480	o
	M.	Wet Landfills Monitoring Report	2	1	2	32	64	3	6	$4,096	p
7.	Travel Expenses for Tests Attended		3 days * ($164 hotel + $81 meals/incidentals) + ($600 round trip) = $1335 per trip			56				$74,493	q
TOTAL (Rounded)							3,100			$247,000	r
Assumptions:
a	We assume that an average of 271 respondents will be subject to this rule, and that 2 new sources and 25 modified sources will become subject to the rule each year over the three-year period of the ICR.
b	This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2024 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c	The number of plants per year is the number of EPA Regions (10 regions). We assume one EPA employee at each Region offices familiarizes with the rule each year.
d	The number of plants per year is based on the total number of landfills that are subject to the standard as well as the number of sources that fall below the thresholds of the standard.
e	The number of observations of initial performance tests and surface methane monitoring per year is based on the assumption that EPA personnel will observe 20% of the landfills where initial performance tests (8 per year)and surface methane monitoring (271 per year) occur.
f	The number of plants is based on the average number of landfills per year expected to install controls, perform the initial performance test, begin monitoring operating parameters, and submit an initial performance test report during the three-year period of this ICR.
g	The number of plants per year is based on the assumption that of the landfills that do the initial performance test, 10% of them will have exceedances and need enforcement.
h	The initial design capacity report applies to new landfills with a design capacity smaller than 2.5 million Mg. We assume that all new landfills will have a design capacity exceeding 2.5 million Mg. Therefore, this one-time requirement will not apply to new landfills. We assume that the existing NSPS landfills with design capacity less than 2.5 million Mg have submitted this report, and are therefore exempt from this requirement.
i	We assume that no landfills currently subject to Subpart XXX will have modifications requiring the submittal of an amended design capacity report during the three-year period of this ICR.
j	The number of plants is the number of uncontrolled landfills that use Tier 1 or Tier 2 calculations for their NMOC reports. We estimate that, over the three-year period of this ICR, an average of 58 respondents per year will submit Tier 1 or Tier 2 reports.
k	We assume that no controlled landfill will close or remove equipment during the three-year period of this ICR.
l	We estimate that an average of 8 landfills per year will submit a Collection and Control System Design Plan for approval during the three-year period of this ICR. This requirement applies only to landfills controlling under the revised 34 Mg/yr requirement. This requirement does not apply to landfills that are "legacy" controllers ( i.e. those landfills already subject to controls under the original 50 Mg/yr requirement).
m	We assume that 10 percent of respondents submitting a collection and control system design plan will submit a revised design plan to account for changes to the landfill or the GCCS as allowed for in 60.767(h).
n	All controlled landfills are required to submit an annual report. We estimate that, over the three-year period of this ICR, an average of 271 respondents per year operating controlled landfills will need to submit this report.
o	Number of plants is based on the assumption that one public and one private landfill subject to controls will have at least one wellhead exceedance that takes longer than 60 days to correct.
p	We assume that, during the three-year period of this ICR, 15 privately-owned landfills and 17 publicly-owned landfills will be required to file this report each year.
q	Total cost is based on the number of trips taken by EPA to observe performance tests in year 1 (3.A. & 3.B.) multiplied by $1335 per trip. The source for hotel and meals/incidental costs is based on FY'25 per diem rates, averaged across all locations in the United States. Airfares are estimated based on experience from other rulemakings. See: https://www.gsa.gov/travel/plan-a-trip/per-diem-rates/per-diem-files#Per-diem-rates
r	Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	Number of Existing Respondents b	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	27	244	0	0	271
2	27	271	0	0	298
3	27	298	0	0	325
Average	27	271	0	0	298
a Based on the data sources used to support the 2016 NSPS rulemaking, there were 14 new landfill over an 8-year period (2 new landfills per year) and 123 modified landfills over a 5-year period (25 modified landfills per year).
b The 'Number of Existing Respondents' in year 3 (217) of the previous ICR (2498.04) has been incremented by 27 modified and new sources (217 + 27 = 244) to reflect the number of existing respondents in Year 1 of this ICR.

Total Annual Number of Responses
(A) Information Collection Activity	(B1) Number of Privately-owned Respondents	(B2) Number of Publicly-owned Respondents	(C) Number of Responses per Respondent	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Responses E=(B1+B2)xC+D
Initial performance test report	5	3	1	NA	8
Initial design capacity report	0	0	1	NA	0
Amended design capacity report	0	0	1	NA	0
Report of NMOC rate (Tier 1)	10	19	1	NA	29
Report of NMOC rate (Tier 2)	10	19	1	NA	29
Landfill Closure Report	0	0	1	NA	0
Equipment Removal Report	0	0	1	NA	0
Collection and Control System Design Plan	5	3	1	NA	8
Revised C&C System design plan	0.5	0.3	1	NA	0.8
Annual Report	173	98	1	NA	271
Corrective Action Analysis	1	1	1	NA	2
Implementation Timeline	1	1	1	NA	2
Root Cause Analysis	1	1	1	NA	2
Wet Landfill Monitoring Report	15	17	1	NA	32
Total Annual Number of Responses					384

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Annualized Capital/Startup Cost for One Respondent	Average Number of Respondents per Year	Total Annualized Capital / Startup Cost, (C x D) per Year	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M (F x G)
Method 25 or 25C testing costs for initial performance test a	$10,067	$1,105	8	$8,842	$0	0	$0
Sampling probe and Method 25 or 25C testing costs for Tier 2 test b	$11,104	$2,708	29	$78,540	$0	0	$0
Method 21 Surface Emission Monitor c	0	0	0	$0	$2,814	271	$762,594
Portable Wellhead Monitor d	0	0	0	$0	$204	271	$55,284
Flow Meter e, f	$3,000	$329	8	$2,635	$1,000	271	$271,000
Thermocouple e, f	$500	$55	8	$439
Data Recorder e, f	$4,500	$494	8	$3,953
Totals (Rounded)				$94,400			$1,090,000
Grand Total (Rounded)							$1,180,000
a This requirement applies only to new landfills requiring controls and existing landfills that are not "legacy" controllers, i.e. those controlling under the revised more stringent 34 Mg/yr requirement and not those already subject to controls under the original 50 Mg/yr requirement. Annualized cost is figured for method 25 or 25C test at 7% over 15 years, which is the expected lifetime of the flare or other destruction device.
b Tier 2 testing is done by operating landfills that do not meet control thresholds but meet the size thresholds of 2.5 million Mg. Of these 58 landfills, 50% assumed to do Tier 1 testing and 50% assumed to do Tier 2 testing. Since a Tier 2 test must be repeated every 5 years, annualized capital cost is based on the cost for conducting a method 25, method 25A or 25C test, figured at 7% over 5 years.
c All controlled landfills must conduct quarterly surface emissions testing at all penetrations of the cover. We assume weekly equipment rental costs at $600/week, and one week per occurrence. In addition, the landfill will need to purchase calibration gases and hydrogen fuel (at a cost of $103.50 per event) to operate the surface monitoring equipment.
d All controlled landfills must conduct monthly wellhead monitoring.
e Sources required to install a control system purchase and install this equipment prior to their initial performance test. All sources operating controls maintain this equipment annually. Annualized cost is figured at 7% over 15 years.
f All sources operating controls maintain the flow meter, thermocouple, and data recorder annually at a cost of $1,000.

5