From: Ward, Hillary Sent: Wednesday, June 18, 2014 6:04 PM To: 'Higgins, Cortney' Cc: Cozzie, David Subject: Response to OMB Request: draft supporting documents for Landfills NSPS

Hi Cortney, Per your request, please see the attached draft supporting docu ments for the Landfills NSPS currently under review by OMB.

Regards, Hillary Ward US EPA, Sector Policies and Programs Division Fuels and Incineration Group (919)541 ‐3154

Attachments: Draft Landfill Dataset Memo 061814_clean.pdf; Draft NSPS Cost and Emission Impacts 061614.pdf; vcs results for standards of performance for municipal solid waste landfills 40 CFR Part 60, Subpart XXX.pdf; Draft NSPS Secondary Impacts Me mo 061814.pdf; Draft Testing and Monitoring Methodology Memo_061614.pdf; Draft NSPS Cost and Emission Impacts Appendix C 60314.xlsx; Draft Final LF Calculation 061814.pdfFrom: Ward, Hillary Sent: Thursday, June 19, 2014 1:17 PM To: 'Higgins, Cortney' Cc : Cozzie, David Subject: Supporting Documents Requested for Interagency Review of Landfills NSPS Hi Cortney, Per your request, please see the attached documents. Regards, Hillary Ward US EPA, Sector Policies and Programs Division Fuels and Incineration Gro up (919)541 ‐3154

Attachments: DRAFT Modeling Database Containing Inputs and Results of Proposed Revisions to MSW Landfill NSPS.zip (database not included in email correspondence due to size and format of file but is available in electronic copy in Docket office) ; DRAFT Database ReadMeTables Appx A and B061814.xlsxFrom: Ward, Hillary Sent: Thursday, June 19, 2014 5:08 PM To: 'Higgins, Cortney' Cc: Cozzie, David Subject: Supporting Documents Requested for Interagency Review of Landfills NSPS Hi Cortney,
P er your request, please see the attached document. Regards, Hillary Ward US EPA, Sector Policies and Programs Division Fuels and Incineration Group (919)541 ‐3154

Attachments: Draft Summary of Small Entity Outreach_061814.pdf1

MEMORANDUM

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

Programs Division, Fuel and Incineration Group

FROM: E astern Research Group, Inc. (ERG)

DATE: April 2014

SUBJECT: Summary of Landfill Data set Used in the Cost and Emission Impacts Analysis of Landfill

Regulat ions

Introduction

The EPA is reviewing the new source performance standards (NSPS) for municipal solid waste (MSW) landfills and issuing an Advanced Notice of Proposed Rulemaking (ANPRM) for a review of the emission guidelines. (40 CFR part 60

, s ubpart WWW and 40 CFR part 60, s ubpart Cc, respectively)

. Currently, the NSPS regulation require s any landfills of at least 2.5 million megagrams (Mg) and 2.5 million cubic meters in size with estimated nonmethane organic compounds (NMOC) emissions of at least 50 Mg per year to collect and control or treat landfill gas (LFG)

. 1

As a first step in developing these estimate d cost and emission impacts of various changes to the current regulatory requirements resulting from the ongoing review of the NSPS/EG , a dataset of existing (current) and future (projected) landfills was created ( NSPS/EG dataset)

. For each landfill, t he NSPS/EG dataset contains landfill

- specific information including:

 Landfill identification (ID) number

 W aste

- in

- place year

 A nnual waste acceptance year

 L andfill closure year

 Y ear landfill opened

 L andfill design capacity ( in tons)

 L andfill d esign area ( in acres)

 L andfill d epth ( in feet)

.
The purpose of this memorandum is to summarize the source data and assumptions used to creat e the NSPS/EG landfill dataset. Using the NSPS/EG dataset as an input, a Microsoft ® Access database was developed to calculate the emission reductions and costs. The assumptions and calculations housed in the database are detailed in the April 2014 memorandum, Methodology for Estimating Cost and Emission Impa cts of MSW Landfill Regulatio ns.

1. Landfill Data Sources

1 The requirements for existing sources under the state and federal plans implementing the EG are similar to those for new sources under the current NSPS.2

L andfill data w ere obtained from three sources: a landfill and LFG energy project database maintained by EPA’s L andfill Methane Outreach Program ( LMOP )

, a voluntary survey of landfills, and the Greenhouse Gas Reporting Program (GHGRP). These data sources are described below.

1.1 LMOP Database

T he LMOP database does not represent the entire universe of landfills in the United States ; t he database includes landfill information provided to LMOP and from publically available sources

. A snapshot of the database based on data as of July

, 2012

. At that time, the LMOP database contained information for 2, 434 landfills , all of which were added to the NSPS/EG dataset

. I n some cases, the amount of information about a partic ular landfill wa s very limited. For example, if the only publically available information for a landfill wa s the location and the opening year, only the location and opening
year were included in the LMOP database. If the combined dataset (from all three s ources) showed duplicate landfills, 2012 LMOP data w ere used over voluntary survey data because the LMOP data we re more recent than the voluntary data. Information in the LMOP database is compiled from a variety of sources by voluntary submittal, is updated periodically, and can change. Updates are not subject to a prescribed schedule as they would be under a regulatory program.

The LMOP database also contains a flag field denoting whether or not a gas collection and control system (GCCS) is install ed and if so, whether energy recovery projects exist at the landfill. A separate snapshot of the LMOP database based on data from December 2013 was used to approximate the total number of landfills with GCCS installed in order to identify which additional systems might be installed voluntarily, in addition to the estimated number of systems based on the methodology discussed in the April 2014 memorandum, Methodology for Estimating Cost and Emission Impacts of MSW Landfill Regulations

.

1.2 Voluntary Data

EPA conducted a voluntary landfill survey in 2010 and received information from 167 landfills

. All but five of the landfills that reported information to the survey were already included in the LMOP database. These five landfills were added to the NSPS/EG dataset.

1.3 GHGRP Data

Subpart HH of the GHGRP collects information from landfills that meet the reporting thresholds of the program. L andfill data were added from GHGRP reporting year 2010. All but seven of the GHGRP landfills and the majority of the data were already included in the LMOP database because LMOP previously compared and combined LMOP and GHGRP data from reporting year 2010. These seven landfills were added to the NSPS/EG dataset. Data from GHGRP w ere reporting year 2010 (which wer e made available in late 2011). Data are updated annually to the GHGRP and data from reporting year 2012

w ere recently released in late October 2013. Reporting year 2012 data include new inputs to GHG equations that were previously deferr ed as confidential information and these data will be incorporated into the dataset between proposal and promulgation of the Landfill NSPS

.
Data from the various sources were evaluated and combined appropriately

. The combination of the LMOP data

base, the voluntary survey d ataset , and the 2010 GHGRP data resulted in a dataset of 2,353 landfills after the following data quality tiers were applied to make corrections and resolve inconsistencies between the three datasets:3

 Landfills closing before November 8, 1987 a re not applicable to the state and federal plans implementing the EG . To accommodate this rule applicability criterion for the purposes of the dataset, any landfill closing before 1988 was removed from the dataset.

 For landfill open and clos ure years and design capacity, it was assumed that data reported in the GHGRP were the most up

- to

- date and were used preferentially before data reported in the survey or included in LMOP database

.

 For LMOP database fields that had not been recently updated , d ata repo rted in the survey was used . If the LMOP database data were updated after the 2010 survey, the updated LMOP data in this dataset were used

.

 Sometimes landfills in the LMOP database were recorded as separate landfills (e.g., old and new landfill), but they were reported as a single landfill in the survey or GHGRP. In these cases the landfills were treated as a single entity in this NSPS/EG dataset. In addition, if the landfills had the same address in the LMOP database and were not designated as reporting separately to the NSPS, they were combined for this dataset

. A total of 18 LMOP landfills were combined into nine landfills for the NSPS analysis. These combined landfills are designated in the dataset with a combined landfill ID

, which includes the separate LMOP landfill IDs separated by a period (example: landfill ID 1009.1008).

2. Filling Data Gaps

The combined NSPS/EG dataset of 2,353 landfills was missing landfill data for recent years (2010

- 2014) and included incomplete data for many landfills. Thus, model landfills were created to represent the recent landfill data that were not included in the dataset. Methods were also developed to estimate , if possible, the missing parameters for individual landfills, using existing data from LMOP, the voluntary survey, and the GHGRP. These data gap filling steps are described below in more detail.

A dataset of model landfills was developed for inclusion in the NSPS/EG analysis

. It was assumed that the sizes and locations of landfills opening in the most recent complete 8 years of data (2003

- 2010) would be similar to landfills opening in the next 8 years (201 1

- 2018)

. Based on existing landfills, 37 model l andfills were created to represent landfills opening in years 2012 to 2018

. Of these landfills, 2 1 were included in the “future” landfill dataset, which includes landfills opening in 2014 to 2018

, because 2014 is the year the NSPS will be proposed and represents the cutoff year for the proposed NSPS and EG

. The future landfills are designated in the dataset with an “F” as the first digit in the landfill ID on (example: landfill ID F1). The other model landfills are designated in the database with a n “N” as the first digit in the landfill ID, (example: landfill ID N1). The model landfills were created before the 18 LMOP landfills were combined to better represent new landfill capacity added each year; if the model landfills had been developed after t he landfills were combin ed , there would be fewer future landfills.

Because the data set did not contain complete data for many landfills, methods were developed to estimate the following parameters:

 W aste

- in

- place year

 A nnual waste acceptance year

 L andfill closure year

 Y ear landfill opened

 L andfill design capacity

 L andfill design area4

 L andfill depth.

When there a re multiple estimation methods for one of the parameters, the methods were followed sequentially as described below . Therefore, parame ters were estimated using later methods only if the parameters were not estimated using an earlier method.

2.1 Waste

- in

-

place Y ear

If waste

- in

- place year was missing and the landfill i s close d, it was assumed that the reported

waste

- in

- place year represent ed the year that the landfill closed

. The refore, the waste

- in

- place year was set as equal to the landfill closure year.

2.2 Annual W

aste A cceptance Y

ear

If annual waste acceptance year was missing and the landfill is closed

, it was assumed that the reported annual waste acceptance rate was reported in the year that the landfill closed

. The refore, the annual waste acceptance year was set as equal to the landfill closure year.

2.3 Landfill C

losure Y ear

For the first estima tion method

, the landfill closure year was calculated based on waste

- in

- place,

waste

- in

- place year, landfill design capacity, and annual waste acceptance rate

. T he number of years required to fill the landfill to capacity was calculated first by subtracting waste

- in

- place from the design capacity and then dividing by the annual waste acceptance rate . This value was added to the reported

waste

- in

- place year to determine the landfill closure year.

For landfills that we could not calculate the closure year by following the first estimat ion method

, a second estimation method was followed

. T he closure year was calculated based on the year the landfill opened, landfill design capacity

, and annual waste acceptan ce rate

. T he number of years required to fill the landfill to capaci ty was calculated first by dividing landfill design capacity by the annual waste acceptance rate . This number of years value was added to the year the landfill opened to estimate the landfill closure year. F ollowing this methodology f or landfills that were reported as closed , t he calculated closure year should be prior to 20 20

, because the landfill was reported to be closed; thus, any calculated closure years after 20 19 were not included in the NSPS/EG dataset

. For landfills that were reported to be
open , t he calculated closure year should be after 2000

, because the landfill was reported to be open ; thus, any calculated closure years prior to 2001 were not included in the NSPS/EG dataset

.

For the third estimation method

, landfill closure was calculated based on waste

- in

- place, waste

in

- place year, landfill design capacity, and a calculated waste acceptance rate

. T he annual waste acceptance rate was calculated by dividing the amount of waste

- in

- place by the number of years the landfill had accepted this amount of waste ( calculated by subtracti ng the year the landfill opened from the

waste

- in

- place year)

. T he amount of waste to be added was calculated by subtracting the waste

- in

- place from the landfill design capacity . T his value was divided by the calculated annual waste acceptance rate
to estimate the number of years to reach capacity

. T he number of years to reach capacity was then added to the waste

- in

- place year to estimate the landfill closure year

.

If the landfil l closure year was still missing and the waste

- in

- place year was not available, it was assumed that the waste

- in

- place year was 1998 because the majority of waste

- in

- place years in the LMOP database we re 1998

. ERG calculated t he annual waste acceptance rate by dividing the amount of waste

in

- place by the number of years the landfill had accepted this amount of waste (subtraction of the year the landfill opened from 1998 )

. The amount of waste to be added was calculated by subtracting the waste

- in

-5

place from the landfill design capacity

. T his value was divided by the calculated waste acceptance rate to estimate the number of years to reach capacity

. The number of years to reach capacity w as added to 1998

to estimate the landfill closure yea r

.

2.4 Year Landfill Opened

If waste

- in

- place, waste

- in

- place year, and annual waste acceptance rate were available, these parameters were used to estimate the year the landfill opened

. T he number of years the landfill had been active was calculated by dividing the waste

- in

- place by the annual waste acceptance rate

. This value was subtracted from the waste

- in

- place year to estimate the year the landfill opened

.
For the second estimation method, i f annual waste acceptance rate, annual waste acceptance year, and waste

- in

- place were available, these param e ters were used to estimate the year the landfill opened

. T he number of years the landfill had been active was calculated by dividing the waste

- in

- place by the annual waste acceptance year. As long as th is value did not exceed 100 years

, it was subtracted from the annual waste acceptance year to estimate the year the landfill opened

.
Finally, t he year the landfill opened was calculated based on the closure year, landfill design capacity, and annual waste acceptance rate

. T he number of years required to fill the landfill to capacity were calculated by dividing landfill design capacity by the annual waste acceptance rate . This value was subtracted from the landfill closure year and used to estimate the year the landfill opened as long as it did not exceed 100 years

.

2.5 Landfill D es ign C

apacity (tons)

First, i f the waste

- in

- place year was greater than the landfill closure year, it was assumed that the landfill had reached capacity and the landfill design capacity wa s set equal to the amount of waste

- in

place.

If the landfill design capacity was available in cubic yards, it was converted to tons using an assumed waste density of 0.6 ton s per cubic yard

.
Next, i f the landfill had values for waste

- in

- place, waste

- in

- place year, year the landfill opened, and landfill closure year, then the landfill design capacity was calculated

. First, the annual waste acceptance rate was calculated by dividing the waste

- in

- place by the number of years the landfill ha d accepted this amount of waste (which was determined by subtracting year the landfill opened from waste

in

- place year)

. T he calculated waste acceptance rate was multiplied by the number of years until the landfill closes ( which was calculated by subtrac ti ng the waste

- in

- place year from landfill closure year) to estimate how much waste w ould be added to the landfill to reach capacity

. T his amount was added to the

waste

- in

- place to estimate the landfill design capacity

.

I f the landfill had values for annual waste acceptance rate, year the landfill opened, and landfill closure year, then t he landfill design capacity was calculated by multiplying the landfill lifetime by the annual waste acceptance rate

. T he landfill lifetim e was calculated by subtracting the year the landfill opened from the landfill closure year

. This calculation method was not used to estimate landfill design capacity if waste

- in

- place exceeded the calculated design capacity

.
If the year the landfill op ened was not available, the landfill design capacity was calculated based

on waste

- in

- place, the years remaining before landfill closure, and annual waste acceptance rate

. T he years remaining before landfill closure were calculated by subtracting the waste

- in

- place year from the landfill closure year

. T his result was then multiplied by the annual waste acceptance rate to estimate the6

amount of waste to be added to the landfill to reach capacity

. T he added waste and the waste

- in

- place were summed to determin e the design capacity

.
Next, the landfill design capacity was calculated based on the landfill lifetime and the annual waste acceptance rate. T he landfill lifetime was estimated by subtracting the year the landfill opened from the landfill closure year

. The annual waste acceptance rate was multiplied by the landfill lifetime to estimate the design capacity.

If the wast e

- in

- place year was not available

, it was assumed to be 1998 because the majority of reported waste

- in

- place years in the LMOP database were 1998

. Using this assumption, the annual waste acceptance rate was calculated by dividing the waste

- in

- place by the subtracti on of the year the landfill opened from 1998

. T he annual waste acceptance rate was then multiplied by the landfill lifetime (subtraction of the year the landfill opened from the landfill closure year) to estimate the design capacity

.

If the landfill design capacity was still missing

, it was calculated by multiplying the landfill design area ( square feet ) with the waste depth ( feet ), and then dividing by an assumed waste density of 45 cubic feet per ton

.

