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: June 2015

SUBJECT: Updated 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) and 

emission guidelines 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

or emission guidelines. These costs are one element of the overall cost estimates used to analyze the 

impacts. Separate memoranda summarize the total cost (control, testing, and monitoring) of each 

regulatory option that EPA considered for each proposal.1,2

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 2025, 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.3

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. 2015. Revised Cost and Emission Impacts Resulting from the Supplemental NSPS Proposal for MSW 

Landfills.

2

 ERG. 2015. Revised Cost and Emission Impacts Resulting from the Landfill EG Review.

3 ERG. 2015. Updated Methodology for Estimating Cost and Emission Impacts of MSW Landfills Regulations. 

1

 
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 Rate4 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. Although Tier 4 is a 

proposed option for the emission guidelines, given the site-specific nature of this tier, it is unknown how 

many landfills would use this option.

4 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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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 

opt to use Tier 2 testing if their Tier 1 calculations exceed the NMOC thresholds that trigger the control 

requirements

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, 25A, or 25C, was estimated using the EPA Monitoring Costs and Benefits tool, which 

estimates a Method 25A test to cost $10,067.5 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. An Information Collection Request (ICR) burden estimate of 12 hours 

of a Civil Engineer’s time or 12 * 84.95 = $1,019 was used.

6 The annualized cost of this test, including 

labor, over 5 years at a 7 percent and 3 percent interest rates is shown by Equations 2a and 2b:

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

Eq. 2b: ($10,067 + $1,019)*{0.03(1 + 0.03)^5} / {[(1 + 0.03)^5]-1} = $2,400

3. Costs for Controlled Landfills

3.1 Initial Performance Testing

The current proposals require 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, 25A, or 25C. 

The estimated performance testing cost is $10,067, according to the EPA Monitoring Costs and 

Benefits tool.7 This cost was annualized over 15 years, consistent with the expected lifetime of the 

combustion control equipment, at a 7 percent and 3 percent interest rate. The annualized cost for the 

initial performance test is expressed in Equations 3a and 3b:

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

5 USEPA Monitoring Costs Assessment Tool. November 30, 2009, Method 25A. 6 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 7 USEPA Monitoring Costs Assessment Tool. November 30, 2009, Method 25A.

3

 
Eq. 3b: 10,067* {0.03(1 + 0.03)^15} / {[(1 + 0.03)^15]-1} = $840

3.2 Continuous Combustor Monitoring

The rules require 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 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.8

 

3.3 Monthly Wellhead Monitoring

The rules require 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 proposals

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.9

3.4 Quarterly Surface Monitoring

The current rules require 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 2010 California Landfill 

Methane Rule included estimates of 1 hour of a Civil Engineering Technician’s time per acre to complete 

surface monitoring requirements.

10 These labor estimates were based on a 25 feet traverse pattern 

requirement, compared with the 30 meter (~100 feet) traverse pattern in the current rules (40 CFR part 60 

subparts WWW and Cf). Adjusting the CA LMR 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.11 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 

8 ERG. 2015. Updated Methodology for Estimating Cost and Emission Impacts of MSW Landfills Regulations. 9 Ibid. 10 http://www.arb.ca.gov/regact/2009/landfills09/appf.pdf 11 Equipment Rental Rates TVA1000b. http://usenvironmental.com/air/fids/thermo-tva-1000b/

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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.

The EPA also estimated the cost to purchase calibration gases for the monitor at $204 per year, 

per landfill and hydrogen fuel to operate the monitor at $210 per year, per landfill.12

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 databases for each proposal13,14 were 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 2025. 15

3.5 Integrated Sample Calculations and Transposing Field Data into Electronic Format

If an integrated surface emission concentration threshold were incorporated in the final rules, the 

EPA estimates that sites would use a data logger to collect the surface monitoring data in various grids of 

the landfills. After the samples were collected, they would be averaged to compute an integrated reading 

over each grid. The EPA understands that many landfills are using data loggers to facilitate the 

calculation of the integrated readings. 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 an enhanced surface monitoring approach were incorporated in the final rules, 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 CA LMR.

16

12 Pine Environmental. Cost to purchase (including shipping/handling) of: 105L of CH4-500ppm/Air; and 105 L

Zero Air ( <1 ppm THC); and 620 L of hydrogen fuel. 13 ERG. 2015. Modeling Database Containing Inputs and Results of Supplemental Proposal for MSW Landfill 

NSPS. 14 ERG. 2015. Modeling Database Containing Inputs and Results of Proposed al for MSW Landfill NSPS. 15 ERG. 2015. Summary of Updated Landfill Dataset Used in the Cost and Emission Analysis of Landfill

Regulations. 16 http://www.arb.ca.gov/regact/2009/landfills09/appf.pdf

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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. 17,18

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

Affected 

Landfilla

Annualize

d Initial 

Performa

nce Test

($)

Continu

ous 

Combus

tor 

Monitori

ng

Monthly 

Wellhead 

Monitori

ng

Quarterly Surface Monitoring

Annualized 

Improved 

Surface 

Maintenance

($/acre)

NMOC 

Testing ($)

Equipment 

Rental 

($/period)

Annual 

Labor 

Cost 

($/acre) 

Calibrati

on/Fuel 

Costs

($/period)

Uncontrolled Landfills

Using 

Tier 1 NA NA NA NA NA NA NA $680

Using 

Tier 2 NA NA NA NA NA NA NA $2,700

For 30-meter traverse pattern

Controll

ed (<=95

acres)

$1,105 Already 

includedb

Already 

includedb $125/day $50.48 $414/yr NA NA

Controll

ed (>95

acres up 

to 472 

acres)

$1,105 Already 

includedb

Already 

includedb $350/week $50.48 $414/yr NA NA

Controll

ed (>472 

acres)

$1,105 Already 

includedb

Already 

includedb

$1100/mont

h $50.48 $414/yr NA NA

For 25-foot traverse pattern with integrated sample calculationc

Controll

ed (<=24

acres)

$1,105 Already 

includedb

Already 

includedb $125/day $198.76 $414/yr $200 NA

Controll

ed (>24

acres up 

to 120 

acres)

$1,105 Already 

includedb

Already 

includedb $350/week $198.76 $414/yr $200 NA

Controll

ed (>120 

acres)

$1,105 Already 

includedb

Already 

includedb

$1100/mont

h $198.76 $414/yr $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. 

17 ERG. 2015. Cost and Emission Impacts Resulting from the Landfills NSPS Review. 18 ERG. 2015. Revised Cost and Emission Impacts Resulting from the Landfill EG Review.

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b Already included in the control cost estimates. See the memo: ERG. 2015. Updated Methodology for Estimating 

Cost and Emission Impacts of 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.

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