### 1 MEMORANDUM

TO: Hillary Ward, U.S. Environmental Prot ection Agency, OAQPS/Sector Policies and Programs Division, Fuel and Incineration Group

FROM: Eastern Research Group, Inc. (ERG)

DATE: April 2014

SUBJECT: Methodology for Estimating Testing and Monitoring Costs for the MSW Landfill Regulations



### Introduction

This memo presents the assumptions and equations used to calculate testing and monitoring costs for landfills that would be affected by the review of the new source performance standards (NSPS) for municipal solid waste (MSW) landfills. This memo summarizes those testing and monitoring costs for
both uncontrolled and controlled landfills that would be subject to the landfills NSPS. These costs are one
element of the overall cost estimates used to anal yze the impacts. A separate memorandum summarizes the total cost (control, testing, and monitoring) of each regulatory option that EPA considered for proposal. 1

The types of testing and monitoring required by the proposal differ depending on whether the landfill is required to control its emissions. Ta ble 1 shows the various testing and monitoring requirements that would apply to controlled and unc ontrolled landfills. For this analysis, it was assumed that if controls were required to be installed by 2023, the landfill was considered to be a controlled landfill, and it would incur the testing and monitoring costs associated with be ing controlled. A separate memorandum discusses the approach for determining wh en and whether a landfill would install controls and the estimated schedule for installing contro ls on each landfill covered under the analysis. 2

Table 1. Applicability of Various T esting and Monitoring Requirements Testing and Monitoring Requirement Applicability

NMOC Emission Rate



###  Annual (Tier 1)



###  Once every 5 years (Tier 2) Uncontrolled Landfills

Initial Performance Tests



###  NMOC % destruction or control device outlet ppmvd



###  Oxygen Controlled Landfills

1 ERG. 2014. Cost and Emission Impact s Resulting from the Landfill NSPS Review.

2 ERG. 2014. Methodology for Estimating Cost and Emission Impacts of Proposed MSW Landfill Regulations.

### 2 Table 1. Applicability of Various T esting and Monitoring Requirements Testing and Monitoring Requirement Applicability Continuous Combustor Monitoring



###  Temperature



###  Flowrate Controlled Landfills

Monthly Wellhead Monitoring



###  Nitrogen or oxygen



###  Gauge pressure



###  Temperature Controlled Landfills

Quarterly Surface Monitoring Controlled Landfills Integrated Sample Calculations Controlled Landfills – Enhanced Monitoring Option Only Improved Surface Maintenance Controlled Landfills – Enhanced Monitoring Option Only

1. Labor Rates

Several of the testing and monitoring requirement s require labor to complete the activities in addition to capital expenditures for purchasing the mon itoring equipment. This analysis assumes that a Civil Engineer or Civil Engineer Technician completes the testing and monitoring requirements of the proposal. The mean hourly wage for these professions is presented in Table 2. The latest wage data are from May 2012. The wage rates were adjusted to in clude benefits and office overhead-related expenses.

Table 2. Labor Rates used in Test ing and Monitoring Cost Analysis

Occupation Unloaded National Mean Wage Rate 3 Adjustment Factor Loaded Wage Rate Civil Engineer $40.45 39.76 + 110%(40.45) $84.95 Civil Engineering

Technician $23.66 23.66 + 110%(23.66) $49.69



### 2. Costs for Uncontrolled Landfills

2.1 NMOC Emission Rate

The only testing and monitoring requirement for unc ontrolled landfills is to periodically calculate
the NMOC emission rates to determine when the landf ill must install controls. The NSPS allows landfills three methods (tiers) for determining their NMOC ra tes. Although the number of landfills using each tier of reporting is unknown, industry experience suggest s that there are a significant number of landfills reporting under the Tier 2 method, which allows the s ite to measure a site-specific NMOC concentration instead of using the higher default NMOC concentra tions required under the Tier 1 calculations. Similar industry experience suggests that the Tier 3 calculation option is not widely used.

This analysis assumes that 50 percent of uncontrolled landfills use Tier 1 calculations and 50 percent use Tier 2 calculations. Some uncontrolled la ndfills are small enough to use the Tier 1 defaults
and still remain under the threshold re quiring the site to control. Howeve r, many of the larger sites may

3 US Bureau of Labor and Statistics. Ma y 2012 Occupational Employment Statistics.

http://www.bls.gov/oes/current/oes_nat.htm#17-0000

### 3 opt to use Tier 2 testing if their Tier 1 calculations exceed the NMOC thresholds that trigger the control requirements in the NSPS.

2.2 Tier 1 Costs

The cost to prepare and submit the NMOC report is based on an estimated 8 hours of a Civil Engineer’s time to collect the data (e.g., historic records of waste age, mass of waste in place, annual waste acceptance waste) used for the LandGEM modeling, to run the model, and to report the results. The Tier 1 report is required annually.