2.6 Landfill Design Area (acres)

If the landfill design area was not recorded in the LMOP data base , d esigned landfill area from the voluntary survey for the landfill was used

. If the designed landfill area was not reported, but the curr ent landfill area (acres) was reported and waste

- in

- place divided by the l andfill design capacity was equal to or less than one

, then the landfill design area was calculated using curre nt landfill area, waste

- in

- place, and landfill design capacity. This calculation assume s that the ratio of the waste

- in

- place to the design capacity is equal to the ratio of the current landfill area to the design landfill area

. T he landfill design area

wa s estimated by dividing the current landfill area by the fraction of waste deposited (waste

- in

- place divided by design capacity). Similarly, if current landfill area was not reported, landfill design area was estimated by dividing the landfill footprint (a cres) by the fraction of waste deposited (waste

- in

- place divided by design capacity).

If the design area of the landfill had not been estimated any other way, the acreage was calculated based on landfill design capacity

, landfill design depth

, and an ass umed waste density of 45 cubic feet per

ton

.
Finally, i f there were no reported depth or area values for the landfill, and no area was estimated by the methods described above, the landfill design was estimated based on a best fit equation created from a linear regression ana l ysis of a graph of the reported design area s and design capacit ies

. T wo different equations

– one for landfills with design capacities greater than 5 million tons and one for landfills with design capacities less than or equal to 5 mi llion tons were developed

.

 Calculation for landfills with design capacities greater than 5 million ton s : Landfill Design Area (acres) = 0.00 00044 * [ Landfill design capacity (tons) ] + 98.26

 Calculation for landfills with design capacities less than or equal to 5 million ton s : Landfill Design Area (acres) = 0.000023 * [ Landfill design capacity (tons) ] + 11.73

2.7 Landfill Design Depth (feet)

If the landfill design depth was not re cor ded in the LMOP database, the designed landfill depth from the voluntary survey for the landfill was used

. If the designed landfill depth was not reported, but the7

current landfill depth (feet) was reported, the current landfill depth was used

. If neither was reported, but the waste depth was reported, the waste depth was used

.
If there were no reported depth values for the landfill, the depth was calculated based on landfill design capacity, landfill design area, and an assumed waste density of 45 cubic fee t per ton

. T he volume of waste was calculated by multiplying the landfill design capacity (tons) by the assumed density of

waste

. The landfill design depth was estimated by dividing the waste volume by the landfill design area

.
Finally, i f there were no reported depth or area values for the landfill, and no depth was estimated by the methods described above, the landfill design depth was estimated based on a best fit equation created from linear regression an a lysis of a graph of the reported design depth s and design capacit ies

. T wo different equations

— one for landfills with design capacities greater than 5 million tons and one for landfills with design capacities less than or equal to 5 million tons were developed

.

 Calculation for landfills with design capacities greater than 5 million ton s : Landfill d esign depth (feet) = 0.00000086 * [ Landfill design capacity (tons) ] + 108

 Calculation for landfills with design capacities less than or equal to 5 million ton s : Landfill d esign depth (feet) = 0.000012 * [ Landfill design capacity (tons) ] + 56

3. Final Dataset

After filling the data gaps ( for w aste

- in

- place year , a nnual waste acceptance year , landfill closure
year, y ear landfill opened , l andfill design capacity

, landfill d esign area , and landfill d epth ) , there were still a number of landfills that did not have sufficient data to include in the NSPS/EG cost and emission impact modeling analysis

. Of the original 2,434 landfill dataset created by the combination of the LMOP database, voluntary survey, GHGRP , and model landfills

, 1

, 8 53 landfills ( 76 percent of the total) had sufficient data to include in the NSPS/EG analysis

– 1,8 32 current landfills (constructed prior to 2014 but accepted waste after 1987 ) and 21 future landfills (constructed in 2014

- 2018 )

.
Appendix A provides a detailed listing of the background data sources, data tables, field names, and field descriptions (including units of measure) for the EG database. Appendix B provides a similar listing for the data tables in the NSPS database. The co ntents of each dataset are available in a database format. 2

, 3 The results of the voluntary survey are not stored in the database, but are provided in another docketed spreadsheet. 3

2 ERG. 2014. Modeling Database Containing Inputs and Results of Proposed Revisions to MSW Landfill NSPS.

3 ERG. 2014. Modeling Database Containing Inputs and Preliminary Impacts for Review of the MSW Landfill Emission Guidelines.

3 Summary of Responses to 2010 Voluntary MSW Landfill Survey.Appendix A-1: Background Data: LMOP July 2012 Table contains data from landfills in LMOP's database as of July 2012.
Field Name Description
LMOP Landfill ID Unique identifying number for each landfill
LMOP Landfill Name Landfill name
LMOP Landfill Alias Alternate landfill name LMOP Physical Address Physical address of landfill LMOP City City landfill is located in or near LMOP County County landfill is located in

LMOP State State landfill is located in LMOP Zip Code Zip code for the landfill
LMOP Latitude Latitude coordinate (decimal) for the landfill LMOP Longitude Longitude coordinate (decimal) for the landfill

LMOP Ownership Type Indicates if landfill is publicly owned, privately owned, or co-owned by public and private
entities LMOP Landfill Owner Organization( Organization that owns the landfill LMOP Landfill Operator Organizatio Organization that operates the landfill LMOP Year Landfill Opened Year landfill opened or began accepting waste (YYYY)

LMOP Landfill Closure Year Year landfill stopped accepting waste or is expected to stop accepting waste or year landfill closed or is expected to close (YYYY)
LMOP Current Landfill Status Open/Closed status of landfill LMOP Design Landfill Area (acres) Design waste mass area of landfill in acres LMOP Current Landfill Area (acres) Current waste mass area of landfill in acres LMOP Total Area (acres) Total area of land the landfill is located on LMOP Design Landfill Depth (feet) Design waste mass depth of landfill (maximum or average) in feet LMOP Current Landfill Depth (feet) Current waste mass depth of landfill (maximum or average) in feet LMOP Landfill Design Capacity (tons Waste design capacity of landfill in short tons LMOP Waste in Place (tons) Waste-in-place at the landfill in short tons
LMOP Waste in Place Year Year corresponding to the waste-in-place at the landfill (YYYY)
LMOP WIP % MSW Percent of the waste-in-place that is municipal solid waste LMOP Annual Waste Acceptance Ra Annual acceptance rate of waste at the landfill in short tons per year LMOP Annual Waste Acceptance Ye Year corresponding to the annual waste acceptance rate at the landfill (YYYY) LMOP Annual Acceptance % MSW Percent of the annual waste acceptance rate that is municipal solid waste LMOP Non-MSW Waste Description Description of the waste-in-place that is not municipal solid waste
LMOP WIP % C&D Percent of the waste-in-place that is construction & demolition waste
LMOP WIP % Industrial Percent of the waste-in-place that is industrial waste

LMOP WIP % Other Percent of the waste-in-place that is something other than MSW, C&D, or industrial waste LMOP WIP % Other Description Description of the "other" type of waste

LMOP LFG Generated (mmscfd) Estimated amount of landfill gas generated by landfill in million standard cubic feet per day LMOP Field Testing Was landfill gas generated estimate determined by field testing? LMOP Modeling Was landfill gas generated estimate determined by modeling?

LMOP Field Testing/Modeling Descr Description of field testing or modeling that determined landfill gas generated estimate

LMOP LFG Collection System In Plac Is there a landfill gas collection system in place? 'Yes' for an active GCCS; 'No' if landfill has no gas collection system, is passively venting/flaring, or has perimeter gas wells. LMOP LFG Collected (mmscfd) Amount of landfill gas being collected in million standard cubic feet per day
LMOP Percent Methane Percent of landfill gas that is methane (typically 40-50%)
LMOP Flares in Place? Is there one or more flares in place at the landfill?
LMOP Number of Flares Number of flares in place at the landfill

LMOP LFG Flared (mmscfd) Amount of landfill gas flared (if project is operational, amount of landfill gas flared in back-up flare(s)) in million standard cubic feet per day
LMOP Reason for Flare Use Description of the reason the landfill is flaring landfill gas LMOP Flare System Comments Comments regarding the flaring (and gas collection) system at the landfillAppendix A-2: Background Data: GHGRP 2010

Field Name Description FACILITY_ID GHGRP Identifier for landfill FACILITY_NAME Landfill Name

EST YEAR LANDFILL CLOSURE Year landfill stopped accepting waste or is expected to stop accepting waste or year landfill closed or is expected to close (YYYY)

LANDFILL OPEN Open/Closed status of landfill

LANDFILL CAPACITY CONVERTED (short tons) Waste design capacity of landfill in short tons

LMOP Waste in Place (tons) Combined Waste-in-place at the landfill in short tons from multiple consolidated landfills in LMOP
database
LMOP Waste in Place Year Waste-in-Place Year

LMOP Annual Waste Acceptance Rate (tons per year) Combined Annual acceptance rate of waste at the landfill in short tons per year from multiple
consolidated landfills in LMOP database LMOP Annual Waste Acceptance

Year Year corresponding to the annual waste acceptance rate at the landfill (YYYY)

Open year Year landfill opened or began accepting waste (YYYY) Table contains data from landfills reporting to GHGRP that were not in LMOP's database as of July 2012.Appendix A-3: Background Data: Consolidated List - LMOP GHGRP and Survey

Field Name Description
Landfill Name Landfill name

Landfill ID # Unique identifying number for each landfill

Landfill Owner Type (Public/Private) Indicates if landfill is publicly owned, privately owned, or co-owned by public and private
entities Landfill Owner Organization Organization that owns the landfill
Current Landfill Status Open/Closed status of landfill

Landfill Design Capacity (tons) Waste design capacity of landfill in short tons

LF Footprint (Acres) Footprint of landfill in acres as reported in

survey

Designed Landfill Area (acres) Design waste mass area of landfill in acres

Current Landfill Area (acres) Current waste mass area of landfill in acres

Total Area (acres) Total area of land the landfill is located on

Waste Depth (Ft) Depth of waste (feet) as reported in survey

Current Landfill Depth (feet) Current waste mass depth of landfill (maximum or average) in feet

Designed Landfill Depth (feet) Design waste mass depth of landfill (maximum or average) in feet

Date of First Waste Received Year first waste received as reported in survey

Year Landfill Opened Year landfill opened or began accepting waste (YYYY)

Year of Final Waste Received Year final waste received as reported in survey

Landfill Closure Year Year landfill stopped accepting waste or is expected to stop accepting waste or year landfill closed or is expected to close (YYYY)

Waste in Place (tons) Waste-in-place at the landfill in short tons

Waste in Place Year Year corresponding to the waste-in-place at the landfill (YYYY)

Annual Waste Acceptance Rate (tons per year) Annual acceptance rate of waste at the landfill in short tons per year Table contains a consolidated list of 2,353 landfills based on LMOP July 2012 data, GHGRP 2010 data and the voluntary landfill survey (2010) data. These data were used to develop inventory for analysis of costs and emission impacts.Annual Waste Acceptance Year Year corresponding to the annual waste acceptance rate at the landfill (YYYY)

Veolia WAR Annual acceptance rate of waste at the landfill in short tons per year reported by Veolia in survey (most recent year of data from historical waste acceptance) Landfill City City landfill is located in or near
Landfill State State landfill is located in

Annual Precipitation (Inches) Precipitation received in county landfill is
located in Landfill County County landfill is located in Landfill Name (survey) Name of landfill on voluntary surveyAppendix A-4: Background Data: LMOP GCCS Crosswalk

Field Name Description

NSPS/EG Dataset Landfill_ID Identifier from landfill inventory table
Landfill_Name Landfill Name

Landfill_City Landfill City Landfill_County Landfill County

Landfill_State Landfill State

LMOP Landfill ID Identifier from LMOP dataset (if blank, landfill is a model landfill and is not in the LMOP dataset)

LFG Collection System In Place? LMOP database status of whether a gas collection and control system is installed at landfill No of Operational LFG Energy

Projects LMOP database tracking of number of landfill gas energy recovery projects installed at landfill Table identifies which landfills in the NSPS/EG dataset report a GCCS installed according to the December 2013 LMOP database and which of those have energy projects installed.Appendix A-5: Background Data: Electricity_Rates

Field Name Description

State State associated with rate

ElectricityPurchase Average Rate in state or territory used to approximate buyback rates for states without wholesale price data, 2009 $/kWh

ElectricityBuyback Average Rate in state or territory used to estimate revenue for LFG energy projects, 2009 $/kWh Table identifies which landfills in the NSPS/EG dataset report a GCCS installed according to the December 2013 LMOP database and which of those have energy projects installed.Appendix A-6: Field Mapping Inventory_Landfills

Field Name Description

FRS_ID FRS ID assigned for landfills that exceed design capacity threshold of 2.5 million Mg Landfill_ID ID from LMOP Landfill and LFG Energy Project Database, 2012. Landfill_Name Landfill Name

Landfill_City City landfill is located in or near Landfill_County County landfill is located in

Landfill_State State landfill is located in
Landfill Address Physical address of landfill
Landfill Latitude Latitude coordinate (decimal) for the landfill Landfill Longitude Longitude coordinate (decimal) for the landfill Landfill_Year_Opened Year Landfill Opened Landfill_Closure_Year Landfill Closure Year Landfill_Current_Status Current Landfill Status Landfill_Designed_Area Designed Landfill Area (acres) Landfill_Current_Area Current Landfill Area (acres) Landfill_Designed_Depth Designed Landfill Depth (feet) Landfill_Current_Depth Current Landfill Depth (feet) Landfill_Waste_Depth Waste Depth (feet) Landfill_Design_Cap_yds Design Capacity (cubic yards) Landfill_Design_Cap_tons Landfill Design Capacity (tons) Table contains master list of existing landfills that accepted waste after 1987 and before 2012 that had sufficient data available to model LFG generation.Appendix A-7: Field Mapping Inventory_Model Landfills

Field Name Description Landfill_ID Public ID from LMOP Landfill and LFG Energy Project Database, 2012.

Landfill_Name Landfill Name

Landfill_City Surrogate city for estimating precipitation Landfill_County Surrogate county for estimating precipitation

Landfill_State Surrogate state for estimating precipitation Landfill_Year_Opened Year Landfill Opened Landfill_Closure_Year Landfill Closure Year Landfill_Current_Status Current Landfill Status Landfill_Designed_Area Designed Landfill Area (acres) Landfill_Current_Area Current Landfill Area (acres) Landfill_Designed_Depth Designed Landfill Depth (feet) Landfill_Current_Depth Current Landfill Depth (feet) Landfill_Waste_Depth Waste Depth (feet) Landfill_Design_Cap_yds Design Capacity (cubic yards) Landfill_Design_Cap_tons Landfill Design Capacity (tons) Landfill_WIP Waste in Place (tons) Landfill_WIP_Year Waste in Place Year Landfill_Ann_WAR Annual Waste Acceptance Rate (tons per year) Landfill_Ann_WAR_Year Annual Waste Acceptance Year Table contains master list of model landfills expected to open after 2010 and before 2014 based on recently opened landfills in the Inventory_Landfill table. These landfills in addition to the landfills in the Inventory_Landfill table are used to estimate the preliminary impacts on any changes to regulations for existing landfills.Appendix A-8: Field Mapping Calculated Inputs_Annual Waste through 2037-ANPRM Existing

Field Name Description Landfill_ID Public Identifier from landfill inventory table Annual_WAR_Year Year of waste acceptance, if year does not appear for landfill has closed or not yet opened Annual_WAR Annual Waste Acceptance Rate (tons per year) Annual_WIP Annual Waste-in-Place (tons) Annual_Acreage Acreage in year Table contains estimated annual waste acceptance rates and waste-in-place data based on inventory characteristics. These data are used in modeling emissions. Since equipment was sized based on a 15-year lifetime, waste input date through 2037 are presented to estimate gas flows over a 15-year lifetime for a project commencing operation in 2023.Appendix A-9: LOOKUP_Option Runs

Field Name Description

Run Run identifier Design_Capacity_Cu
toff Design Capacity threshold, megagrams NMOC_Cutoff Emission threshold, megagram/yr NMOC

Initial_Lag_Time years to install system after emission threshold is
exceeded Expansion_Lag_Tim

e years to expand system Interest_Rate interest rate for annualizing capital costs This table summarizes the attributes of each preliminary control option analyzed and discussed in the ANPRM.Appendix A-10: Output_Gas Flow 2014 to 2037 ANPRM Existing

