### 1

MEMORANDUM

TO: Hillary Ward, U.S. Environmental Protection Agency, OA QPS/Sector Policies and

Programs Division, Fuel and Incineration Group, Docket

FROM: Eastern Research Group, Inc. (ERG)

DATE: July 2015

SUBJECT: Revised Cost and Emissions Impacts Resulting from the Land fill EG Review

Introduction

The purpose of this memorandum is to present the results of the analysis to estimate costs and emission reductions for the 2015 supplemental proposed review of the emission guidelines for municipal solid waste (MSW) landfills. These impacts were calcu lated for existing landfills that accepted waste after 1987 and modified before July 17, 2014. The equations and data input s used to estimate the impacts are

discussed in other memoranda in the docket. 1, 2,3

Results are presented in 2012 dollars ($2012) and are based on the annualized costs in 2025 using an interest rate of 7 percent. By 2025, the Emission Guide lines are expected to be fully implemented and this year is representative of costs and the number of c ontrolling landfills.

The results of the impacts analysis are presented for the proposed changes to the emission guidelines (the proposal) as well as several options. The r esults are presented as incremental impacts relative to impacts associated with the current design ca pacity and NMOC emission thresholds currently in 40 CFR part 60, subpart WWW and the state and federal pla ns implementing subpart Cf. Landfillspecific details of each option under consideration are docume nted in the modeling database. 4 This memorandum is organized as follows:

1.0 Overview of Regulatory Options

2.0 Estimating Cost Impacts

3.0 Estimating Emission Reductions Impacts

4.0 Estimating Impacts for Enhanced Surface Emission Monitori ng

Appendix A: Index of Regulatory Options Appendix B: Detailed Cost and Emission Reduction Impacts

1 ERG. 2015. Summary of Updated Landfill Dataset Used in the Cost and Emission Reduction Analysis of Landfills Regulations.

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

3 ERG. 2015. Updated Methodology for Estimating Testing and Monitoring Cos ts for the MSW Landfill Regulations.

4 ERG. 2015. Summary of Updated Landfill Dataset Used in the Cost and Emission Reduction Analysis of Landfills Regulations.

### 2

Appendix C: Emissions Profiles

1. Overview of Regulatory Options



### D escriptions of the current regulatory baseline, the proposed revision, and alternative options are

included in this section.

1.1 Baseline

• Currently, 40 CFR part 60, subpart WWW requires all landf ills with a design capacity of 2.5 million megagrams (Mg) and 2.5 million cubic meters or g reater to report their NMOC emission rate. When the NMOC emission rate exceeds 50 Mg/y r, a landfill is required to control its emissions within 30 months of submitting a report in w hich the NMOC emissions exceeded the threshold. Approximately 989 existing landfills are expect ed to meet the design capacity threshold. Of these 989 landfills, 574 are expected to exceed the NMOC emission threshold and install a gas collection and control system (GCCS) by 2025.

1.2 Proposal

• The proposal reduces the NMOC emission threshold from 50 Mg /yr to 34 Mg/yr for landfills that are open as of the date of this proposal. The number of landfills subject to the rule remains the same as the baseline because the design capacity threshold r emains the same. However, 106 more open landfills are expected to exceed the NMOC emission threshold and install a GCCS by 2025 when compared to the baseline.

• Consistent with the current baseline, the proposal employs a modeled initial GCCS installation lag time of 3 years after exceeding the NMOC threshold, and an average GCCS expansion lag time of 4 years as discussed in another memorandum. 5

1.3 Alternative Regulatory Options

The impacts of several regulatory options other than pro posed option 2.5/34 were also considered. The options varied one or more of the size and N MOC control parameters. For each of these variations in size and NMOC thresholds, the universe of land fills potentially subject to more stringent requirements were analyzed. First, for all landfills ( open or closed) meeting the revised criteria and then for just landfills that are open as of the date of the proposal and meeting the revised criteria. These options

are summarized in this memorandum for reference and in clude the following adjustments to the control requirements. A complete index of the characteristics of ea ch option considered is shown in Appendix A.

• If the proposed threshold of 34 Mg/yr were reduced for all landfills (open and closed), 142 more landfills would expect to install a GCCS by 2025 when compared to the baseline.

• One option incorporated a reduction in the NMOC threshold, to 40 Mg/yr. 62 more open landfills are expected to exceed the NMOC emission threshold and ins tall a GCCS by 2025 when compared to the baseline. Considering all landfills (open and closed) 84 more landfills would install a GCCS in 2025 when compared to the baseline.

• One option combined a reduced size threshold of 2.0 million Mg design capacity with an NMOC emission threshold of 34 Mg/yr. 122 more open landfills are expected to exceed the NMOC

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

### 3

emission threshold and install a GCCS by 2025 when compared to the baseline. Considering all landfills (open and closed) 162 more landfills would insta ll a GCCS in 2025 when compared to

the baseline.

