1 

MEMORANDUM

TO: Hillary Ward, U.S. Environmental Protection 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 analyze 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. Table 1 shows the various testing and monitoring 

requirements that would apply to controlled and uncontrolled 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 being controlled. A separate 

memorandum discusses the approach for determining when and whether a landfill would install controls 

and the estimated schedule for installing controls on each landfill covered under the analysis.2

Table 1. Applicability of Various Testing 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 Impacts 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 Testing 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 requirements require labor to complete the activities in 

addition to capital expenditures for purchasing the monitoring 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 include benefits and office overhead-related expenses. 

Table 2. Labor Rates used in Testing and Monitoring Cost Analysis 

Occupation

Unloaded National 

Mean Wage Rate3 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 uncontrolled landfills is to periodically calculate 

the NMOC emission rates to determine when the landfill must install controls. The NSPS allows landfills 

three methods (tiers) for determining their NMOC rates. Although the number of landfills using each tier 

of reporting is unknown, industry experience suggests that there are a significant number of landfills 

reporting under the Tier 2 method, which allows the site to measure a site-specific NMOC concentration 

instead of using the higher default NMOC concentrations 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 landfills are small enough to use the Tier 1 defaults 

and still remain under the threshold requiring the site to control. However, many of the larger sites may 

 

3

 US Bureau of Labor and Statistics. May 2012 Occupational Employment Statistics. 

http://www.bls.gov/oes/current/oes_nat.htm#17-0000
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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-specific NMOC values, which can be obtained using 

Method 25 or 25C, was estimated using the EPA Monitoring 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 Information 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 interest 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 NMOC 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 performance 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 Assessment 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/public/do/PRAViewDocument?ref_nbr=201112-2060-017 6

 USEPA Monitoring Costs Assessment Tool. November 30, 2009. 
4 

3.2 Continuous Combustor Monitoring 

The NSPS requires continuous monitoring of the flowrate to the control device and the 

temperature of the enclosed flare or other enclosed 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 energy infrastructure. The 

LFGcost model algorithms (used to estimate NSPS control costs) bases its enclosed flare and engine costs 

on landfills with energy projects. Therefore, these continuous monitoring costs are included in the control 

cost estimates described in the control cost memorandum 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 nitrogen 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 wellfield O&M cost data on landfills with LFG energy 

projects installed. These landfills would already monitor these wellhead parameters in order to maintain a 

well balanced gas collection system and gas quality for their energy project. Therefore, these costs are 

already included in the well O&M cost line item 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 using 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 hourly 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 acreage 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 regulations 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 requirement, compared with the 30 meter (~100 feet) 

traverse pattern in the NSPS. Adjusting the SCAQMD 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 less than or equal to 24 hours (three 8-hour days). 

Weekly equipment rental rates were used if the number 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 occurrence 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/regact/2009/landfills09/appf.pdf 10 Equipment Rental Rates TVA1000b. http://usenvironmental.com/air/fids/thermo-tva-1000b/
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In addition to these equipment costs, there is a significant 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 Results of Proposed Revisions to MSW Landfill 

NSPS11 was used to estimate the surface area of each new 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 integrated surface monitoring requirements under the 

enhanced monitoring option use a data logger to collect the surface monitoring data. After the samples are 

collected, they are averaged to compute an integrated sample for the SCAQMD landfill regulations. For 

the analysis associated with the enhanced monitoring requirements, we assumed that 75 percent of sites 

would use a data logger. To estimate the additional burden of transposing the hand written sample values 

into an electronic spreadsheet and computing an integrated 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 Monitoring Costs for Categories of Affected Landfills 

 

11 ERG. 2014. Modeling Database Containing Inputs and Results of Proposed Revisions to MSW Landfill NSPS. 12 ERG. 2014. Summary of Landfill Dataset Used in the Cost and Emission Analysis of Landfill Regulations. 13 http://www.arb.ca.gov/regact/2009/landfills09/appf.pdf 14 ERG. 2014. Cost and Emission Impacts Resulting from the Landfills NSPS Review. 
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Affected 

Landfilla

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 

includedb 

Already 

includedb $125/day $50.48 NA NA 

Controlled 

(>95 acres up 

to 472 acres) 

$1,105 Already 

includedb

Already 

includedb $350/week $50.48 NA NA 

Controlled 

(>472 acres) $1,105 Already 

includedb

Already 

includedb $1100/month $50.48 NA NA 

For 25-foot traverse pattern with integrated sample calculationc

Controlled 

(<=24 acres) $1,105 Already 

includedb

Already 

includedb $125/day $198.76 $200 NA 

Controlled 

(>24 acres up 

to 120 acres) 

$1,105 Already 

includedb

Already 

includedb $350/week $198.76 $200 NA 

Controlled 

(>120 acres) $1,105 Already 

includedb

Already 

includedb $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 Section 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 electronic format as discussed 

under Section 3.5 of this memo, Integrated Sample Calculations and Transposing Field Data into Electronic 

Format.