Field Name Description

RunID See LOOKUP_Options Runs for Index of option descriptions Landfill_ID Public Landfill Identifier Annual_Gas_Year Year associated with gas collection rates, based on GCCS equipment installation and expansion schedule of each option ProjectStartYear First year GCCS is installed ProjectEndYear Last year of GCCS operation Annual_Wells Number of Wells in Annual_Gas_Year Annual_Acreage Acreage of Wellfield in Annual_Gas_Year FlagExpansionYear Time lapse (years) since the most recent wellfield installation or expansion Annual_LFG_ft3_AP42 LFG generated in Annual_Gas_Year with AP-42 Defaults for k, Lo, and NMOC, ft3/yr Annual_LFG_ft3_NSPS LFG generated in Annual_Gas_Year with Tier 1 Defaults for k and Lo and AP-42 Default for NMOC, ft3/yr Annual_Methane_ft3_NSPS Methane generated in Annual_Gas_Year with Tier 1 Defaults for k and Lo and AP-42 Default for NMOC, ft3/yr Annual_NMOC_NSPS NMOC generated in Annual_Gas_Year with Tier 1 Defaults for k and Lo and AP-42 Default for NMOC, Mg/yr Annual_Collected_NMOC_NSPS NMOC collected in Annual_Gas_Year with Tier 1 Defaults for k and Lo and AP-42 Default for NMOC, Mg/yr

Annual_Collected_LFG_NSPS LFG collected in Annual_Gas_Year with Tier 1 Defaults for k and Lo and AP-42 Default for NMOC, Mg/yr Annual_Methane_ft3_AP42 Methane generated in Annual_Gas_Year with AP-42 Defaults for k, Lo, and NMOC, ft3/yr Annual_NMOC_AP42 NMOC generated in Annual_Gas_Year with AP-42 Defaults for k, Lo, and NMOC, Mg/yr Annual_Collected_NMOC_AP42 NMOC collected in Annual_Gas_Year with AP-42 Defaults for k, Lo, and NMOC, Mg/yr

Annual_Collected_LFG_AP42 LFG collected in Annual_Gas_Year with AP-42 Defaults for k, Lo, and NMOC, Mg/yr Max_Annual_LFG_NSPS Maximum annual LFG, used to determine if the landfill exceeds an option threshold. ft3/yr Max_Annual_NMOC_NSPS Maximum annual NMOC, used to determine if the landfill exceeds an option threshold, Mg/yr 15yr_Max_LFG_ft3_AP42 Maximum LFG collected over 15-year time frame, with AP-42 Defaults for k, Lo, and NMOC, ft3/yr. Used to size equipment. EngineMultiplier Number of engines estimated per year based on supply of 195 million ft3 per year per engine

Next15yrLow_EngineMultiplier Minimum number of engines required over the next 15 years. Used to ensure that engines are only modeled when there is enoug run the engine for 15 years. EnginesOperated Number of engines installed, based on minimum supply of 195 million ft3 per year per engine over 15 year period. This table includes the gas generated and collected quantities on an annual basis, using different modeling parameters. These data were used to assess the timing of installation an expansion of controls as well as to estimate the reductions and size of any collection and control equipment needed. Since equipment was sized based on a 15-year lifetime, gas flow through 2037 are presented to accommodate estimate a 15-year lifetime for a project commencing operation in 2023.Appendix A-11: Output_Costs All Options 2014 to 2023 ANPRM Existing

Field Name Description
RunID See LOOKUP_Options Runs for Index of option descriptions Landfill_ID Public Landfill Identifier

CostYear Year annualized costs apply, based on GCCS equipment installation and expansion schedule of each option Capital_Engine Annualized capital of engine if recovery project present, from Eq. 9 ($2012) Capital_Flare Annualized capital of flare, from Eq. 5 ($2012) Capital_Installation Annualized installation (mobilization) cost of drill rig, from Eq. 8 ($2012) Capital_Well Annualized capital of wells, from Eq. 6 ($2012) Capital_WellHead Annualized capital of wellheads, from Eq. 7 ($2012)

OM_Electricity Annual electricity cost for blowers, from Eq. 12 ($2012)

OM_Engine Annual O&M cost for engine if recovery project present, from Eq. 13 ($2012) OM_Flare Annual O&M cost for flare, from Eq. 10 ($2012) OM_Well Annual O&M cost for well, from Eq. 11 ($2012)

Revenue_Engine Annual revenue from electricity project, if engine is installed, from Eq. 14 ($2012)

Net Cost Sum of all annualized capital and O&M costs minus any revenue ($2012) This table includes the total annualized capital, O&M costs, and revenue, for each option during the period of 2014 to 2023. Incremental emission reductions were calculated by subracting the net cost associated with the current rule requirements (option 1)Appendix A-12: Output_Emission_Reductions All Options 2014-2023 ANPRM Existing

Field Name Description

RunID See LOOKUP_Options Runs for Index of option descriptions Landfill_ID Public Landfill Identifier Landfill_Closure_Ye

ar Year landfill closed

Annual_Gas_Year Year annualized reductions occur, based on GCCS equipment installation and expansion schedule of each option

Annual_NMOC_Mg Annual NMOC emission reductions, Mg/yr Annual_LFG_Mg_C

O2e Annual Methane emission reductions, Mg/yr CO2e (based on GWP of 25) Annual_LFG_Mg_M
ethane Annual Methane emission reductions, Mg/yr This table includes the annual emisison reductions (total) for each option during the period of 2014 to 2023. Incremental emission reductions were calculated by subracting the reductions associated with the current rule requirements (option 1)Appendix A-13: Output_Uncontrolled Potential Emissions - ANPRM Existing

Field Name Description Landfill_ID Public Landfill Identifier Annual_Gas_Year Year of potential emissions SumOfAnnual_LFG_AP42 potential LFG emissions ft^3 per year Mg_NMOC_AP42 potential NMOC emissions Mg per year SumOfAnnual_Methane_AP42 potential methane emissions ft^3 per year

Methane Mg AP42 CO2e potential methane emissions Mg per year CO2e (GWP = 25) Methane Mg AP42 potential methane emissions Mg per year This table includes the estimated emissions from modeled gas generation rates for all landfills, not just the landfills expected to control under various options under
consideration.Appendix B-1: Field Mapping Inventory_Model Landfills

Field Name Description Landfill_ID Public ID from LMOP Landfill and LFG Energy Project Database, 2012.

Landfill_Name Landfill Name

Landfill_City Surrogate city for estimating precipitation Landfill_County Surrogate county for estimating precipitation

Landfill_State Surrogate state for estimating precipitation Landfill_Year_Opened Year Landfill Opened Landfill_Closure_Year Landfill Closure Year Landfill_Current_Status Current Landfill Status Landfill_Designed_Area Designed Landfill Area (acres) Landfill_Current_Area Current Landfill Area (acres) Landfill_Designed_Depth Designed Landfill Depth (feet) Landfill_Current_Depth Current Landfill Depth (feet) Landfill_Waste_Depth Waste Depth (feet) Landfill_Design_Cap_yds Design Capacity (cubic yards) Landfill_Design_Cap_tons Landfill Design Capacity (tons) Landfill_WIP Waste in Place (tons) Landfill_WIP_Year Waste in Place Year Landfill_Ann_WAR Annual Waste Acceptance Rate (tons per year) Landfill_Ann_WAR_Year Annual Waste Acceptance Year Table contains master list of model landfills expected to open between 2014 and 2018 based on recently opened landfills in the Inventory_Landfill table. Used to estimate impacts of the proposed new subpart XXX.Appendix B-2: Field Mapping Calculated Inputs_Annual Waste through 2037-Proposed XXX

Field Name Description Landfill_ID Public Identifier from landfill inventory table Annual_WAR_Year Year of waste acceptance, if year does not appear for landfill has closed or not yet opened Annual_WAR Annual Waste Acceptance Rate (tons per year) Annual_WIP Annual Waste-in-Place (tons) Annual_Acreage Acreage in year Table contains estimated annual waste acceptance rates and waste-in-place data based on inventory characteristics. These data are used in modeling emissions. Since equipment was sized based on a 15-year lifetime, waste input date through 2037 are presented to estimate gas flows over a 15-year lifetime for a project commencing operation in 2023.Appendix B-3: LOOKUP_Option Runs

Field Name Description

Run Run identifier Design_Capacity_Cu
toff Design Capacity threshold, megagrams NMOC_Cutoff Emission threshold, megagram/yr NMOC

Initial_Lag_Time years to install system after emission threshold is
exceeded Expansion_Lag_Tim

e years to expand system Interest_Rate interest rate for annualizing capital costs This table summarizes the attributes of each control option analyzed for proposed subpart XXX.Appendix B-4: Output_Gas Flow 2014 to 2037 Proposed XXX

Field Name Description

RunID See LOOKUP_Options Runs for Index of option descriptions Landfill_ID Public Landfill Identifier Annual_Gas_Year Year associated with gas collection rates, based on GCCS equipment installation and expansion schedule of each option ProjectStartYear First year GCCS is installed ProjectEndYear Last year of GCCS operation Annual_Wells Number of Wells in Annual_Gas_Year Annual_Acreage Acreage of Wellfield in Annual_Gas_Year FlagExpansionYear Time lapse (years) since the most recent wellfield installation or expansion Annual_LFG_ft3_AP42 LFG generated in Annual_Gas_Year with AP-42 Defaults for k, Lo, and NMOC, ft3/yr Annual_LFG_ft3_NSPS LFG generated in Annual_Gas_Year with Tier 1 Defaults for k and Lo and AP-42 Default for NMOC, ft3/yr Annual_Methane_ft3_NSPS Methane generated in Annual_Gas_Year with Tier 1 Defaults for k and Lo and AP-42 Default for NMOC, ft3/yr Annual_NMOC_NSPS NMOC generated in Annual_Gas_Year with Tier 1 Defaults for k and Lo and AP-42 Default for NMOC, Mg/yr Annual_Collected_NMOC_NSPS NMOC collected in Annual_Gas_Year with Tier 1 Defaults for k and Lo and AP-42 Default for NMOC, Mg/yr

Annual_Collected_LFG_NSPS LFG collected in Annual_Gas_Year with Tier 1 Defaults for k and Lo and AP-42 Default for NMOC, Mg/yr Annual_Methane_ft3_AP42 Methane generated in Annual_Gas_Year with AP-42 Defaults for k, Lo, and NMOC, ft3/yr Annual_NMOC_AP42 NMOC generated in Annual_Gas_Year with AP-42 Defaults for k, Lo, and NMOC, Mg/yr Annual_Collected_NMOC_AP42 NMOC collected in Annual_Gas_Year with AP-42 Defaults for k, Lo, and NMOC, Mg/yr

Annual_Collected_LFG_AP42 LFG collected in Annual_Gas_Year with AP-42 Defaults for k, Lo, and NMOC, Mg/yr Max_Annual_LFG_NSPS Maximum annual LFG, used to determine if the landfill exceeds an option threshold. ft3/yr Max_Annual_NMOC_NSPS Maximum annual NMOC, used to determine if the landfill exceeds an option threshold, Mg/yr 15yr_Max_LFG_ft3_AP42 Maximum LFG collected over 15-year time frame, with AP-42 Defaults for k, Lo, and NMOC, ft3/yr. Used to size equipment. EngineMultiplier Number of engines estimated per year based on supply of 195 million ft3 per year per engine

Next15yrLow_EngineMultiplier Minimum number of engines required over the next 15 years. Used to ensure that engines are only modeled when there is enoug run the engine for 15 years. EnginesOperated Number of engines installed, based on minimum supply of 195 million ft3 per year per engine over 15 year period. This table includes the gas generated and collected quantities on an annual basis, using different modeling parameters. These data were used to assess the timing of installation an expansion of controls as well as to estimate the reductions and size of any collection and control equipment needed. Since equipment was sized based on a 15-year lifetime, waste i through 2037 are presented to estimate gas flows over a 15-year lifetime for a project commencing operation in 2023.Appendix B-5: Output_Costs All Options 2014 to 2023 Proposed XXX

Field Name Description
RunID See LOOKUP_Options Runs for Index of option descriptions Landfill_ID Public Landfill Identifier

CostYear Year annualized costs apply, based on GCCS equipment installation and expansion schedule of each option Capital_Engine Annualized capital of engine if recovery project present, from Eq. 9 ($2012) Capital_Flare Annualized capital of flare, from Eq. 5 ($2012) Capital_Installation Annualized installation (mobilization) cost of drill rig, from Eq. 8 ($2012) Capital_Well Annualized capital of wells, from Eq. 6 ($2012) Capital_WellHead Annualized capital of wellheads, from Eq. 7 ($2012)

OM_Electricity Annual electricity cost for blowers, from Eq. 12 ($2012)

OM_Engine Annual O&M cost for engine if recovery project present, from Eq. 13 ($2012) OM_Flare Annual O&M cost for flare, from Eq. 10 ($2012) OM_Well Annual O&M cost for well, from Eq. 11 ($2012)

Revenue_Engine Annual revenue from electricity project, if engine is installed, from Eq. 14 ($2012)

Net Cost Sum of all annualized capital and O&M costs minus any revenue ($2012) This table includes the total annualized capital, O&M costs, and revenue, for each option during the period of 2014 to 2023. Incremental emission reductions were calculated by subracting the net cost associated with the current rule requirements (option 1)Appendix B-6: Output_Emission_Reductions All Options 2014-2023 Proposed XXX

Field Name Description

RunID See LOOKUP_Options Runs for Index of option descriptions Landfill_ID Public Landfill Identifier Landfill_Closure_Ye

ar Year landfill closed

Annual_Gas_Year Year annualized reductions occur, based on GCCS equipment installation and expansion schedule of each option

Annual_NMOC_Mg Annual NMOC emission reductions, Mg/yr Annual_LFG_Mg_C

O2e Annual Methane emission reductions, Mg/yr CO2e (based on GWP of 25) Annual_LFG_Mg_M
ethane Annual Methane emission reductions, Mg/yr This table includes the annual emisison reductions (total) for each option during the period of 2014 to 2023. Incremental emission reductions were calculated by subracting the reductions associated with the current rule requirements (option 1)Appendix B-7: Output_Uncontrolled Potential Emissions - Subpart XXX

Field Name Description Landfill_ID Public Landfill Identifier Annual_Gas_Year Year of potential emissions SumOfAnnual_LFG_AP42 potential LFG emissions ft^3 per year Mg_NMOC_AP42 potential NMOC emissions Mg per year SumOfAnnual_Methane_AP42 potential methane emissions ft^3 per year

Methane Mg AP42 CO2e potential methane emissions Mg per year CO2e (GWP = 25) Methane Mg AP42 potential methane emissions Mg per year This table includes the estimated emissions from modeled gas generation rates for all landfills, not just the landfills expected to control under various options under
consideration.Appendix B-8: Outputs 2023 GCCS Acreage Proposed XXX

Field Name Description

RunID See LOOKUP_Options Runs for Index of option descriptions

Annual_Gas_Yea

r Year associated with gas collection rates, based on GCCS equipment installation and expansion schedule of each option

Landfill_ID Public Landfill Identifier

Annual_Acreage acreage of wellfield in 2023 This table estimates the acreage for each controlled landfills in 2023. This acreage was used to estimate testing and monitoring costs for each control option.1

MEMORANDUM

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

Programs Division, Fuel and Incineration Group



### FROM: E astern Research Group, Inc. (ERG)

DATE: April 2014

SUBJECT: Methodology for Estimating Cost and Emission Impacts of MSW Landfill Regulations

Introduction

The EPA is reviewing the new source performance standards (NSPS) for municipal solid waste (MSW) landfills and issuing an Advanced Notice of Proposed Rulemaking (ANPRM) for a review of the emission guidelines (EG) for MSW landfills (40 CFR part 60

, s ubpart WWW and 40 CFR part 60,

s ubpart Cc, respectively)

. Currently, t he regulations require any landfills of at least 2.5 million
megagrams (Mg) and 2.5 cubi c meters in design capacity with estimated nonmethane organic com p ounds (NMOC) emission s of at least 50 megagrams ( Mg ) per year to collect and control landfill gas (LFG) . As part of the proposed revisions, a Microsoft ® Access database was developed to calculate the cost and emission impacts associated with varying certain control parameters and applying these parameters to a dataset of existing and model future land fills

. The development of the dataset is discussed in another memorandum. 1 The purpose of this memorandum is to summarize the methodology for the evaluations.

1. General Assumptions

The emission reductions and costs associated with the requirements of the current rule are considered the baseline and each alternative was compared to this ba seline

. All existing landfills that accepted waste after November 1987 2 as well as future landfills that are predicted to open in the 5

- year period of January 201 4 t hro ugh December 20 18 are included in the analysis

. Annual estimates of

e mission reductions and costs w ere estimated for each landfill and alternative control scenario over the 10

- year period (2014

- 2023) following the proposed revisions to the NSPS. Costs were estimated using a 7 percent interest rate , which is consistent with EPA guidance for cost evaluations.