Eq. 1 : 8 hours * $84.95/hr = $680

2.3 Tier 2 Costs

The cost to conduct a Tier 2 test for site-speci fic NMOC values, which can be obtained using Method 25 or 25C, was estimated using the EPA Mon itoring Costs and Benefits tool, which estimates a Method 25A test to cost $10,067. 4 The EPA Monitoring Costs and Benefits tool does not include an estimate for Method 25 or 25C, but the costs estimated for Method 25A are expected to be similar to the methods allowed under the proposal. This test is incurred once every 5 years.

In addition to the capital costs to conduct this test , there is time associated with gathering the samples and reporting the results. We used the Info rmation Collection Request (ICR) burden estimate of 12 hours of a Civil Engineer’s time or 12 * 84.95 = $1,019. 5 The annualized cost of this test, including labor, over 5 years at a 7 percent inte rest rate is shown by Equation 2:

Eq. 2 : ($10,067 + $1,019)*{0.07(1 + 0.07)^5} / {[(1 + 0.07)^5]-1} = $2,700



### 3. Costs for Controlled Landfills

3.1 Initial Performance Testing

The current NSPS requires an initial test of the combustion control equipment in order to demonstrate compliance with the 98 percent NM OC reduction requirement or the 20 ppmvd NMOC concentration adjusted to 3 percent oxygen. This test will be conducted using Method 25 or 25C.

The estimated performance testing cost is $10,067, which is expected to be the same as Method 25 or 25C, according to the EPA Monitoring Costs and Benefits tool. 6 This cost was annualized over 15 years, consistent with the expected lifetime of the combustion control equipment, at a 7 percent interest rate. The annualized cost for the initial perfo rmance test is expressed in Equation 3:

Eq. 3 : 10,067* {0.07(1 + 0.07)^15} / {[(1 + 0.07)^15]-1} = $1,105

4 USEPA Monitoring Costs Asse ssment Tool. November 30, 2009.

5 See supporting statement for approved ICR 1557.08, line item for Report of tier 2 and 3 NMOC sampling Change.

ICR available online at http://www.reginfo.gov/pu blic/do/PRAViewDocument?ref_nbr=201112-2060-017

6 USEPA Monitoring Costs Asse ssment Tool. November 30, 2009.

### 4 3.2 Continuous Combustor Monitoring

The NSPS requires continuous monitoring of th e flowrate to the control device and the temperature of the enclosed flare or other enclo sed combustion device. It is common practice for the flowrate and temperature to be monitored and recorded at landfills with energy projects in order to meet contractual requirements, safety protocols, and protect the investment in the en ergy infrastructure. The LFGcost model algorithms (used to estimate NSPS contro l costs) bases its enclosed flare and engine costs on landfills with energy projects. Therefore, these c ontinuous monitoring costs are included in the control

cost estimates described in the control cost memora ndum because the flares and engines at these sites are typically equipped with sensors to monitor these parameters. 7

3.3 Monthly Wellhead Monitoring

The rule requires monthly monitoring of nitroge n or oxygen, pressure, and temperature at gas wells. Such well monitoring activities are included in the well O&M costs estimated for the NSPS using the LFGcost model algorithms. This model bases well field O&M cost data on landfills with LFG energy projects installed. These landfills would already monito r these wellhead parameters in order to maintain a well balanced gas collection system and gas quality fo r their energy project. Therefore, these costs are already included in the well O&M cost line ite m discussed in the control cost memorandum. 8

3.4 Quarterly Surface Monitoring

The current NSPS requires a technician to traverse the controlled sections of the landfill at 30
meter intervals to measure methane concentrations us ing a portable analyzer. This analysis assumes that most landfills will contract out their surface monitoring requirements and the contracted price to complete the monitoring requirement would include both an hou rly labor rate and an equipment rental rate.

The length of time for each rental was estimated by determining the controlled acreage of each landfill, as discussed below, and multiplying this acr eage by an hour per acre estimate to obtain an estimate of total hours per landfill for each quarterly monitoring occurrence. The 2009 South Coast Air Quality Management District (SCAQMD) landfill regul ations included estimates of 1 hour of a Civil Engineering Technician’s time per acre to complete surface monitoring requirements. 9 These labor estimates were based on a 25 feet traverse pattern re quirement, compared with the 30 meter (~100 feet) traverse pattern in the NSPS. Adjusting the SCAQM D time estimates for a wider pattern and using the ratio of each pattern’s distance, we estimate that a 30 meter traverse pattern will require 0.254 hours per acre to complete.

The rental cost of a portable analyzer, such as the TVA 1000B, varies depending on the length of the rental. Rental rates were provided on a daily, weekly, and monthly basis from an equipment rental

company. 10 Daily equipment rental rates ($125 per day) were multiplied by the number of hours to complete each monitoring occurrence if the time was l ess than or equal to 24 hours (three 8-hour days). Weekly equipment rental rates were used if the num ber of hours to complete each monitoring occurrence was less than or equal 120 hours (three 40-hour weeks) . Monthly equipment rental rates were applied if the number of hours to complete each monitoring occu rrence was greater than 3 weeks. These rental costs were then multiplied by four occurrences per year to estimate an annual equipment rental cost for the quarterly monitoring requirements.