For wet landfills, the EPA also considered options to red uce the lag times to install and expand on the

GCCS:

Several options paired the NMOC thresholds of 34 and 40 Mg/yr and size thresholds of 2.0 and 2.5 million Mg design capacity with shortened the initial lag times for installing the GCCS. For example, shortening the initial lag time from 3 years to 2 years wou ld require some landfills to install the controls earlier and would also trigger an earlier installation schedule for each subsequent expansion. However, because the same subset of landfills would require controls to be installed under the current 3-year lag times, the overall additional emission reductions are not a s significant over time. Further, when installing controls a year earlier as a result of a shortened lag t ime, the initial system will be designed slightly smaller than a system designed to capture gas in a subsequ ent year. The options that reduced the initial lag times also shortened the expansion lag times. Reducing the expansion lag time achieves a larger net emission reduction over time because each subsequent expansi on is on a shorter 2-year cycle. However, the same subset of landfills would still require controls to be installed under either lag time. This combination of initial and expansion lag time reductions achi eved the largest amount of reductions over time because they achieved an earlier installation start date, paired with a tighter frequency of subsequent expansions.

The emission reduction and cost analysis was conducted us ing a k value of 0.04 for any landfill that is

located in an area with at least 25 inches of rainfal l, consistent with the analysis discussed at 79 FR 41805. The reductions and cost impacts on wet landfills shown i n Appendix B-3a and B-3b were isolated for wet landfills, which for the purpose of the preliminary analysis included landfills receiving greater than 40 inches of rain fall per year, landfills permitted under the research, development, and demonstration (RD&D) rule, or landfills that reported a k value of at least 0.057 to the GHGRP subpart HH and indicated they recirculated leachate. Most wet landfills were located in non-arid climate zones, but there were nine additional landfills, which are either bi oreactor projects permitted under the research, development, and demonstration (RD&D) rule or reported signif icant leachate recirculation to subpart HH of the GHGRP were modeled using a k value of 0.02 because they were located in arid areas. The results could differ significantly if alternative modeling pa rameters (k and/or L

o ) were used to model emissions from this group of wet landfills.

2. Estimating Cost Impacts

For each option, the cost impacts analysis compares net an nualized costs of the baseline option in 2025 to the net annualized costs of each regulatory option i n 2025. The costs incorporate annualized capital costs to install the GCCS, operating and mainten ance (O&M) costs for the GCCS, and if relevant, any annualized capital and O&M costs for energy recovery e quipment. If energy recovery was expected to occur at a landfill, the annual revenue from the energy re covery project was subtracted from the total annualized costs in order to compute the net annualized cost to each landfill. The detailed control cost equations are shown in another memorandum. 6

In addition to the control costs to comply with the regulat ion, the costs also include testing and monitoring costs to demonstrate compliance. The testing and mo nitoring costs include the labor, equipment rental, and any capital expenses involved with pr eparation of NMOC emission rate reports, conducting initial performance tests, monthly wellhead monito ring, continuous combustor monitoring, and quarterly surface emission monitoring. The detailed te sting and monitoring equations are shown in

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

### 4

another memorandum. 7 The costs and revenues associated with the baseline and proposal are shown in

Table 2.

Table 2. Summary of Cost Impacts for Proposal in 2025 Option Annualized

Control

Cost Average

Annualized

Revenue Average

Annualized Testing and Monitoring

Cost Average

Net Total

Annualized

Cost

Total Costs of Baseline (millions, $2012)

Baseline

2.5/50 1,700 1,408 7 .3 299

Incremental Costs above Baseline (millions, $2012)
Proposal 2.5/34 open

and 2.5/50

closed 102 55.5 0. 6 8 46.8

The incremental costs associated with the other regulato ry alternatives as well as a summary of each individual cost component are shown in Appendix B.

3. Estimating Emission Reduction Impacts

The emission reductions of each regulatory option are pres ented in terms of NMOC (Mg/yr), methane (Mg/yr), and carbon dioxide equivalents (Mg CO 2 e/yr) based on a global warming potential of 25 for methane. The detailed emission reductions equations are shown in another memorandum. 2 The reductions associated with the baseline and the proposal ar e shown in Table 3.

Table 3. Summary of Emission Reductions for Proposal in 2025 Option NMOC

Reductions (Mg/yr) Methane

Reductions (million Mg/yr) Methane

Reductions (million mt

CO 2 e/yr)*

Baseline 57,300 9.0 226

Incremental Reductions above Baseline
Proposal 2.5/34 open

and 2.5/50

closed 

### 2,770 0.44 10.9

*A global warming potential of 25 is used to convert metha ne to CO 2 - equivalents. Minor secondary air impacts are not included in this table but are presented in anoth er memorandum. 8

Detailed annual emission reductions for other options for e ach affected landfill are shown in the

7 ERG. 2015. Updated Methodology for Estimating Testing and Monitoring Cos ts for the MSW Landfill Regulations.

8 ERG. 2015. Estimating Secondary Impacts of the Emission G uidelines for MSW Landfills.

### 5

landfill modeling database outputs. 9 Table 4 summarizes the overall and incremental cost effec tiveness of the proposal. The cost effectiveness is presented with and without consideration of project revenue from electricity sales.