The alternative s differ from the baseline by variations in the emission rate threshold s, the design capacity threshold s, the initial lag time to install gas collection and control systems (GCCS)

, and the expansion lag time for GCCS

. A description of each variable is presented bel ow:

 The emission rate threshold in the current rule is 50 Mg per year NMOC

. T he alternati ve s include lower NMOC thresholds

.

1 ERG. 2014. Summary of Landfill Dataset Used in the Cost and Emission Analysis of Landfill Regulations

2 The designated facility under the EG is each existing MSW landfill that has accepted waste since November 8, 1987.2

 The design capacity threshold in the current rule is 2.5 million M g and 2.5 cubic meters

. Other landfill design capacity thresholds were evaluated as alternative s

.

 The initial lag time is the time period between when the landfill exceeds the emission threshold and when GCCS are required to be installed

. The current rule allows a 30

- month initial lag time

, which was modeled as a 3

- year lag time since the first

- order decay equation used to model emissions is on an annual , instead of monthly, basis

. Further, because the current rule requires annual NMOC emission reports to be submitted by 6 months into the following calendar year, the landfill would get 30 months after the submittal of its first NMOC emission report showing an exceedance to install the GCCS

, which is approximately 36 months after the excess emissions

occu r red. S horter initial lag times were examined among the alternative s

.

 The expansion lag time is the amount of time allotted fo r the landfill to expand the GCCS into waste being placed in new areas of the landfill

. The current rule allows 2 years after initial waste placement in closed areas and 5 years after initial waste placement in active areas of the landfill ; so the actual lag time varies by landfill depending how quickly expansion areas are filled and closed

. Based on input received during public outreach, most modern large landfills do not reach final grade within 2 years and a majority of landfills are comp lying with the 5 year provision

. Therefore, a 4

- year expansion lag time was assumed to represent the baseline . A shorter lag time was examined as an alternative.

2. Estimating Emission Impacts

2.1 Waste Estimates

First

, t he quantity of waste maintained in each landfill was estimated for each year of the analysis

, based on one of two methods: 1. When a landfill’s annual waste acceptance rate (WAR) and waste in place (WIP) values were available in the landfill dataset and associated with a particular year , t h ose values were extrapolated to estimate the landfill’s WAR and WIP for each year. This estimation method was designated Option A in the database table of Calculated Inputs_Annual Waste

 When a Landfill_WIP and Landfill_WIP_Year are reported, the WAR up u ntil the Landfill_WIP_Year is estimated based on the following relationship: WAR = Landfill_WIP / (Landfill_WIP_Year

- Landfill _Year_Open +1 ).

 The WAR after the Landfill_WIP_Year is based on the following relationship: WAR = (Landfill_Design_Cap_tons

- La ndfill_WIP) / (Landfill_Closure_Year

- Landfill _WIP_Year+1).

2. When WIP and WAR values were not available in the landfill dataset, the annual WAR was estimated using the landfill open and closure years and the landfill capacity and assuming a
constant WAR over the lifetime of the landfill. This estimation method was d esignated Option D
in the database table of Calculated Inputs_Annual Waste

.

 WAR = Landfill_Design_Cap_tons / (Landfill_Closure_Year

- Landfill _Year_Open+1) Next, t he annual WIP was calculated by summing the WAR over time. The EPA is aware of historical W AR data from GHGRP, and it plans to incorporate these data in a future iteration of the model. The EPA also noted that some respondents to the voluntary survey provided historical waste acceptance rates that will be considered in the next iteration of the analysis. 2.3

2.2 Emission Equations

After the annual quantity of waste was estimated for each landfill, a first order decay equation (Equation 1) was used estimate annual methane em issions from each landfill for each year during the period of 2014

- 20 2 3

.

Eq

. 1 :

Where : CH 4 t = Methane

, ft 3 in year t k = Methane generation rate, year

- 1
L 0 = Potential methane generation capacity, ft 3 methane per ton M = Mass of waste accepted in year t, tons
t = Analysis year (year 1 through 50) , year The volume of LFG produced by a landfill was estimated using Equation 2.

Eq

. 2 : LFG t = CH 4t × 2

Where: LFG t = Landfill gas, ft 3 in year t CH 4t = Methane , ft 3 in year t 2 = Multiplier to convert methane to LFG (assuming that LFG is 50 percent

methane), unitless

T he mass of NMOC emissions produced by each landfill was estimated based on the amount of LFG produced at the landfill , as shown in E quation 3.

Eq

. 3 : NMOC t = LFG t ÷ 35.32 × 595 × 3.6E

- 9

Where : NMOC t = NMOC in year t , Mg in year t LFG t = Landfill gas

, ft 3 in year t 35.32 = Conversion, ft 3 per m 3 595 = Concentration of NMOC in LFG , ppm NMOC by volume as hexane 3.6E

- 9 = Conversion factor , Mg NMO C per m 3 LFG

The mass of methane emissions produced by each landfill was estimated based on the volume of methane produced at the landfill, as shown in Equation 4 a

.
Eq

. 4 a : Mg CH 4 = CH 4t × 0.0423 ÷ 2000 ÷ 0.90718

Where: Mg CH 4 = Methane in year t, Mg in year t CH 4t = Methane , ft 3 in year t (From Equation 1) 0.0423 = Density of methane, lb per ft 3
2000 = Conversion , lb per short ton 0. 90718 = Conversion , short ton per Mg4

T he mass of methane emissions

, in terms of carbon dioxide equivalents

, produced by each landfill was estimated using the E quation 4b

.
Eq

. 4b : Mg CO 2 eq = Mg CH 4 × GWP CH4

Where: Mg CO 2 eq t = Methane emissions as c arbon dioxide equivalents , Mg in year t Mg CH 4t = Methane

, Mg in year t (From Equation 4 a ) GWP CH4 = 25, Global Warming Potential of Methane

2.3 NSPS/EG and AP

- 42 Default Values for Calculating Emissions 3

The current NSPS requires the use of Tier 1 default value for the potential methane generation capacity (L 0 ) and methane generation rate (k) to determine when the landfill exceeds the 50 M g NMOC
per year emission rate threshold

. The NSPS L 0 is equal to 5458 ft 3 methane per ton of waste and the NSPS k values are 0.05 per year for areas receiving 25 inches or more of rainfall per year and 0.02 per year for areas receiving less than 25 inches of rainfall

. While the NSPS offer s a conservatively high Tier 1 default NMOC concentration, the regulations allow the use of Tier 2 tests to determine NMOC concentration

. (Many landfills have conducted Tier 2 tests and gotten values that are consistent with the AP

- 42 average NMOC concentra tion of 595 ppmv. ) Therefore, the combination of the Tier 1 defaults for k and L 0 and the NMOC concentration of 595 ppmv were used to represent how landfills currently calculate NMOC emissions to determine if they have to install controls under the NSPS. B ecause t he use of these values result in estimates of LFG and NMOC that are in accordance with the current NSPS ; in this evaluation these estimates were called LFG NSPS/EG and NMOC NSPS/EG

. NSPS defaults tend to overestimate actual emissions at most landfill s (due to the conservatively high L 0 and k values). EPA has collected and compiled available emission factor data for landfills in the report Compilation of Air Pollutant Emission Factors (AP

- 42). 4 The AP

- 42 L 0 is equal to 3210 ft 3 methane per ton of waste

. T he AP

- 42 k values are 0.04 per year for areas receiving 25 inches or more of rainfall per year and 0.02 per year for areas receiving less than 25 inches of rainfall

. The use of these values , in combination with the NMOC concentr ation of 595 ppmv, result in estimates of LFG and NMOC that are in accordance with the AP

- 42; in this evaluation these estimates w ere called LFG AP

- 42 and NMOC AP

- 42

.
As previously mentioned, for this evaluation, LFG N SPS /EG and NMOC NSPS/EG were used to determine when landfills would install controls

. To determine when landfills may remove contro ls, t he

current r ule s al low landfills to measure the actual collected gas flow rate as well as the concentration (instead of relying on Tier 1 default L 0 and k defaults). Because the AP

- 42 values for L 0 and k produce results that more closely match actual gas flow rates and emissions, LFG AP

- 42 and NMOC AP

- 42 were used in this analysis to determine when landfill s would remove controls.

Landfill

- Specific k Factors

As noted above , t he k values depend on the amount of precipitation at the landfill

. For this evaluation, precipitation data by climate division from the National Oceanic and Atmospheric Administration (NOAA) were obtained and averaged over the per iod of 2000 to 2009. 5 These average

3 The modeling requirements for existing sources under the state and federal plans implementing the EG are similar to those for new sources under the current NSPS.

4 USEPA AP

- 42, Fifth Edition, Volume I Chapter 2: Solid Waste Disposal. http://www.epa.gov/t tn/chief/ap42/ch02/index.html

5 NOAA climate division data are available online at: http://www7.ncdc.noaa.gov/CDO/CDODivisionalSelect.jsp# and are available for download at ftp://ftp.ncdc.noaa.gov/pub/data/cirs

.5

precipitation factors of each climate division were matched to the county

- level location of each landfill. The k factors were assigned to each landfill based on the resulting amount of precipitation at each landfill.

2.4 Emission Reductions

To estimate emission reductions, the amount of LFG , methane and NMOC emitted at each landfill was estimated using the equations in Section 2.1

. After the emissions at each landfill exceed the NMOC emission rate threshold of each control scenario

, the model assume d that the collection equipment

wa s installed and operational at the landfill after the initial lag time of the control scenario

. For example, if the landfill exceeded the NMOC emission threshold in year 1 , and the initial lag time was 3 years, the landfill would begin collecting gas in year 4

. A s the landfill was filled over time, the model assumed the landfill would expand the GCCS into new areas of waste placement in accordance with the expansion lag time of the control scenario

. If the landfill wa s not expanding the gas collection system (i.e.

, by installing wells in new areas of waste placement) every year, the landfill may have produce d more emissions than

c ould be collected until the gas co llection system was expanded

.
Once the landfill reached the maximum gas production and the gas production started to decrease

, the analysis assumed that the GCCS would collect all of the emitted gas

. To determine the amount of LFG , methane and NMOC collected, the analysis used the LFG AP

- 42 and NMOC AP

- 42

, estimates w ith the appropriate lag times

. T his was the best estimate of actual gas collected. See Table 1 for an example of the collected gas estimate at a landfill where the initial lag time wa s 3 years and the expansion lag time

w as 4 years

.

Table 1. Example of Collected NMOC Estimate at a Landfill with an Ini tial Lag Time of 3 Years and an Expansion Lag Time of 4 Year s

Year NMOC NSPS/EG NMOC AP

- 42 Collected NMOC 1 50.2 27.7 0.0 2 50.4 27.9 0.0 3 50.6 28.0 0.0 4 50.8 28.2 28.2 5 51.0 28.3 28.2
6 51.1 28.5 28.2
7 51.3 28.6 28.2 8 51.5 28.7 28.7 9 51.6 28.9 28.7 10 51.7 29.0 28.7 11 51.9 29.1 28.7 12 52.0 29.2 29.2 13 52.1 29.3 29.2 14 52.2 29.4 29.2 15 52.3 29.5 29.2

The emission reductions are equal to the amount of collected NMOC and methane that is combusted

. T he amount of collected NMOC and methane destroyed by combust ion controls was estimated by multiplying the amount of collected gas by a destruction efficiency of 98 percent

. T he 98 percent destruction efficiency account s for the fact that combustion is not 100 percent efficient

.

3. Cost Equations

T he cost equations used in th is regulatory evaluation were derived from EPA’s Landfill Gas Energy Cost Model ( LFG c ost )

, version 2. 3

, which was developed by EPA ’s Landfill Methane Outreach Program ( LMOP ) . LFG c ost estimate s costs for gas collection, flare a nd energy recovery system s and was6

developed based on cost data obtained from equipment v endors and consulting firm s that have installed and operated numerous gas collection and control systems

. LFG c ost encompasses the types of costs included in the EPA Office of Air Quality Planning and Standards ( OAQPS ) control cost manual including capital costs, annual costs, and recovery credits

. Total capital costs include purchased equipment costs, installation costs, engineering and design costs, costs for site preparation and buildings, costs of permits and fees, and working capital

. Total annual costs include direct costs, in direct costs, and

re covery credits

. Direct annual costs are those that are proportional to a facility

- specific metric s such as the facility’s productive output or size

. Indirect annual costs are independent of facility

- specific metrics and may include cate gories such as administrative charges, taxes, or insurance

. R ecovery credits are for materials or energy recovered by the control system.

For this evaluation, all costs are presented in 201 2 $

. The costs included in LFG c ost are in 2008$ and were escalated to 2012$ using an escalation factor of 1 percent for capital costs and 2.5 percent for O&M costs

.
The analysis presents the annualized capital cost of flare s , well s , wellhead s (including piping to collect gas) and engine s over the lifetime of the equipment

. It was assumed that the equipment w ould be replaced when its lifetime was over, so the annualized capital costs were incurred as long as the landfill still had controls in place

. In order to calculate the annualization factors

, it was assume d that flares, wells, well heads, and engines ha d a 15

- year life time

. In addition, there was a mobilization/installation charge to bring well drilling equipment on site each time the gas collection system was expanded. Because the landfill would be drilling wells to expand the control system during the expansion lag year, it was assumed that this capital i nstallation cost ha d a lifetime equal to the expansion lag time

.
A number of the capital costs equations depend on the number of wells at each landfill

. In order to estimate the number of wells at each landfill, the number of acres that have been filled with waste for each landfill for each year were estimated

. It was assumed that the percent of design area filled (acres) would track the ratio of waste in place/design capacity (e.g., if a landfill had a waste

- in

- place amount equivalent to 40 percent of design capacity, then 40 percent of the planned acreage would be filled). In addition, it was assumed that each landfill would install one well per acre , consistent with the guidelines provided in the LFGcost model, and that the number of wells would increase periodically based on expansion lag time

. See Table 2 for an example of the number of we lls estimated annually at a landfill where the initial lag time is 3 years and the expansion lag time is 4 years

.

Table 2 . Example of Number of Wells at a Landfill with an Initial Lag Time of 3 Years and an Expansion Lag Time Equal to 4 Years (and the landfill reaches the emission rate threshold in year 1)
Year Acreage Number of Wells

1 98.2 0 2 102.9 0 3 107.5 0 4 112.1 112 5 116.8 112
6 121.4 112
7 126.1 112 8 130.7 131 9 135.4 131 10 140 131 11 140 131 12 140 140 13 140 1407 Year Acreage Number of Wells 14 140 140 15 140 140

3.1 Capital Costs

The equations used in this evaluation to calculate capital costs for flares, wells, wellheads (including gas collection piping), mobilization/installation, and engines are presented below

. All costs equations are shown on an individual landfill and year basis

.
Flare Capital Costs

Flares are the primary c ontrol device used at landfills

. A ll landfills required to comply with the control scenario were assumed to install flares; e ven landfills using engines would h ave flares as the back

up control device for periods when the engine s are not operating

. The capital flare costs wer e estimated using the equation below

, which was based on the installed cost of the knockout, blower, and flare system as determined in LFG c ost

. The f lares wer e sized based on the maximum LFG flow rate over the 15

- year flare lifetime , which could be as late as 2037 for projects that were expected to begin operation in 2023

.

Eq

. 5 :

Where: Flare capital = Installed annualized cost of knockout, blower, and flare system

, 201 2 $

z 15,y = Annualization factor where x=15 yrs and y= interest rate ( 0.07 ) , unitless LFG 15yrmax = Maximum LFG collected for 15 year project period , ft 3 per year 525,600 = Conversion factor, minutes per year $4,100 = Installed capital cost of knockout, blower, and flare system , 2008$ per

ft 3 /min LFG ( 1.0 1) 4 = Adjustment from 2008$ to 201 2 $, unitless 6

Well Capital Costs

T he w ell capital costs were based on a dollar per foot of well depth installed estimate from LFG c ost

. As shown in the equation below, w ells were assumed to have a depth of 10 feet less than the landfill depth

. The method used to estimate the number of wells at the landfill each year is described above.

