Burden Tables

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Overview

Summary
Table 1A
Table 1B
Table 1C
Table 2
Capital O&M
Respondents
Responses

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Sheet 1: Summary

ICR Summary Information
Hours per Response	651
Number of Respondents	298
Total Estimated Burden Hours	250,000
Total Estimated Costs	$19,800,000
Annualized Capital O&M	$1,180,000
Form Number	Not Applicable

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Sheet 2: Table 1A

	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											Labor
	2. Surveys and Studies	NA											Category	Rates	Occupation Code
	3. Reporting Requirements												Management	$147.74	11-9199
	A. Read and Understand Rule Requirements												Technical - Civil Engineer	$102.14	17-2051
	1. Existing Sources	4	1	4	144	0	576	29	58	$65,623	c		Technical - Civil Engineering Technician	$64.39	17-3022
	2. New sources	40	1	40	1	0	40	2	4	$4,557	c		Clerical	$43.97	43-9061
	B. Required Activities												https://www.bls.gov/oes/current/oes_nat.htm
	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.

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Sheet 3: Table 1B

	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											Labor
	2. Surveys and Studies	NA											Category	Rates	Occupation Code
	3. Reporting Requirements												Management	$147.74	11-9199
	A. Read and Understand Rule Requirements												Technical - Civil Engineer	$102.14	17-2051
	1. Existing Sources	4	1	4	127	0	508	25	51	$57,876	c		Technical - Civil Engineering Technician	$64.39	17-3022
	2. New sources	40	1	40	1	0	40	2	4	$4,557	c		Clerical	$43.97	43-9061
	B. Required Activities												https://www.bls.gov/oes/current/oes_nat.htm
	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		Totals for 1A + 1B
	E. Personnel Training	NA											250,000	Hours
	F. Time for Audits	NA											$18,600,000	$ Labor
	Subtotal for Recordkeeping Requirements					21,638				$2,143,672			$1,180,000	$ Capital/O&M
	Total Labor Burden and Costs (rounded)						90,700			$6,760,000	r		$19,800,000	$ Grand
	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.

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Sheet 4: Table 1C

	Table 1C: Universe of Existing, Modified and Greenfield Landfills Subject to NSPS for Municipal Solid Waste Landfills (40 CFR Part 60, Subpart XXX) (Renewal)
		NSPS only (new/modified after July 2014)							Footnotes
	Burden Item	Number of Respondents			Sector
					Private		Public
		Year 2025	Year 2026	Year 2027	% Respondents	3-Year Average Number Respondents	% Respondents	3-Year Average Number Respondents
	1. Applications
	2. Surveys and Studies
	3. Reporting Requirements
	A. Read and Understand Rule Requirements
	1. Existing Sources	244	271	298	53%	144	47%	127	a			158
	2. New sources	2	2	2	53%	1	47%	1	a
	B. Required Activities											140.06
	1. Initial performance test report	20	0	4	64%	5	36%	3	b
	2. Surface methane monitoring quarterly	244	271	298	64%	173	36%	98	c
	3. Wellhead monitoring monthly	244	271	298	64%	173	36%	98	d
	C. Create Information
	D. Gather Information
	E. Report Preparation
	1. Initial design capacity report	0	0	0	36%	0	64%	0	e
	2. Amended design capacity report	0	0	0		0		0	f
	3. Report of NMOC rate (Tier 1)	29	30	28	36%	10	64%	19	g
	4. Report of NMOC rate (Tier 2)	29	30	28	36%	10	64%	19
	5. Landfill Closure Report	0	0	0					h
	6. Equipment Removal Report	0	0	0					i
	7. Collection and Control System Design Plan	20	0	4	64%	5	36%	3	j
	8. Revised C&C System design plan	2.0	0.0	0.4	64%	0.5	36%	0.3	k
	9. Initial Performance Test	Included in 3B
	10. Compliance Report	Included in 3B
	11. Annual Report	244	271	298	64%	173	36%	98	l
	12. Corrective Action Analysis	2	2	2	50%	1	50%	1	m
	13. Implementation Timeline	2	2	2	50%	1	50%	1	m
	14. Root Cause Analysis	2	2	2	50%	1	50%	1	m
	15. Wet Landfill Monitoring Report	32	32	32	47%	15	53%	17	n
	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)	244	271	298	64%	173	36%	98	o
	2. Recordkeeping and Data Storage (controllers)	244	271	298	64%	173	36%	98	o
	3. Recordkeeping and Data Storage (others)	0	0	0	36%	0	64%	0	p
	E. Personnel Training	NA
	F. Time for Audits	NA
Assumptions:
a	This ICR assumes all existing sources need to re-familiarize with the rule each year, at 4 hours per source, and new sources need to read and understand the rule, at 40 hours for each new greenfield source.
b	One time requirement. The initial year burden reflects that most state plans or federal plans have not yet taken effect. Requirement applies only to landfills that are not "legacy" controllers, i.e. those controlling under the revised more stringent 34 Mg/yr requirement not those already subject to controls under the original 50 Mg/yr requirement.
c	Total number of controllers each year must conduct SEM, recurring requirement. New greenfield sources would not be expected to trigger these requirements.
d	Total number of controllers each year must conduct wellhead, recurring requirement.
e	These are landfills that are smaller than 2.5 million Mg. This ICR assumes new landfills will be large in size so 0 respondents; also a one-time requirement. This ICR assume most of the NSPS sites would be legacy controllers during this reporting period. Legacy controllers are exempt from this requirement.
f	Landfills filing an amended design capacity report under the EG will became subject to XXX.
g	Includes reporters at open landfills that do not meet control thresholds but meet the size thresholds of 2.5 million Mg. Of these, 50% assumed to do Tier 1 and 50% assumed to do Tier 2 calculations. Closed landfills do not have to continue submitting the annual NMOC report.
h	Only applies to EG sources. No NSPS sources would close in this period.
i	Assume 0 equipment removed during the ICR period.
j	The initial year burden reflects that most state plans or federal plans have not yet taken effect. Requirement applies only to landfills that are not "legacy" controllers, i.e. those controlling under the revised more stringent 34 Mg/yr requirement not those already subject to controls under the original 50 Mg/yr requirement.
k	10% of controllers will prepare revised GCCS.
l	Includes all controlling landfills.
m	It is unknown how many landfills will be required to conduct a root cause analysis, corrective action analysis, or 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 the wellhead parameter 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. Landfills can minimize the number of exceedances found by ensuring the GCCS is well-operated. For the purposes of estimating ICR burden, one of the landfills subject to controls will have at least one wellhead exceedance that takes longer than 60 days to correct.
n	Only landfills with leachate recirc or RDD that have capacity >2.5 million Mg must file this report.
o	Includes all controlling landfills.
p	Those that have at least one report but do not control.

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Sheet 5: Table 2

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		Labor Rates
2.	Enter and update information into agency recordkeeping system					2	1	2	271	542	27	54	$34,691	d		Management	$76.91
3.	Required activities												$0			Technical	$57.07
	A.	Observe initial performance test				12	0.2	2	8	19	1	2	$1,229	e		Clerical	$30.88
	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.

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Sheet 6: Capital O&M

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.

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Sheet 7: Respondents

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.

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Sheet 8: Responses

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
				Hours/response	651