Table 4. Summary of Overall Cost-Effectiveness Option Net Cost a Total

Cost Net Cost a Total

Cost Net Cost a Total

Cost $/Mg NMOC $/Mg Methane $/CO 2 e
Baseline

2.5/50 

### 5,100 29,800 32.3 189 1.3 7.6

Proposal 2.5/34 open

and 2.5/50

closed 

### 17,000 37,000 108 235 4.3 9.4

a Net Cost is the total control and testing and monitoring cost minus any project revenue. The control costs for landfills with energy projects includes costs to install and operate a reciprocating engine (and associated el ectrical equipment), which is more expensive than a standard flare. Reciprocating engines are not required by the regulation but are expected to be used as control devices when it is c ost-effective to recovery the LFG energy.

The overall cost effectiveness of the baseline is provided fo r reference and it was calculated by dividing the total emission reductions achieved under the baseli ne by the total costs associated with the baseline. The incremental cost effectiveness of the proposal was calculated by dividing the incremental costs of the proposal by the incremental reductions of t he proposal.

Additional details about the emission impacts and cost effec tiveness of other regulatory alternatives can be found in Appendix B.

4. Impacts Over Time

While the formal regulatory analysis was based on the co sts and benefits in year 2025, the EPA recognizes that cost and reduction impacts could vary bas ed on where the landfill is in its lifecycle. This variation is not as pronounced when looking at the total impa cts of each option in a given snapshot year because the landfills controlling in any given year are eac h at different points of their lifecycle. Appendix C presents three different landfills as examples in o rder to demonstrate how the proposed option affects

an individual landfill over time.

9 ERG. 2015. Modeling Database Containing Inputs and Results for Review of the MSW Landfill Emission

Guidelines.

### 6

Appendix A: Index of Regulatory Options for Landfill Emis sion Guidelines Review

Database

Model Option # Option Name Description 1

1 , 1a Baseline

(2.5/50) • Design capacity cutoff = 2.5 million Mg

• NMOC cutoff = 50 Mg/yr

• Initial lag time = 3 years (30 months in rule, modeled as 3 years to account for time between when emission threshold was first exceeded and the time the repo rt was submitted)

• Expansion lag time = 4 years (some will do 2, more will do 5, so use 4 as typical)

3 , 3a 2.5/40 Same as current rule, except: • NMOC cutoff = 40 Mg/yr

4 , 4a 2 2.5/40, IL, EL Same as current rule, except: • NMOC cutoff = 40 Mg/yr

• Expansion lag time = 2 years

• Initial lag time = 2 years

7 , 7a 2.0/34 Same as current rule, except: • Design capacity cutoff = 2.0 million Mg

• NMOC cutoff = 34 Mg/yr

13, 13a 2.5 /34

PROPOSED

OPTION Same as current rule, except: • NMOC cutoff = 34 Mg/yr

14, 14a 2 2.5 /34

, IL, EL Same as current rule, except: • NMOC cutoff = 34 Mg/yr

• Expansion lag time = 2 years

• Initial lag time = 2 years

1 For each option, interest rates of both 3% and 7% were us ed to annualize the costs. The option number with an “a” suffix denotes 3% in the database (i.e. Option 1a) and the opt ion number without this suffix denotes a 7% rate (i.e. Option 1)

2 Options with shorter expansion lag times or initial lag t imes were evaluated for wet landfills.

### 7

Appendix B: See spreadsheet containing detailed cost and e mission reduction impacts.

### 8 Appendix C: Emission Profiles

• LF ID 1742 would stop controlling in year 2049 under the baseline, but would continue on with controls beyond year 2063 with a lower emission t hreshold.

• LF ID 52598 would not add controls under the baseline option, b ut controls would be required until 2033 under the lower emission threshold of 34 M g/yr, according to our

model.

• LF 522776 is controlling at the same level throughout the period of 2025-2063, the dropoff occurs outside the scope of our modeled emissions. 0 100000 200000 300000 400000 500000 6000002020202220242026202820302032203420362038204020422044204620482050205220542056205820602062Mg/yr CO2e Reductions, by landfill

Axis Title



## Emissions Profile 2025-2063 for EG (Subpart Cc) Lan dfills

Baseline - 1742 Proposed Option 2.5/34 - 1742

Baseline - 522776 Proposed Option 2.5/34 - 522776

Baseline - 525598 Proposed Option 2.5/34 - 525598