Eq

. 6 : Well c apital = z 15,y × (Depth

– 10) × 90 × Wells a nnual × ( 1.0 1) 4

Where: Well ca pital = Installed annualized cost of wells

, 201 2 $

z 15,y = Annualization factor where x=15 yrs and y= interest rate ( 0.07 ) , unitless De pth = Landfill waste depth, feet 10 = feet $ 90 = Installed capital cost of one well, 2008$ per foot of well depth

6 Escalation equation uses a formula of (1 +escalation/100) t , where capital cost escalation is assumed to be 1 percent and t is equal to 4 years8

Wells annual = Number of wells operated each year ( 1.0 1) 4 = Adjustment from 2008$ to 201 2 $, unitless

Wellhead Capital Costs

The capital wellhead cost covered the equipment associated with each well, including the wellhead and gathering lines (and associated sumps) connecting the wells, and was dependent on the number of wells. T he capital wellhead costs at each landfill were estimated using a dollar per wellhea d installed cost from LFG c ost and the number of wells at each landfill

.

Eq

. 7 : Well h ead c apital = z 15,y × 15,000 × Wells a nnual × ( 1.0 1) 4

Where: Wellh ead c apital = Installed annualized cost of wellhead s , 201 2 $

z 15,y = Annualization factor where x=15 yrs and y= interest rate ( 0.07 ) , unitless $ 15,000 = Installed capital cost of one wellhead, 2008$ per well Wells annual = Number of wells operated each year ( 1.0 1) 4 = Adjustment from 2008$ to 201 2 $, unitless

Mobilization/ Installation Costs for Wellfield Expansion

The cost occurs each time the gas collection system (i.e., wellfield) was expanded into new areas of the landfill, so the frequency wa s dependent on the expansion lag time. This cost was independent of the number of wells being a dded. It included costs such as planning and set

- up, mobilization costs to get the well drilling rig on site, and limited engineering/management costs. This cost was estimated using the following equation:

Eq

. 8 : Installation ca pital = z x,y × 25,000 × ( 1.0 1) 4

Where: Installation c apital = Mobilization/i nstall ation annualized cost, 201 2 $

z x ,y = Annualization factor where x= expansion lag time in yrs and y= interest

rate ( 0.07 ) , unitless $ 25,000 = Mobilization/ Install ation costs, per occurrence , 2008$ ( 1.0 1) 4 = Adjustment from 2008$ to 201 2 $, unitless

Engine Capital Costs

Engines were assumed to be installed only at landfills that produce d enough LFG to power the engine and only when the electricity buyback rates allow ed the operation of the engine to b e profitable. Standard engines used at landfills have approximately 1 MW capacity, which equates to 195 million ft 3 per year of collected LFG (at 50 percent methane)

. Therefore, engines were assumed to be installed at landfills that ha d at least 195 million ft 3 per year of collected LFG for at least 15 years , which could be as late as 2037 for engines there were installed in 2023

.

T he engine capital and operation and maintenance (O&M) equations were calculated and summed to determine at what electric ity buyback rate an engine would be profitable

. The profitable electricity buyback rate was greater than $ 0.0457 per kWh at 7 percent interest

. It was assumed e ngines were only installed in states with buyback rates exceeding those values

.9

Multiple engin es may be present at a landfill when there is sufficient gas flow to support additional engines

. As noted above, one engine required 195 million ft 3 per year of collected LFG

. T o have two engines on site, the landfill must have had double that amount of LFG (390 million ft 3 per year ) for at least 15 years after the project start date, which could be as late as 2037 for projects starting in 2023

.
The capital costs for engines were based on the capital costs for standard reciprocatin g engine

generator sets in LFG c ost

. These costs include d gas compression and treatment to remove particulates and moisture (e.g., a chiller) , reciprocating engine and generator, electrical interconnect equipment, and site work including housings, utilities , and total facility engineering, design, and permitting.

Eq

. 9 : Engine capital = z 15,y × 1,850,000 × ( 1.0 1) 4 × Engine multiplier

Where: Engine capital = Installed annualized cost of engines

, 201 2 $

z 15,y = Annualization factor where x=15 yrs and y= interest rate ( 0.07 ) , unitless $ 1,850,000 = Installed capital cost of one reciprocating engine

- generator set , 2008$ per

engine ( 1.0 1) 4 = Adjustment from 2008$ to 201 2 $, unitless Engine multiplier = Number of engines needed

3.2 Operation and Maintenance (O&M) Costs

The equations used in this evaluation to calculate O&M costs for flares, wells, electricity , and engines are presented below

. All cost equations are shown on an individual landfill and year basis

. These costs for all landfills were summed by year and the resulting annual sums were used to estimate NPV

costs. To accurately estimate annual electricity costs and engine revenue from the generation and sale of electricity, two electricity prices were ne eded

. Landfills must purchase electricity to operate the blowers used to collect LFG

. EPA used commercial average retail electricity prices by State from t he U.S. Energy Information Administration to estimate electricity purchase prices at the landfill

.

L andfills utilizing engines generate revenue from the sale of the LFG

- produced electricity

. The amount of revenue generated depends primarily on the buyback rate negotiated between the landfill (or third party developer) and the electric company purchasing the LFG

- generated power

. Average (mean) wholesale prices for each s tate from the U.S. Energy Information Administration (EIA) were used to estimate electricity buyback rates 7

. These wholesale prices generally fit in the range of typical buy back prices for LFG of $0.025

- $0.07/kWh , as discussed in LMOP’s Project Development Handbook

. Additionally, LFGcost uses a default buyback rate of $0.06/kWh and the U.S. average of the wholesale prices used is $0.058/kWh.

EIA wholesale data were not available for three States (HI, RI & WV) . For these States, electricity purchase price data from EIA were used to estimate buyback rates. 8 The buyback rates were estimated by first determining the ratio of each State’s purchase price to the overall average U.S. purchase. This ratio was then multiplied by the calculated average U.S. whole price to estimate a buyback

7 U.S. DOE/EIA. Form EIA

- 861 Database. Final Data File for 2009 (File 1.xls). http://www.eia.doe.gov/cneaf/electricity/page/eia861.html

8 U.S. DOE/EIA. E lectric Sales, Revenue, and Average Price 2009. Table 4. Average Retail Price for Bundled and Unbundled Consumers by Sector, Census Division, and State, 2009. Nov 2010. http://www.eia.doe.gov/electricity/esr/table4.html10

rate

. Electricity price data for t he U.S. territories of Guam, Puerto Rico, and the Virgin Islands were not found

. T herefore, an LFGcost scenario was created using economic inputs expected on an island to estimate a buyback rate of $0.12/kWh utilized by all three territories.

Flare O&M Costs

A n estimate of the flare O&M costs from LFG c ost was used to estimate the flare annual costs, as shown in the equation below:

Eq

. 10 : Flare O&M = 4,500 × ( 1.0 2 5 ) 4

Where: Flare O&Ml = Flare annual O&M costs, 201 2 $ $ 4,500 = Annual O&M flare cost, 2008$ ( 1.0 2 5 ) 4 = Adjustment from 2008$ to 201 2 $, unitless 9

Well O&M Costs

A n estimate of the well O&M costs from LFG c ost was used to estimate the well annual costs, as shown in the equation below:

Eq

. 11 : Well O&M = 2,250 × Wells an nual × ( 1.0 2 5 ) 4

Where: Well O&M l = Well annual O&M costs, 201 2 $ $ 2,250 = Annual O& M well costs, 2008$ per well Wells annual = Number of wells operating each year ( 1.0 2 5 ) 4 = Adjustment from 2008$ to 201 2 $, unitless

Electricity O&M Costs

T he electricity cost of operating the blowers was calculated using the electricity usage of blowers and the electricity purchase price

.

Eq

. 12 : Electricity O&M = 0.002 × Electricity p urchase × LFG collected

Where: Electricity O&M = Electricity annual O&M costs, 201 2 $ 0.002 = Electricity usage by blowers , kWh per ft 3 LFG Electricity purchase = Electricity purchase price, 201 2 $ per kWh LFG collected = Amount of LFG collected, ft 3 per year

Engine O&M Costs

For landfills with engines installed, the O&M costs of the engine were estimated using the annual costs for standard reciprocating engine

- generator sets from LFG c ost, and taking into account the amount of time that the engine was operating each year and the number of engines on site

.

9 Escalation equation uses a formul a of (1+escalation/100) t , where O&M cost escalation is assumed to be 2.5 percent and t is equal to 4 years.11 Eq

. 13 : Engine O&M = 0.02 × 1

, 000 × 8,760 × 0.93 × ( 1.0 2 5 ) 4 × Engine multiplier

Where: E ngine O&M = Engine annual O&M costs, 201 2 $ 0.02 = Annual O&M engine cost, 2008$ per kWh 1

, 000 = Amount of electricity as kW produced by a 1 MW engine, kW per engine 8,760 = Conversion factor , hours per year 0.93 = Fraction of time that the engine is online, unitless ( 1.0 2 5 ) 4 = Adjustment from 2008$ to 201 2 $, unitless Engine multiplier = Number of engines

Engine Revenue Costs

For landfills with engines installed, the revenue of the electricity produced by the engines was calculated using the equation below. This equation assumed that all electricity generated was sold to the grid ( instead of some of the electricity generated being used to power the GCCS )

.

Eq

. 14 : Engine revenue = 1

, 000 × 8,760 × 0.93 × Electricity buyback × Engine multiplier

Where: Engine revenue = Engine annual revenue, 201 2 $ 1

, 000 = Amount of electricity as kW produced by a 1 MW engine, kW per engine 8,760 = Conversion factor, hours per year 0.93 = Fraction of time that the engine is online, unitless Electricity buyback = Electricity buyback rate, 201 2 $ per K W h Engine multiplier = Number of engines

4. Summary

This memorandum summari z es the emission reduction and cost equations use d to evaluate the cost and emission impacts of various control scenarios considered under the review of the NSPS and EG

. The EPA determine d which landfills met the design capacity and emission rate threshold s for each regulatory option , then calculate d t he emission reductions and costs for each landfill for each year from 201 4 through 20 2 3 under each control scenario using the equations described in this memorandum

. The results of applying this methodology to the landfills dataset are discussed in other memoranda and are detailed in the database. 10

, 11

, 12

, 13

10 ERG. 2014. Cost and Emissions Impacts Resulting from the Landfills NSPS Review.

11 ERG. 2014. Modeling Database Containing Inputs and Results of Proposed Revis ions to MSW Landfill NSPS.

12 ERG. 2014. Preliminary Cost and Emissions Impacts Analysis for Review of the MSW Landfills Emission Guidelines.

13 ERG. 2014. Modeling Database Containing Inputs and Preliminary Impacts for Review of the MSW Landfill Emission Guidelines.

### 1

MEMORANDUM

TO: Hillary Ward

, U.S. Environmental Pr otection Agency, OAQPS/ Sector Policies and

Programs Division, Fuel and Incineration Group

FROM: Eastern Research Group, Inc. (ERG)

DATE: April 2014

SUBJECT: Cost and Emissions Impacts Resulting from the Landfill s NSPS Review

Introduction

The purpose of this memorandum is to present the results of the analysis to estimate cost s and emission reductions for the 2014 r eview of the n ew s ource p erformance s tandards (NSPS) for m unicipal

s olid w aste (MSW) l andfills . These impacts were calculated for new landfills that are projected to commence construction, reconstruction, or modification in the first 5 years after proposal ( between 2014 and 2018 )

. The equation s and data inputs used to estimat e the impacts are discussed in other memora nda in the docket

. 1,2,3

Results are presented in 2012 dollars ($2012) and are based on the annualized costs in 2023 using an interest rate of 7 percent . By 2023, the new model landfills have reached a point in their lifecycle at which at least half of the models trigger the NMOC emission threshold, install controls, and therefore incur costs and emission reductions for most of the options under consideration in this review.

The results of the impacts analysis are presented for the proposed changes to the NSPS (the proposal) as well as several options. The results are presented as incremental impacts relative to impact s associated with the current design capacity and NMOC emission thresholds current ly in 40 CFR part 60

, subpart WWW

. Landfill

- specific details of each option under consideration are documented in the modeling database. 4 This memorandum is organized as foll ows:

1.0 Overview of Regulatory Options 2.0 E stimating Cost Impacts 3.0 Estimating Emission Reductions Impacts 4.0 Estimating Impacts for Enhanced Surface Emission Monitoring 5.0 References Appendix A: Index of Regulatory Options Appendix B : Charts Tracking Impact of NMOC Emission Thresholds and Lag Times Over Time Appendix C: Detailed Cost and Emission Reduction Impacts

1. Overview of Regulatory Options



### D escription s of the current regulatory baseline, the proposed revision, and alternativ e options are included in this s ection

.

### 2

1.1 Baseline

 Currently, 40 CFR part 60

, subpart WWW requires all landfills with a de sign capacity of 2.5 million m egagrams (Mg) and 2.5 million cubic meters or greater to report their NMOC emission rate. When the NMOC emission rate exceeds 50 Mg/yr, a landfill is required to control its emissions within 30 months of submitting a report in which the NMOC emissions exceeded the threshold. Based on the characteristics of the 21 modeled new landfills expected to commence constructio n, reconstruction, or modification in the first 5 years after proposal , 17 landfills are expected to meet the design capacity threshold. Of these 17 landfills

, eight are expected to exceed the NMOC emission threshold and install a gas collection and contro l system (GCCS) by 2023.

1. 2 Propos al

 The proposal reduces the NMOC emission threshold from 50 Mg/yr to 40 Mg/yr. T he number of landfills subject to the rule remain s the same as the baseline because the design capacity threshold remains the same. However, 1 1 landfills are expected to exceed the NMOC emission threshold and install a GCCS by 2023. The installation of the GCCS is accelerated under this option, because landfills will exceed the emission threshold earlier

, as shown in Table 1.

 Consistent with the current baseline, the proposal employ s 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 memorand um

. 2 As a result, 20 20 is the earliest year any cost and emission reduction impacts would be realized from the projected new landfills as shown in Table 1

.

Table 1 . Total Number of New Landfills Projected to Control Landfill Gas Emissions over the Initia l 10

- year Period

Control Parameters Number of Landfills with Control Systems Installed By Year 2014

- 201 9 2020 2021 2022 2023
Baselin e (2.5/50) 0 0 6 7 8
Proposal (2.5/40) 0 3 6 7 11

1. 3 Alternative Regulatory Options

The impacts of s everal regulatory options other than proposed option 2.5/40 were also considered. The options varied one or more of the control parameters and/or lag times to install and expand on the GCCS. These options are summarized in this memorandum for reference and include the following adjustments to the control requirements

. A complete index of the characteristics of each option considered is shown in Appendix A.

 Some o ptions incorporat ed a further reduction in the NMOC threshold, to 34 Mg/yr. These options also made a corresponding reduction in the design capacity threshold, from 2.5 m illion Mg to 2.0 million Mg in order to include any smaller landfills that might exceed this lower NMOC e mission threshold. While these landfills would be expected to achieve additional reductions over the lifetime of the landfill when compared to the baseline emission threshold of 50 Mg/yr, there can be some variation of how much additional emission reductio ns, if any

, would

### 3

be achieved in any particular year. A lower NMOC emission threshold would result in earlier installation of controls, and these initial systems would be designed smaller than a system that was installed at a later point in the landfill li fecycle. As a result, the amount of reductions achieved in any particular year may fluctuate above or below the baseline as shown in Chart B

- 1 of Appendix B.

 Other options considered increasing the design capacity threshold to 3.0 milli on Mg from 2.5 million Mg along with a reduced NMOC emission threshold of 40 Mg/yr. This option evaluated any potential reduction in the reporting burden from landfills that are subject to the rule but have not yet exceeded the emission threshold.

 Some options shortened the initial lag times for installing the GCCS. For example, shortening the initial lag time from 3 years to 2 years would require some landfills to install the controls earlier and would also trigger an earlier installation schedule for each subsequent ex pansion. However, because the same subset of landfills would require controls to b e installed under the current 3

- year lag times, the overall ad ditional emission reductions are not a s significant over time. Further, when installing controls a year earlier as a result of a shortened lag time, the initial system will be designed slightly smaller than a system designed to capture gas in a subsequent year.

 Some options shorten ed the expansion lag times. Reducing the expansion lag time achieves a larger net e mission reduction over time because each subsequent expansion is on a shorter 2

- year cycle. However, the same subset of landfills would still require controls to be installed under either lag time.

 Other options shortened both the initial and expansion l ag times. This combination of initial and expansion lag time reductions achieved the largest amount of reductions over time because they achieved an earlier installation start date, pai r ed with a tighter frequency of subsequent expansions.

 Finally, some options combined reduced de sign capacity or NMOC emission threshold with a shortened initial and/or expansion lag time.

Charts displaying the patterns of emission reductions as a function of various lag times are shown in Appendix B. The patterns of emission reductions follow a step

- wise pattern over time.

