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 Cost s for the MSW

Landfill Regulations



### Introduction

Th is memo presents the assumptions and equations used to calculate testing and monitoring c osts
for landfills that would be affected by the review of the n ew s ource p erformance s tandards ( NSPS ) and

e mission g uidelines for municipal solid waste (MSW) landfills

. This memo summarizes th os e testing and monitoring cost s for both uncontrolled and controlled landfills that would be subject to the landfills NSPS

or e mission g uidelines

. The se costs are one element of the overall cost estimates used to analyze the impacts. S eparate memorand a summarize the total cost (control, testing

, and monitoring) of each regulatory option that EPA considered for each proposal. 1

, 2

T he types of testing and monitoring required by the propos al 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 landfill s

. For this analysis

, it was assumed

that if controls were required to be installed by 202 5 , the landfill was considered to be a controlled landfill, and it would i ncur 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 Requir e ment Applicability

NMO C 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. 201 5

. Revised Cost and Emis sion 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. 201 5

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



### 1Table 1. Applicability of Various Testing and Monitoring Requirements Testing and Monitoring Requir e ment Applicability

Continuous Combustor Monitoring



### • Temperature



### • Flowrate Controlled Landfills

Monthly Wellhead Monitoring



### • Nitrogen or o xygen



### • 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 expen ditures for purchasing the monitoring equipment. This analysis assumes that a Civil Engineer or Civil Engineer Techn ician 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 201 2

. The wage rates were adjusted to inclu de benefits and office overhead

- related expenses.

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

Occupation Unloaded National Mean Wage Rate 4 Adjustment Factor Loaded Wage Rate Civil Engineer $ 40.45 39.76 + 110%( 40

. 45 ) $8 4.95 Civil Engineering

Technician $23 .66 23. 66 + 110%(23. 66 ) $4 9.69



### 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 sugge sts 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. Simi lar industry experience suggests that the Tier 3 calculation option is not widely used. Although Tier 4 is a proposed option for the e mission g uidelines, 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



### 2This analysis assumes that 50 percent of uncontrolled landfills use Tier 1 calculations and

50 percent use Tier 2 calculations. S ome 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 ru n the model, and to report the results. The

Tier 1 report is required annually.

Eq. 1 : 8 hours * $8 4

. 9 5/hr = $6 80

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 e stimated 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 I nformation C ollection R equest (ICR) burden estimate of 12 hours of a Civil Engineer’s time or 12 * 8 4

. 95 = $1,0 19 was used

. 6 The annualized cost of this test, including labor, over 5 years at a 7 percent and 3 percent interest rate s is shown by Equation s 2 a and 2b :

E q. 2 a : ($10,067 + $1,0 19 )*{0.07(1 + 0.07)^5} / {[(1 + 0.07)^5]

- 1} = $2,700 Eq. 2b : ($10,067 + $1,0 19 )*{0.0 3 (1 + 0.0 3 )^5} / {[(1 + 0.0 3 )^5]

- 1} = $2, 4 00



### 3. Costs for C ontrolled 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 t he initial performance test is expressed in Equation s 3 a and 3b :

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

- 1} = $1,105

5 USEPA Monitoring Costs Asse ssment 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

.



### 3Eq. 3 b : 10,067* {0.0 3 (1 + 0.0 3 )^15} / {[(1 + 0.0 3 )^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 combust ion device. It is common practice for the flowrate and temperature to be monit ored 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) base s 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 rule s 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 base s wellfield O&M cost data on landfills with LFG energy projects installed. These landfills would already monitor th ese wellhead parameter s in order to

maintain a well

- ba lanced 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 as sumes that most

landfills will contract out their surface monitoring requirements and the con tracted 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 deter mining the controlled acreage of each landfill, as discussed below, and mul tiplying this acreage by an hour per acre estimate t o obtain an

estimate of total hours per landfill for each quarterly monitoring occu rre nce. 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 patter n 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) w ere multiplied by the number of hours to complete each monitoring occur re nce 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 occur re nce was less than or equal 120 hours (three 40

- hour weeks ) . Monthly equipment rental rates were applied if

8 ERG. 201 5

. 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/



### 4the number of hours to complete each monitoring occur re nce was greater than 3 weeks. These rental costs

were then multiplied by four occur re nces per year to estim ate 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 land fill. 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 4 a and 4 b:

Eq. 4 a : $4 9

. 69 /h r *0.254 hr/acre * 4 events/year = $ 50

. 49 /acre ( 30 meter traverse pattern ) Eq. 4 b : $4 9

. 69 /hr * 1 hr/acre * 4 events/year = $ 19 8

. 76 /acr e (2 5 foot traverse pattern )

The databases for each proposal 13

, 14 w ere 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 202 5

. 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 da ta 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 r eadings. 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 $4 9

. 69 per hour. We multiplied this hourly wag e 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 n 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, a dditional costs to maintain and repair the landfill cover are estimated on the basis that a tighte r traverse pattern might identify a larger number of elevated methane readings. A factor of $50 per acre per monitoring occurre nce
, (or $200 per acre per year) was used to account for these additional repair costs

, based on estimates provided in the 2009 C A 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. 2 01 5

. Modeling Database Containing Inputs and Results of Supplemental Propos al for MSW Landfill

NSPS

. 14 ERG. 2015. Modeling Database Containing Inputs and Results of Propos ed al for MSW Landfill NSPS

. 15 ERG. 201 5

. Summary of Updated Landfill Dataset Used i n the Cost and Emission Analysis of Landfill Regulations

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



### 5

### 4. Summary of Costs

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

These cos ts a re 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

Landfill a Annualize

d Initial

Performa

nce Test ($) Continu

ous Combus

tor
Monitori

ng Monthly

W ellhead

M onitori

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 $6 80

Using

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

For 30

- meter traverse pattern

Controll

ed ( < =95

acres ) $1,105 Already

included b Already

included b $ 125/day $ 50.48 $414/yr NA NA

Controll

ed (>95

acres up to 472 acres) $1,105 Already

included b Already

included b $ 350/week $ 50.48 $414/yr NA NA

Controll

ed (>472 acres) $1,105 Already

included b Already

included b $ 1100/mont

h $ 50.48 $414/yr NA NA

For 25

- foot traverse pattern with integrated sample calculation c

Controll

ed ( < =24

acres ) $1,105 Already

included b Already

included b $ 125/day $ 198.76 $414/yr $ 20 0 NA

Controll

ed (>24

acres up to 120 acres) $1,105 Already

included b Already

included b $ 350/week $ 198.76 $414/yr $ 20 0 NA

Controll

ed (>120 acres) $1,105 Already

included b Already

included b $ 1100/mont

h $ 198.76 $414/yr $ 20 0 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. 201 5 . Cost and Emission Impacts Resulting from the Landfill s NSPS Review.

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



### 6b Already included in the control cost estimates. See the memo: ERG. 201 5

. 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 $4 9

. 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.



### 7