7 ERG. 2014. Methodology for Estimating Cost and Emission Impacts of Proposed MSW Landfill Regulations.

8 Ibid.

9 http://www.arb.ca.gov/regac t/2009/landfills09/appf.pdf

10 Equipment Rental Rates TVA1000b. http://usenvironmental.com/air/fids/thermo-tva-1000b/

### 5 In addition to these equipment costs, there is a si gnificant labor cost associated with traversing the path. Applying the labor rate for a Civil Engineering Technician, this annualized cost per acre is shown in Equations 4a and 4b:

Eq. 4a : $49.69/hr *0.254 hr/acre * 4 events/year = $50.49/acre (30 meter traverse pattern) Eq. 4b : $49.69/hr * 1 hr/acre * 4 events/year = $198.76/acre (25 foot traverse pattern)

The Modeling Database Containing Inputs and R esults of Proposed Revisions to MSW Landfill

NSPS 11 was used to estimate the surface area of each ne w controlled site. Year-specific acreages were estimated in the Annual_Landfill_Waste table using annual waste rate data and the fraction of the designed area that was filled for all landfills that were estimated to control gas in 2023. 12

3.5 Integrated Sample Calculations and Transposing Field Data into Electronic Format

EPA estimates that most sites subject to in tegrated surface monitoring requirements under the enhanced monitoring option use a data logger to colle ct the surface monitoring da ta. After the samples are collected, they are averaged to compute an integr ated sample for the SCAQMD landfill regulations. For the analysis associated with the e nhanced monitoring requirements, we assumed that 75 percent of sites would use a data logger. To estimate the additional bu rden of transposing the hand written sample values into an electronic spreadsheet and computing an inte grated sample average, we estimated it would take one hour per acre to transpose the field data into an electronic format. We applied the same Civil Engineering Technician hourly labor rate of $49.69 per hour. We multiplied this hourly wage by 25 percent of the overall controlled acreage for the selected option to estimate the cost of manual calculations associated with an integrated sample reading.

3.6 Improved Surface Maintenance

If a tighter traverse pattern were incorporated in the NSPS, landfills would likely be doing more surface maintenance and repair to prevent or correct methane surface emissions. Thus, additional costs to maintain and repair the landfill cover are estimated on the basis that a tighter traverse pattern might identify a larger number of elevated methane readings. A factor of $50 per acre per monitoring occurrence, (or $200 per acre per year) was used to account for these additional repair costs, based on estimates provided in the 2009 SCAQMD Landfill rule. 13



### 4. Summary of Costs

Table 3 summarizes the testing and monitoring costs for controlled and uncontrolled landfills.

These costs are added to the control costs in order to develop a total cost for each regulatory option, as discussed in the Cost and Emission Reductions Impacts memo. 14

Table 3. Summary of Annual Testing and Monitori ng Costs for Categories of Affected Landfills

11 ERG. 2014. Modeling Database Containing Inputs an d Results of Proposed Revisions to MSW Landfill NSPS.

12 ERG. 2014. Summary of Landfill Dataset Used in th e Cost and Emission Analysis of Landfill Regulations.

13 http://www.arb.ca.gov/reg act/2009/landfills09/appf.pdf

14 ERG. 2014. Cost and Emission Impacts Resulting from the Landfills NSPS Review.

### 6 Affected
Landfill a Annualized
Initial
Performance Test ($) Continuous
Combustor Monitoring Monthly

Wellhead Monitoring Quarterly Surface Monitoring Annualized Improved
Surface
Maintenance ($/acre) NMOC Testing ($) Equipment

Rental ($/period) Annual
Labor Cost ($/acre)

Uncontrolled Landfills Using Tier 1 NA NA NA NA NA NA $680 Using Tier 2 NA NA NA NA NA NA $2,700 For 30-meter traverse pattern

Controlled (<=95 acres) $1,105 Already
included b Already
included b $125/day $50.48 NA NA

Controlled (>95 acres up to 472 acres) $1,105 Already
included b Already
included b $350/week $50.48 NA NA

Controlled (>472 acres) $1,105 Already
included b Already
included b $1100/month $50.48 NA NA

For 25-foot traverse pattern with integrated sample calculation c

Controlled (<=24 acres) $1,105 Already
included b Already
included b $125/day $198.76 $200 NA

Controlled (>24 acres up to 120 acres) $1,105 Already
included b Already
included b $350/week $198.76 $200 NA

Controlled (>120 acres) $1,105 Already
included b Already
included b $1100/month $198.76 $200 NA

a The listed acreages correspond to the length of time a monitor would need to be rented to complete surface

monitoring for a landfill (daily, weekly , monthly), as described under Secti on 3.4 of this memo, Quarterly Surface Monitoring.

b Already included in the control cost estimates. See the memo: ERG. 2014. Methodology for Estimating Cost and

Emission Impacts for MSW Landfills Regulations.

c In addition to these costs, it was assumed that a portion of the sites would not have a data logger to compile the

field data automatically and compute the integrated sample calculations. The sites without a data logger would include an additional $49.69 per acre in labor to transpose the field data into an elect ronic format as discussed under Section 3.5 of this memo, Integrated Sample Calculations and Transposing Field Data into Electronic

Format.