2

. Estimating Cost Impacts

For each option, the cost impacts analysis compares net annualized costs of the baseline option in 2023 to the net annualized costs of each regulatory option in 2023 . The costs incorporate annualized capital costs to install the GCCS, operating and maintenance (O&M) costs for the GCCS, and if relevant

, any annualized capital and O&M costs for energy recovery equipment. If energy recovery was expected to occur at a landfill, the annual revenue from the energy recovery 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. 2

In addition to the control costs to comply with the regulation, the costs also include testing and monitoring costs to demonstrate compliance . The testing and monitoring costs include the labor, equipment rental, and any capital expe nses involved with preparation of NMOC emission rate reports, conducting initial performance tests, monthly wellhead monitoring, continuous combustor monitoring, and quarterly surface emission monitoring. The detailed testing and monitoring equations are s hown in another memorandum. 3

The costs and revenues associated with the baseline and proposal are shown in Table 2.

### 4

Table 2 . Summary of Cost Impacts for Proposal in 2023

Option Annualized

Control Cost Average

Annualized Revenue Average

Annualized Testing and Monitoring Cost Average

Net Total Annualized Cost Total Costs of Baseline ($2012)
Baseline 2.5/50 23,956,900 21,315,300 66,400 2,708 ,000

Incremental Costs above Baseline ($2012) Proposal 2.5/40 3,178,800 2,713,700 5,900 471,000

The incremental costs associated with the other regulatory alternatives as well as a summary of each individual cost component are shown in Appendix C

.

3

. Estimating Emission Reduction Impacts

Th e emission reductions of each regulatory option a re presented 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 are shown in Table 3.

Table 3 . Summary of Emission Reductions for Proposal in 2023

Option NMOC

Reductions (Mg/yr) Methane

Reductions (Mg/yr) Methane

Reductions (Mg CO 2 e/yr) Incremental

Annual NMOC Reductions (Mg/yr) Incremental

Annual Methane Reductions (Mg/yr) Incremental

Methane Reductions (Mg CO 2 e/yr) Baseline 610 94,800 2,371,000 N/A N/A N/A Proposal 2.5/40 689 107,100 2,678,300 79 12,300 307,600

Detailed annual emission reductions for other options for each affected landfill are shown in the landfill modeling database outputs. 4

Table 4 summarizes the overall and incremental cost effectiveness of the proposal

.

Table 4 . Summary of Overall Cost

- Effectiveness Option $/Mg NMOC $/Mg Methane $/CO 2 e Baseline 2.5/50 4,4 00 2 9 1.1

Proposal 2.5/40 6,000 38 1.5

The overall cost effectiveness of the baseline is provided for reference and it was calculated by dividing the total emission reductions achieved under the baseline by the total costs associated with the

### 5

baseline. The incremental cost effectiveness of the proposal was calculated by dividing the incremental costs of the proposal by the incremental reductions of the proposal.

Additional details about the emission impacts and cost effectiveness of other reg ulatory alternatives can be found in Appendix C

.

4

. Estimating Impacts for Enhanced Surface Emission Monitoring

In the notice to propose amendments to the landfills NSPS, the EPA is requesting public comment on adopting an enhanced surface emissions monitoring (SEM) program. Using the methodology outlined in another memorandum 3 , SEM costs were estimated for both the proposed SEM program and the enhanced SEM program. 3 The costs for the proposed SEM pro gram are included as one element of the estimated testing and monitoring costs shown in Table 2 of this memo.

This section compares the costs of the proposed SEM program to the costs of the enhanced SEM
program as they would apply to the baseline and pro posal . The significant driver associated with the increased costs of an enhanced SEM program is the time it takes to walk a tighter traverse path. Under the proposed SEM program, the traverse path is every 30 meters (~ 100 feet) , but under an enhanced
appro ach, this traverse is every 25 feet, or approximately four times the distance of the current approach. There are also additional costs associated with an increased frequency of cover deficiencies identified and repaired as a result of walking a tighter pat h.

Table 5

. Summary of Costs for Proposed V ersus Enhanced Surface Emission Monitoring Program

Control Option Surface

Monitoring Option No. of

L andfills C onducting S urface M onitoring Average

Annual Cost Incremental

Cost Average

Annual Cost P er C ontrolled L andfill Incremental

Annual Cost per Controlled Landfill

Baseline (2.5/50) No change ( 30

-

meter traverse) 8 42,300 N/A 5,300 N/A
Enhanced (25

- foot traverse, integrated sample) 8 312,800 270,500 39,100 33,800

Proposed (2.5/40) No change (30

-

meter traverse) 11 50,000 7,700 4,500 700
Enhanced (25

- foot traverse, integrated sample) 11 362,900 320,600 33,000 29,100

5

. References

1. E RG. 2014 . Summary of Landfill Dataset Used in the Cost and Emission Reduction Analysi s of Landfill Regulations.

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

3. ERG. 2014 . Methodology for Estimating Testing and Monitoring Cost s for MSW Landfill Regulations.

### 6

4. ERG

. 2014. Modeling Database Containing Inputs and Results of Proposed Revisions to MSW Landfill NSPS

.

### A

- 1

Appendix A: Index of Regulatory Options for Landfill NSPS Review

Database Model Option # Option Name Description 1 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 report was submitted)

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

2 2.5/50, IL Same as current rule, except  Initial lag time = 2 years

3 Proposed

(2.5/40) Same as current rule, except:  NMOC cutoff = 40 Mg/yr

4 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

5 2.0/40 Same as current rule, except:  Design capacity cutoff = 2.0 million Mg

 NMOC cutoff = 40 Mg/yr

6 2.0/40, IL Same as current rule, except:  Design capacity cutoff = 2.0 million Mg

 NMOC cutoff = 40 Mg/yr

 Initial lag time = 2 years

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

 NMOC cutoff = 34 Mg/yr

8 2.0/34, IL, EL Same as current rule, except:  Design capacity cutoff = 2.0 million Mg

 NMOC cutoff = 34 Mg/yr

 Expansion lag time = 2 years

 Initial lag time = 2 years

9 3.0/40 Same as current rule, except:  Design capacity cutoff = 3.0 million Mg

 NMOC cutoff = 40 Mg/yr

10 3.0/40, EL Same as current rule, except:  Design capacity cutoff = 3.0 million Mg

 NMOC cutoff = 40 Mg/yr

 Expansion lag time = 2 years

11 2.0/50 Same as current rule, except  Design capacity cutoff = 2.0 million Mg

12 2.5/50, EL Same as current rule, except  Expansion lag time = 2 years

### B

- 1

Appendix B. Charts Displaying the Impact of Variations in NMOC Emission Thresholds and Lag Times

Figure B

- 1 . Impact of Reduced NMOC Emission Threshold

Figure B

- 2 . Impact of Shortened Initial Lag Time

0 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000

2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 Methane Emission Reductions (Mg CO2e/yr)

NMOC = 50 Mg/yr NMOC = 40 Mg/yr NMOC=34 Mg/yr

Threshold : Design Capacity : 2.0 million Mg
NMOC: various

-1,000,000 0 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000

2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 Methane Emission Reductions (Mg CO2e/yr)

Net Impact of Reduced Initial Lagtime Initial Lag = 3 years Initial Lag = 2 years

Thresholds : Design Capacity : 2.5 million Mg
NMOC : 50 Mg/yr

### B

- 2

Figure B

- 3 . Impact of Shortened Expansion Lag Time

Figure B

- 4 . Impact of Shortened Initial and Expansion Lag Time s

0 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000

2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 Methane Emission Reductions (Mg CO2e/yr)

Net Impact of Reduced Expansion Lagtime Expansion Lag = 4 years Expansion Lag = 2 years

Thresholds : Design Capacity : 2.5 million Mg
NMOC : 50 Mg/yr

0 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000

2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 Methane Emission Reductions (Mg CO2e/yr)

Net Impact of Reduced Initial and Expansion Lagtimes Initial Lag = 3 yrs; Expansion Lag = 4 yrs Initial and Expansion Lags = 2 years Thresholds : Design Capacity : 2.5 million Mg
NMOC : 40 Mg/yrAppendix C-1 Summary of Cost Impacts of Regulatory Options for Subpart XXX in 2023

**Internal Option #**  **Option Name Annualized**  **Capital for**

**Landfills Operating LFG**  **Engines Annualized**  **Capital for**

**Flares Annualized**  **Mobilization/I**

**nstallation**
**Costs Annualized**  **Capital for Wells**  **Annualized Capital for**  **Wellheads Annual**  **Electricity**

**Costs to Operate**  **Blowers Annual O&M**  **for Landfills**

**with LFG Engines**  **Annual O&M for Flares**  **Annual O&M for Wells**  **Total Annual**
**Costs Annual Revenue**  **from LFG Engines**  **Net Annualized Control Cost** 

1 Baseline (2.5/50) 9,934,308 708,960 61,443 571,593 880,892 2,030,412 8,452,991 39,737 1,276,560 23,956,896 21,315,288 2,641,608

2 Alternative Option (2.5/50); IL = 2 9,511,572 818,542 76,804 526,598 843,188 1,860,655 8,093,289 49,672 1,221,921 23,002,239 20,374,332 2,627,907

3 Proposal (2.5/40) 11,202,518 869,186 84,484 614,532 1,024,850 2,268,247 9,532,096 54,639 1,485,180 27,135,734 24,028,987 3,106,747

4 Alternative Option (2.5/40); IL = 2 years; EL = 2 years 9,511,572 920,382 172,665 759,968 1,287,061 2,766,123 8,093,289 59,606 1,865,168 25,435,835 20,483,499 4,952,336

5 Alternative Option (2.0/40) 11,202,518 869,186 84,484 614,532 1,024,850 2,268,247 9,532,096 54,639 1,485,180 27,135,734 24,028,987 3,106,747

6 Alternative Option (2.0/40); IL = 2 years 9,511,572 920,382 92,165 642,446 1,057,413 2,246,079 8,093,289 59,606 1,532,368 24,155,319 20,483,499 3,671,820

7 Alternative Option (2.0/34) 10,568,413 864,558 84,484 584,002 976,864 2,141,905 8,992,544 54,639 1,415,640 25,683,048 22,659,510 3,023,539

8 Alternative Option (2.5/34); IL = 2 years; EL = 2 years 8,454,731 915,497 172,665 768,930 1,305,913 2,796,013 7,194,035 59,606 1,892,487 23,559,877 18,253,720 5,306,157

9 Alternative Option (3.0/40) 11,202,518 869,186 84,484 614,532 1,024,850 2,268,247 9,532,096 54,639 1,485,180 27,135,734 24,028,987 3,106,747

10 Alternative Option (3.0/40); EL = 2 years 11,202,518 869,186 158,276 732,576 1,215,082 2,831,692 9,532,096 54,639 1,760,858 28,356,924 24,028,987 4,327,937

11 Alternative Option (2.0/50) 9,934,308 708,960 61,443 571,593 880,892 2,030,412 8,452,991 39,737 1,276,560 23,956,896 21,315,288 2,641,608

12 Alternative Option (2.5/50); EL = 2 years 9,934,308 708,960 115,110 690,397 1,072,837 2,587,924 8,452,991 39,737 1,554,721 25,156,986 21,315,288 3,841,698

IL = Initial Lag EL = Expansion Lag Totals

Annual Control CostsAppendix C-1 Summary of Cost Impacts of Reg

**Internal Option #**  **Option Name**

1 Baseline (2.5/50)

2 Alternative Option (2.5/50); IL = 2

3 Proposal (2.5/40)

4 Alternative Option (2.5/40); IL = 2 years; EL = 2 years

5 Alternative Option (2.0/40)

6 Alternative Option (2.0/40); IL = 2 years

7 Alternative Option (2.0/34)

8 Alternative Option (2.5/34); IL = 2 years; EL = 2 years

9 Alternative Option (3.0/40)

10 Alternative Option (3.0/40); EL = 2 years

11 Alternative Option (2.0/50)

12 Alternative Option (2.5/50); EL = 2 years

IL = Initial Lag EL = Expansion Lag Initial Performan

ce Tests NMOC
Emission

Rate Quarterly Surface Monitoring (30 m pattern) Total Testing and Monitoring **Annualized Control Costs**  **Annual Revenue from LFG**  **Engines Net Annualized**  **Control Cost Total**  **Testing and Monitoring**  **Total Annualized** 
**Cost**

8,842 15,225 42,306 66,373 2,707,982

11,053 11,842 47,098 69,993 2,697,900 (954,656) (940,955) (13,701) 3,619 (10,081)

12,158 10,150 49,971 72,279 3,179,027 3,178,838 2,713,699 465,139 5,906 471,045

13,264 8,459 53,275 74,998 5,027,333 1,478,939 (831,788) 2,310,727 8,624 2,319,352

12,158 11,842 49,971 73,971 3,180,719 3,178,838 2,713,699 465,139 7,598 472,737

13,264 10,150 53,275 76,689 3,748,509 198,424 (831,788) 1,030,212 10,316 1,040,528

12,158 11,842 49,971 73,971 3,097,510 1,726,153 1,344,222 381,931 7,598 389,528

13,264 10,150 53,275 76,689 5,382,847 (397,018) (3,061,567) 2,664,549 10,316 2,674,865

12,158 10,150 49,971 72,279 3,179,027 3,178,838 2,713,699 465,139 5,906 471,045

12,158 10,150 49,971 72,279 4,400,216 4,400,028 2,713,699 1,686,329 5,906 1,692,235

8,842 15,225 42,306 66,373 2,707,982

- - - - -

8,842 15,225 42,306 66,373 3,908,071 1,200,090

- 1,200,090

- 1,200,090 Annual Testing and Monitoring Costs

**Total Annualized**
**Cost** Incrementals**Internal Option #**  **Option Name Annual** 
**NMOC Reductions** 

**(Mg/yr) Annual**  **Methane Reductions** 

**(Mg/yr) Annual**  **Methane Reductions**  **(Mg CO2e/yr)**  **Incremen tal**  **Annual**
**NMOC Reduction**  **s (Mg/yr) Incremen**  **tal Annual**  **Methane Reduction**  **s (Mg/yr) Increment**  **al Annual Methane**  **Reduction s (Mg**  **CO2e/yr) $/Mg NMOC**  **$/Mg CH 4**  **$/Mg**
**CO2e**

1 Baseline (2.5/50) 610 94,826 2,370,652 4,443 29 1.1

2 Alternative Option (2.5/50); IL

= 2 years 570 88,688 2,217,206 (39) (6,138) (153,446)

3 Proposal (2.5/40) 689 107,130 2,678,257 79 12,304 307,605 5,956 38 1.5

4 Alternative Option (2.5/40); IL

= 2 years; EL = 2 years 839 130,601 3,265,014 230 35,775 894,363 10,087 65 2.6
5 Alternative Option (2.0/40) 689 107,130 2,678,257 79 12,304 307,605 5,977 38 1.5

6 Alternative Option (2.0/40); IL

= 2 years 684 106,359 2,658,975 74 11,533 288,323 14,037 90 3.6
7 Alternative Option (2.0/34) 651 101,206 2,530,152 41 6,380 159,500 9,499 61 2.4

8 Alternative Option (2.5/34); IL

= 2 years; EL = 2 years 847 131,774 3,294,356 237 36,948 923,704 11,263 72 2.9
9 Alternative Option (3.0/40) 689 107,130 2,678,257 79 12,304 307,605 5,956 38 1.5

10 Alternative Option (3.0/40); EL = 2 years 855 133,078 3,326,941 246 38,252 956,289 6,883 44 1.8
11 Alternative Option (2.0/50) 610 94,826 2,370,652

- - -

12 Alternative Option (2.5/50); EL = 2 years 775 120,500 3,012,492 165 25,674 641,840 7,272 47 1.9 N/A*

* Based on characteristics of projected modeled landfills there are no additional landfills with capacities between 2.0 million and 2.5 million that exceed the NMOC emission threshold of 50 Mg/yr by 2023. Incremental Total Cost Effectiveness

N/A - achieves less emission
reductions than baseline in 2023 Appendix C-2 Summary of Emission Impacts of Regulatory Options for Subpart
XXX in 2023Appendix C-3 Summary of Enhanced Surface Emission Monitoring Cost Impacts in 2023

**Internal Option #**  **Option Name** Quarterly
Surface Monitoring (25 ft pattern) Transposing
Data for Integrated

Sample
Calculations Improved
Surface
Maintenance

Allowance Total
Enhanced
SEM Incremental
SEM Costs
above Current
30-meter

pattern
1 Baseline (2.5/50) 154,506 31,501 126,802 312,810 270,504

2 Alternative Option

(2.5/50); IL = 2

years 170,267 34,742 139,846 344,855 302,549
3 Proposal (2.5/40) 179,042 36,585 147,267 362,894 320,588

4 Alternative Option

(2.5/40); IL = 2 years; EL = 2 years 190,915 38,854 156,397 386,166 343,860

5 Alternative Option

(2.0/40) 179,042 36,585 147,267 362,894 320,588

6 Alternative Option

(2.0/40); IL = 2

years 190,915 38,854 156,397 386,166 343,860

7 Alternative Option

(2.0/34) 179,042 36,585 147,267 362,894 320,588

8 Alternative Option

(2.5/34); IL = 2 years; EL = 2 years 190,915 38,854 156,397 386,166 343,860

9 Alternative Option

(3.0/40) 179,042 36,585 147,267 362,894 320,588

10 Alternative Option (3.0/40); EL = 2

years 179,042 36,585 147,267 362,894 320,588

11 Alternative Option (2.0/50) 154,506 31,501 126,802 312,810 270,504

12 Alternative Option (2.5/50); EL = 2

years 154,506 31,501 126,802 336,877 294,572 Annualized Costs of Enhanced Surface MonitoringRunID Landfill_ID Acreage
2023 25f Hours

Per
Monitorin

g Occurance 25f Days

Per
Monitorin

g Occurance 25f Weeks

per monitorin

g Occurance 25f
Months

per monitorin

g Occurance 25f Labor per year (4

occurances

per year) 25f Equipmen

t Rental

per year (4

occurance s per year) 30m
Hours Per
Monitorin

g Occurance 30m Days
Per
Monitorin

g Occurance 30m
Weeks

per monitorin

g Occurance 30m
Months

per monitorin

g Occurance 30m Labor per year (4

occurances

per year) 30m Equipment Rental per

year (4

occurances

per year) SCAQMD: Surface Maintenance per year (4 occurances per year)
10 F3 39 39 5 1 1 7,652 1,400 10 2 1 1 1,944 1,000 7,700

2 F3 39 39 5 1 1 7,652 1,400 10 2 1 1 1,944 1,000 7,700
3 F3 39 39 5 1 1 7,652 1,400 10 2 1 1 1,944 1,000 7,700
4 F3 39 39 5 1 1 7,652 1,400 10 2 1 1 1,944 1,000 7,700
5 F3 39 39 5 1 1 7,652 1,400 10 2 1 1 1,944 1,000 7,700
6 F3 39 39 5 1 1 7,652 1,400 10 2 1 1 1,944 1,000 7,700
7 F3 39 39 5 1 1 7,652 1,400 10 2 1 1 1,944 1,000 7,700
8 F3 39 39 5 1 1 7,652 1,400 10 2 1 1 1,944 1,000 7,700
9 F3 39 39 5 1 1 7,652 1,400 10 2 1 1 1,944 1,000 7,700
1 F6 256 256 32 7 2 50,878 8,800 65 9 2 1 12,923 2,800 51,200
10 F6 256 256 32 7 2 50,878 8,800 65 9 2 1 12,923 2,800 51,200

2 F6 256 256 32 7 2 50,878 8,800 65 9 2 1 12,923 2,800 51,200
3 F6 256 256 32 7 2 50,878 8,800 65 9 2 1 12,923 2,800 51,200
4 F6 256 256 32 7 2 50,878 8,800 65 9 2 1 12,923 2,800 51,200
5 F6 256 256 32 7 2 50,878 8,800 65 9 2 1 12,923 2,800 51,200
6 F6 256 256 32 7 2 50,878 8,800 65 9 2 1 12,923 2,800 51,200
7 F6 256 256 32 7 2 50,878 8,800 65 9 2 1 12,923 2,800 51,200
8 F6 256 256 32 7 2 50,878 8,800 65 9 2 1 12,923 2,800 51,200
9 F6 256 256 32 7 2 50,878 8,800 65 9 2 1 12,923 2,800 51,200
11 F6 256 256 32 7 2 50,878 8,800 65 9 2 1 12,923 2,800 51,200
12 F6 256 256 32 7 2 50,878 8,800 65 9 2 1 12,923 2,800 51,200

4 F7 46 46 6 2 1 9,073 2,800 12 2 1 1 2,305 1,000 9,130
6 F7 46 46 6 2 1 9,073 2,800 12 2 1 1 2,305 1,000 9,130
8 F7 46 46 6 2 1 9,073 2,800 12 2 1 1 2,305 1,000 9,130
10 F8 27 27 4 1 1 5,310 1,400 7 1 1 1 1,349 500 5,343

2 F8 27 27 4 1 1 5,310 1,400 7 1 1 1 1,349 500 5,343
3 F8 27 27 4 1 1 5,310 1,400 7 1 1 1 1,349 500 5,343
4 F8 27 27 4 1 1 5,310 1,400 7 1 1 1 1,349 500 5,343
5 F8 27 27 4 1 1 5,310 1,400 7 1 1 1 1,349 500 5,343
6 F8 27 27 4 1 1 5,310 1,400 7 1 1 1 1,349 500 5,343
7 F8 27 27 4 1 1 5,310 1,400 7 1 1 1 1,349 500 5,343
8 F8 27 27 4 1 1 5,310 1,400 7 1 1 1 1,349 500 5,343
9 F8 27 27 4 1 1 5,310 1,400 7 1 1 1 1,349 500 5,343
1 F10 58 58 8 2 1 11,564 2,800 15 2 1 1 2,937 1,000 11,637
10 F10 58 58 8 2 1 11,564 2,800 15 2 1 1 2,937 1,000 11,637

2 F10 58 58 8 2 1 11,564 2,800 15 2 1 1 2,937 1,000 11,637
3 F10 58 58 8 2 1 11,564 2,800 15 2 1 1 2,937 1,000 11,637 25-foot Traverse 30 meter traverse C-4. Detailed Landfill Costs of Quarterly SEM under Current 30- meter Pattern and the Tighter 25- foot traverse patternRunID Landfill_ID Acreage
2023 25f Hours

Per
Monitorin

g Occurance 25f Days

Per
Monitorin

g Occurance 25f Weeks

per monitorin

g Occurance 25f
Months

per monitorin

g Occurance 25f Labor per year (4

occurances

per year) 25f Equipmen

t Rental

per year (4

occurance s per year) 30m
Hours Per
Monitorin

g Occurance 30m Days
Per
Monitorin

g Occurance 30m
Weeks

per monitorin

g Occurance 30m
Months

per monitorin

g Occurance 30m Labor per year (4

occurances

per year) 30m Equipment Rental per

year (4

occurances

per year) SCAQMD: Surface Maintenance per year (4 occurances per year) 25-foot Traverse 30 meter traverse C-4. Detailed Landfill Costs of Quarterly SEM under Current 30- meter Pattern and the Tighter 25- foot traverse pattern

4 F10 58 58 8 2 1 11,564 2,800 15 2 1 1 2,937 1,000 11,637
5 F10 58 58 8 2 1 11,564 2,800 15 2 1 1 2,937 1,000 11,637
6 F10 58 58 8 2 1 11,564 2,800 15 2 1 1 2,937 1,000 11,637
7 F10 58 58 8 2 1 11,564 2,800 15 2 1 1 2,937 1,000 11,637
8 F10 58 58 8 2 1 11,564 2,800 15 2 1 1 2,937 1,000 11,637
9 F10 58 58 8 2 1 11,564 2,800 15 2 1 1 2,937 1,000 11,637
11 F10 58 58 8 2 1 11,564 2,800 15 2 1 1 2,937 1,000 11,637
12 F10 58 58 8 2 1 11,564 2,800 15 2 1 1 2,937 1,000 11,637

1 F13 18 18 3 1 1 3,612 1,500 5 1 1 1 918 500 3,635
10 F13 18 18 3 1 1 3,612 1,500 5 1 1 1 918 500 3,635

2 F13 18 18 3 1 1 3,612 1,500 5 1 1 1 918 500 3,635
3 F13 18 18 3 1 1 3,612 1,500 5 1 1 1 918 500 3,635
4 F13 18 18 3 1 1 3,612 1,500 5 1 1 1 918 500 3,635
5 F13 18 18 3 1 1 3,612 1,500 5 1 1 1 918 500 3,635
6 F13 18 18 3 1 1 3,612 1,500 5 1 1 1 918 500 3,635
7 F13 18 18 3 1 1 3,612 1,500 5 1 1 1 918 500 3,635
8 F13 18 18 3 1 1 3,612 1,500 5 1 1 1 918 500 3,635
9 F13 18 18 3 1 1 3,612 1,500 5 1 1 1 918 500 3,635
11 F13 18 18 3 1 1 3,612 1,500 5 1 1 1 918 500 3,635
12 F13 18 18 3 1 1 3,612 1,500 5 1 1 1 918 500 3,635

1 F15 73 73 10 2 1 14,432 2,800 18 3 1 1 3,666 1,500 14,523
10 F15 73 73 10 2 1 14,432 2,800 18 3 1 1 3,666 1,500 14,523

2 F15 73 73 10 2 1 14,432 2,800 18 3 1 1 3,666 1,500 14,523
3 F15 73 73 10 2 1 14,432 2,800 18 3 1 1 3,666 1,500 14,523
4 F15 73 73 10 2 1 14,432 2,800 18 3 1 1 3,666 1,500 14,523
5 F15 73 73 10 2 1 14,432 2,800 18 3 1 1 3,666 1,500 14,523
6 F15 73 73 10 2 1 14,432 2,800 18 3 1 1 3,666 1,500 14,523
7 F15 73 73 10 2 1 14,432 2,800 18 3 1 1 3,666 1,500 14,523
8 F15 73 73 10 2 1 14,432 2,800 18 3 1 1 3,666 1,500 14,523
9 F15 73 73 10 2 1 14,432 2,800 18 3 1 1 3,666 1,500 14,523
11 F15 73 73 10 2 1 14,432 2,800 18 3 1 1 3,666 1,500 14,523
12 F15 73 73 10 2 1 14,432 2,800 18 3 1 1 3,666 1,500 14,523

1 F16 42 42 6 2 1 8,375 2,800 11 2 1 1 2,127 1,000 8,427
10 F16 42 42 6 2 1 8,375 2,800 11 2 1 1 2,127 1,000 8,427

2 F16 42 42 6 2 1 8,375 2,800 11 2 1 1 2,127 1,000 8,427
3 F16 42 42 6 2 1 8,375 2,800 11 2 1 1 2,127 1,000 8,427
4 F16 42 42 6 2 1 8,375 2,800 11 2 1 1 2,127 1,000 8,427RunID Landfill_ID Acreage
2023 25f Hours

Per
Monitorin

g Occurance 25f Days

Per
Monitorin

g Occurance 25f Weeks

per monitorin

g Occurance 25f
Months

per monitorin

g Occurance 25f Labor per year (4

occurances

per year) 25f Equipmen

t Rental

per year (4

occurance s per year) 30m
Hours Per
Monitorin

g Occurance 30m Days
Per
Monitorin

g Occurance 30m
Weeks

per monitorin

g Occurance 30m
Months

per monitorin

g Occurance 30m Labor per year (4

occurances

per year) 30m Equipment Rental per

year (4

occurances

per year) SCAQMD: Surface Maintenance per year (4 occurances per year) 25-foot Traverse 30 meter traverse C-4. Detailed Landfill Costs of Quarterly SEM under Current 30- meter Pattern and the Tighter 25- foot traverse pattern

5 F16 42 42 6 2 1 8,375 2,800 11 2 1 1 2,127 1,000 8,427
6 F16 42 42 6 2 1 8,375 2,800 11 2 1 1 2,127 1,000 8,427
7 F16 42 42 6 2 1 8,375 2,800 11 2 1 1 2,127 1,000 8,427
8 F16 42 42 6 2 1 8,375 2,800 11 2 1 1 2,127 1,000 8,427
9 F16 42 42 6 2 1 8,375 2,800 11 2 1 1 2,127 1,000 8,427
11 F16 42 42 6 2 1 8,375 2,800 11 2 1 1 2,127 1,000 8,427
12 F16 42 42 6 2 1 8,375 2,800 11 2 1 1 2,127 1,000 8,427

1 F17 61 61 8 2 1 12,206 2,800 16 2 1 1 3,100 1,000 12,283
10 F17 61 61 8 2 1 12,206 2,800 16 2 1 1 3,100 1,000 12,283

2 F17 61 61 8 2 1 12,206 2,800 16 2 1 1 3,100 1,000 12,283
3 F17 61 61 8 2 1 12,206 2,800 16 2 1 1 3,100 1,000 12,283
4 F17 61 61 8 2 1 12,206 2,800 16 2 1 1 3,100 1,000 12,283
5 F17 61 61 8 2 1 12,206 2,800 16 2 1 1 3,100 1,000 12,283
6 F17 61 61 8 2 1 12,206 2,800 16 2 1 1 3,100 1,000 12,283
7 F17 61 61 8 2 1 12,206 2,800 16 2 1 1 3,100 1,000 12,283
8 F17 61 61 8 2 1 12,206 2,800 16 2 1 1 3,100 1,000 12,283
9 F17 61 61 8 2 1 12,206 2,800 16 2 1 1 3,100 1,000 12,283
11 F17 61 61 8 2 1 12,206 2,800 16 2 1 1 3,100 1,000 12,283
12 F17 61 61 8 2 1 12,206 2,800 16 2 1 1 3,100 1,000 12,283

1 F18 42 42 6 2 1 8,320 2,800 11 2 1 1 2,113 1,000 8,372
10 F18 42 42 6 2 1 8,320 2,800 11 2 1 1 2,113 1,000 8,372

2 F18 42 42 6 2 1 8,320 2,800 11 2 1 1 2,113 1,000 8,372
3 F18 42 42 6 2 1 8,320 2,800 11 2 1 1 2,113 1,000 8,372
4 F18 42 42 6 2 1 8,320 2,800 11 2 1 1 2,113 1,000 8,372
5 F18 42 42 6 2 1 8,320 2,800 11 2 1 1 2,113 1,000 8,372
6 F18 42 42 6 2 1 8,320 2,800 11 2 1 1 2,113 1,000 8,372
7 F18 42 42 6 2 1 8,320 2,800 11 2 1 1 2,113 1,000 8,372
8 F18 42 42 6 2 1 8,320 2,800 11 2 1 1 2,113 1,000 8,372
9 F18 42 42 6 2 1 8,320 2,800 11 2 1 1 2,113 1,000 8,372
11 F18 42 42 6 2 1 8,320 2,800 11 2 1 1 2,113 1,000 8,372
12 F18 42 42 6 2 1 8,320 2,800 11 2 1 1 2,113 1,000 8,372
10 F19 37 37 5 1 1 7,374 1,400 9 2 1 1 1,873 1,000 7,421

3 F19 37 37 5 1 1 7,374 1,400 9 2 1 1 1,873 1,000 7,421
4 F19 37 37 5 1 1 7,374 1,400 9 2 1 1 1,873 1,000 7,421
5 F19 37 37 5 1 1 7,374 1,400 9 2 1 1 1,873 1,000 7,421
6 F19 37 37 5 1 1 7,374 1,400 9 2 1 1 1,873 1,000 7,421
7 F19 37 37 5 1 1 7,374 1,400 9 2 1 1 1,873 1,000 7,421RunID Landfill_ID Acreage
2023 25f Hours

Per
Monitorin

g Occurance 25f Days

Per
Monitorin

g Occurance 25f Weeks

per monitorin

g Occurance 25f
Months

per monitorin

g Occurance 25f Labor per year (4

occurances

per year) 25f Equipmen

t Rental

per year (4

occurance s per year) 30m
Hours Per
Monitorin

g Occurance 30m Days
Per
Monitorin

g Occurance 30m
Weeks

per monitorin

g Occurance 30m
Months

per monitorin

g Occurance 30m Labor per year (4

occurances

per year) 30m Equipment Rental per

year (4

occurances

per year) SCAQMD: Surface Maintenance per year (4 occurances per year) 25-foot Traverse 30 meter traverse C-4. Detailed Landfill Costs of Quarterly SEM under Current 30- meter Pattern and the Tighter 25- foot traverse pattern

8 F19 37 37 5 1 1 7,374 1,400 9 2 1 1 1,873 1,000 7,421
9 F19 37 37 5 1 1 7,374 1,400 9 2 1 1 1,873 1,000 7,421
1 F20 84 84 11 3 1 16,620 4,200 21 3 1 1 4,221 1,500 16,725
10 F20 84 84 11 3 1 16,620 4,200 21 3 1 1 4,221 1,500 16,725

2 F20 84 84 11 3 1 16,620 4,200 21 3 1 1 4,221 1,500 16,725
3 F20 84 84 11 3 1 16,620 4,200 21 3 1 1 4,221 1,500 16,725
4 F20 84 84 11 3 1 16,620 4,200 21 3 1 1 4,221 1,500 16,725
5 F20 84 84 11 3 1 16,620 4,200 21 3 1 1 4,221 1,500 16,725
6 F20 84 84 11 3 1 16,620 4,200 21 3 1 1 4,221 1,500 16,725
7 F20 84 84 11 3 1 16,620 4,200 21 3 1 1 4,221 1,500 16,725
8 F20 84 84 11 3 1 16,620 4,200 21 3 1 1 4,221 1,500 16,725
9 F20 84 84 11 3 1 16,620 4,200 21 3 1 1 4,221 1,500 16,725
11 F20 84 84 11 3 1 16,620 4,200 21 3 1 1 4,221 1,500 16,725
12 F20 84 84 11 3 1 16,620 4,200 21 3 1 1 4,221 1,500 16,725

### 1

MEMORANDUM

TO: Hillary Ward, EPA

FROM: ERG

DATE: April 2014

SUBJECT: Estim ating Secondary Impacts of the Landfill s NSPS Re view

The EPA is reviewing the new source performance standards (NSPS) f or air emissions from municipal solid waste landfills (40 CFR part 60, subpart WWW ). This memo presents the assumptions and equations used to calculate the secondary impacts that would result from the proposed new subpart XXX in 40 CFR part 60.

The propos ed new subpart would affect the nation’s energy supply and is expected to generate a net increase in the nation’s energy supply . The combustion of landfill gas ( LFG ) also creates secon dary air impacts in the form of by

- product emissions, additional energy demand required to operate the control system, and avoided emissions from the national electrical grid as a result of new LFG energy supply.

The secondary impacts are computed for th e year 2023, which is 10 years after the NSPS is proposed

. This is consistent with the presentation of the cost s and emission impacts in the preamble

. The methodologies for estimating costs and emission reductions are presented in the c ost and emission impacts methodology memo randum 1

. The secondary impacts are computed on an incremental basis relative to the current NSPS requirements (baseline)

.

1. Distribution of Methane to Flares and Engines

The gas curve models (that were used to estimate costs and emission reductions) compute the total amount of methane destroyed

, as well as the total revenue generated from the sale of electricity to the grid

, by the current NSPS and the proposed 40 CFR part 60, subpart XXX . Usi ng these values, it is possible to back calculate the amount of methane destroyed by the engines vs. the flares. E quations 1, 2, and 3 are used to determine the annual electricity produced ( in megawatt hours per year or MWh/yr), the annual methane sent to engines (me tric ton s /yr ), and the annual m ethane sent to flares ( in cubic feet per
year or ft 3 /yr ) in 2023

. These amounts are then used to compute the secondary impacts using equations described in Sections 2 and 3 of this memorandum.

Equation 1: Quantity of Electricity Produced

Elec_Produced = Eng_Revenue ÷ Elec tricity _Price ÷ 1

, 000

Where: Elec_Produced = E lectricity produced (2023)

, MWh/yr Eng_Revenue = $/yr (computed using equations in the cost and emission impacts methodology memo randum )

1 E RG. 2014. Methodology for Estimating Cost and Emission Impacts of Proposed MSW Landfill Regulations.

### 2

Electricity_Price = Average electricity price, $0.06297 per kWh 1

, 000 = C onversion factor, k W per MW

Equation 2: Quantity of Methane Sent to Engines

CH 4 Engines = Elec_Produced × 11,100 × 1

, 000 ÷ 1

, 012 × 0.0423 ÷ 2

, 000 × 0.9072

Where:

CH 4 Engines = M ethane sent to engines ( 2023 ) , metric ton/yr Elec_Produced = E lectricity produced, MWh/yr, from Eq n. 1 11,100 = Engine heat rate, 11,100 Btu/kWh 1

, 000 = C onversion factor, k W per MW 1

, 012 = Heating value of methane, Btu/ ft 3 CH 4 0.0423 = D ensity of CH 4 , lb/ ft 3
2

, 000 = C onversion factor, lb/ton 0.9072 = C onversion factor, metric ton per short ton

Equation 3: Quantity of Methane Flared

CH 4 flared = (CH 4 Total - CH 4 Engines ) × 2

, 000 ÷ 0.9072 ÷ 0.0423

Where: CH 4 flared = M ethane sent to flares ( 2023 ) , ft 3 /yr CH 4 Total = M ethane destroyed, (2023), (computed using equations in cost and emission impacts methodology memo randum

, metric ton/yr ) CH 4 Engines = M ethane sent to engines, from Eq n. 2 2

, 000 = C onversion factor, lb/ton 0.9072 = C onversion factor, metric ton per short ton 0.0423 = D ensity of CH 4 , lb/ ft 3

2. Energy Impacts

As discussed in the cost and emission impacts methodology memorandum

, 2 the reg ulatory options analysis assumes that landfills with sufficient gas to support an LFG engine that are located in areas with favorable electricity prices will install LFG engines as a least cost control alternative.

The energy impacts of the proposed 40 CF R part 60, subpart XXX are two

- fold:

1. Energy demand to operate the blowers of the LFG collection system. This energy is expected to be purchased from the grid for landfills that do not have LFG electricity projects installed. For landfills with LFG engines installed, the engines are expected to provide this energy to the LFG collection system.

2. Energy supply from the LFG engines. Additional energy generated above what is required to operate the LFG collection system is expected to be sold to the local grid.

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

.

### 3

The net energy impacts can be estimated using the following equations:

Equation 4: Energy Demand

E_demand = CH 4 _flared × 0.002 × 2 ÷ 1

, 000

Where: E_demand = E nergy d emand ( 2023 ) , MWh CH 4 _flared = Quantity of methane flared in each option, ft 3 /yr, from Eqn

. 3 0.002 = Energy demand of LFG collection system , kWh /ft 3 LFG (see cost and

emission impacts methodology memo randum) 2 = M ultiplier, methane in LFG, assuming 50% methane 1,000 = C onversion factor kW/MW

Equation 5: Net Energy Impact

E_Impact = Elec_Produced

– E_demand

Where: Elec_Produced = E lectricity produced ( 2023 )

, MWh, from Eq n. 1 E_demand = E nergy demand 2023, MWh, from E q n

. 4

Table 1 summarizes the energy impacts of the proposed 40 CF R part 60, subpart XXX . The proposed subpart XXX is expected to generate a net increase in the nation’s energy supply. The energy revenue provided from new LFG engine energy supply was estimated as part of the cost analysis; as described in the cost and emission impacts methodology m emorandum

. 3 Applying an average national electricity price of $0.0629/kWh to the net energy impact, the energy supply is also summarized in Table 1 for the proposed subpart XXX

. Appendix A shows the detailed calculations of the energy impacts for all of th e regulatory options presented in the preamble

.

Table 1 Summary of Incremental Energy Impacts of Proposed Subpart XXX in 2023 A bove the Current NSPS

Option Incremental

Energy Demand (MWh) Incremental

Energy Supply (MWh) Incremental Net

Energy Impact (MWh) Incremental

Value of Net Energy Supply (2012$)
P roposed subpart to

r educe NMOC

t hreshold to 40 Mg/yr 

### 674 42,421 42,421 $ 2,671

3 . Secondary Air Impacts

In addition to the reduction of methane and NMOC emissions, th e proposed subpart ha s secondary air impacts, which are expected to incur in three main components :

3 ERG. 2014. Methodolo gy for Estimating Cost and Emission Impacts of Proposed MSW Landfill Regulations

.

### 4

1. By

- product emissions created from the combustion of LFG in flares or engines 2. Emissions created from purchasing energy from the grid to operate the blowers o n the LFG collection system. 3. Avoiding or offsetting emissions from grid electricity by supplying new energy from LFG engines.

By

- product Emissions from Flares or Engines

When LFG is controlled using engines or flare s , combustion by

- product emissions such as SO 2 and NOx are generated. In addition, trace amounts of LFG constituents, such as mercury (Hg) , can be emitted in the engine or flare exhaust gas. Equations 6 a and 6b and 7 a and 7b along with emission factors from Chapter 2 of EPA’s AP

- 42 4 were used to estimate the secondary air impacts resulting from the combustion of LFG.

Equation 6a: NOx Emissions f rom Flares

NOx flare = EFNOx flare × CH 4 _flared ÷ 2

, 000

Where: NOx flare = NOx emitted from flared LFG (2 023 ) , tpy EFNOx flare = NOx emission factor, 40lb/ 10 6 dscf methane , from AP

- 42 CH 4 _flared = Q uantity of methane flared ( 2023 ) , dscf/yr 2

, 000 = C onversion factor lb/ton

Equation 6b: NOx Emissions f rom Engines

NOx engine = EFNOx engine ÷ 1,012 × 11,100 × 1,000 × Elec_Produced ÷ 2

, 000

Where: NOx engine = NOx emitted from LFG engines ( 2023 ) , tpy EFNOx engines = NOx emission factor, 250 lb/ 10 6 dscf methane , from AP

- 42 1,012 = Methane heating value, Btu/scf 11,100 = Engine heat rate, Btu/kWh 1

, 000 = C onversion factor kW/MW Elec_Produced = E lectricity produced 2023, MWh, from Eq n 1 2

, 000 = C onversion factor lb/ton

SO 2 emissions from the flare and engines vary depending on the sulfur content of the LFG. This analysis assumes all sulfur compounds in LFG are converted to SO 2 during combustion and uses the AP

- 42 default sulfur content for raw LFG rather than using landfill

- specific data.

Equation 7a: SO 2 or Hg Emissions f rom Flares

Poll flare = Pconc LFG ÷ 10 6 × MW poll ÷ LFG std × 2 × CH4_flared ÷ 2000

Where: Poll flare = P ollutant emitted from flared LFG ( 2023 ) , tpy

4 USEPA. 1998. AP

- 42 Vol. I. Chapter 2.4. Municipal Solid Waste Landfills. Available on

- line at: http://www.epa.gov/ttn/chief/ap42/ch02/final/c02s04.pdf

.

### 5

Pconc LFG = Pollutant concentration of LFG 5 , ppmv MW Poll = Molecular weight of SO 2 (64.06) or Hg (200.61), lb/lb

- mol LFG std = LFG at standard conditions, 385.5 scf/lb

- mol 2 = M ultiplier, ratio of LFG to methane , assuming 50% methane CH 4 _flared = Q uantity of methane flared, ( 2023 ) , dscf/yr, from Eq n 3 2

, 000 = C onversion factor lb/ton

Equation 7 b: SO 2 or Hg Emissions f rom Engines

Poll eng = Pconc LFG ÷ 10 6 × MW poll ÷ LFG std *2 ÷ 1,012 × 1,000 × 11,100 × Elec_Produced ÷ 2

, 000

Where: Poll eng = P ollutant emitted from LFG engines ( 2023 ) , tpy Pconc LFG = Pollutant concentration of LFG 6
MW Poll = Molecular weight of SO 2 (64.06) or Hg (200.61), lb/lb

- mol LFG std = LFG at standard conditions, 385.5, scf/lb

- mol 2 = M ultiplier, ratio of LFG to CH 4 , assuming 50% methane 1,012 = Methane heating value, Btu/scf 1

, 000 = C onversion factor kW/MW 11,100 = Engine heat rate, 11,100, Btu/kWh Elec_Produced = E lectricity produced ( 2023 ) , MWh, from Eqn. 1 2

, 000 = C onversion factor lb/ton

Emissions from Purchased Electricity

In addition to the emissions resulting directly from the combustion of LFG, there are also emissions associated with the energy demand to operate the LFG control system. The energy demand is qu antified using Equation 2, and emission factors from EPA eGRID (9 th edition) 7 can be applied to estimate the emissions associated with this purchased electricity. While cap and trade mechanisms in place for SO 2 and NOx emissions in the electricity sector p revent quantifying emissions resulting from purchased electricity, the eGRID factors can be used to estimate the increase in CO 2 and Hg emissions from purchased electricity. However, eGRID data are unavailable to estimate the impacts on CO or PM from purch ased electricity.

The eGRID factors are presented as lb/MWh output and the data are available for an overall national average grid factor as well as an average of only fossil

- fuel based electricity. For this analysis, the overall national grid average fa ctors were chosen to estimate emissions because on average the purchased electricity would reflect the overall national average and not just electricity from fossil sources. The grid factors used in this analysis are documented in Table 2. The most recent version of eGRID data do es not include a factor for mercury

, so the 2007 eGRID data set was used to estimate mercury emissions.

Equation 8 : CO 2 or Hg Emissions from Grid Purchased Electricity

Poll grid = 0.002 × CH 4 _flared × 2 × EF grid ÷ 2

, 000 ÷ 1

, 000

Where:

5 Sulfur concentrati on is 46.9 ppmv, from AP

- 42 page 2.4

- 8 ; Hg concentration is 2.92E

- 04 ppmv from Table 2.4

- 1.

6 Sulfur concentration is 46.9 ppmv, from AP

- 42 page 2.4

- 8 ; Hg concentration is 2.92E

- 04 ppmv from Table 2.4

- 1.

7 USEPA. eGRID 9th Edition (2010 data). February 24, 2014. http://www.epa.gov/cleanenergy/energy

resources/egrid/index.html

.

### 6

Poll grid = P ollutant emitted from grid purchased electricity in 2023 , tpy EF grid = E mission factor from grid purchased electricity, lb/MWh from Table 2 0.002 = E lectricity consumption by LFG collection blowers, kWh/ft 3 LFG CH4_flared = Q uantity of CH 4 flared ( 2023 ) , dscf/yr, from Eq n. 3 2 = M ultiplier, ratio of LFG to CH 4 , assuming 50% methane 1

, 000 = C onversion factor kWh/MWh 2

, 000 = C onversion factor lb/ton

Table 2

. eGRID Emission Factors Used in Impacts Analysis

Pollutant Factor (lb/MWh) Source Hg 27.2 eGRID2007 V1.1, national average, all sources CO 2 1216.18 eGRID 9 th Edition (2010 Data) V1.0, national average, all

sources

Avoided Emissions from Excess Energy Supply

The third component affecting overall secondary air impacts are the emissions avoided as a result of increased LFG energy production expected to occur as a result of the new subpart

. LFG electricity sold to the grid is expected to offset the demand of pu rchased electricity from the national grid. The eGRID factors from Table 2 were used with Equation 9 to estimate the avoided air impacts.

Equation 9 : Avoided CO 2 and Hg Emissions from LFG Energy Supply

Poll avoided = Elec_Produced × EF grid ÷ 2

, 000

Where: Poll avoided = P ollutant avoided from grid electricity ( 2023 ) , tpy EF grid = E mission factor from avoided grid electricity, lb/MWh from Table 2 Elec_Produced = Average a nnual e lectricity p roduced ( 2023 ) , MWh, from Eqn. 1 2

, 000 = C onversion factor lb/ton

Net Emissions Impact

Considering the three sources of emissions impacts from the proposed subpart , a net impact on emissions can be computed according to Equation 10 for each pollutant that was estimated using Equations 6 through 9 above.

Equati on 10 : Net Secondary Emissions Impact

Net Emissions = Poll eng + Poll flare + Poll grid - Poll avoided

Where: Net Emissions = N et emissions ( 2023 ) , tpy Poll eng = P ollutant emitted from LFG engines ( 2023 ) , tpy Poll flare = P ollutant emitted from flared LFG ( 2023 ) , tpy Poll grid = P ollutant emitted from grid purchased electricity ( 2023 ) , tpy Poll avoided = P ollutant avoided from grid electricity ( 2023 ) , tpy

### 7

Table 3 summarizes the secondary air impact s of the proposed subpart compared to the current NSPS

r equirements

. The CO 2 emission reductions presented in this table are in addition to the CO 2 e emission reductions achieved from the direct destruction of methane in flares or engines. Appendix B shows the detailed calculations of the secondary air impacts for all of the regulatory options considered

.

Table 3

. Summary of Incremental Secondary Air Impacts for Propos ed Subpart XXX in 2023

Pollutant Emissions Created

(LFG Flares and Engines) (tpy) Emissions Avoided (tpy) Net Emis sions (tpy) SO 2 

### 5 Cannot compute Cannot compute Hg 

### 9 586

- 577
NOx 

### 62 Cannot compute Cannot compute
CO 2 

### 4 15 26,554

- 26,139*** Draft

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SUMMARY OF SMALL ENTITY OUTREACH. 2014

The EPA h el d meetings with municipal solid waste landfill small entity representatives. A summary of the outreach conducted and written comments received appears below.

The EPA met with small entity representatives on October 30, 2013. The meeting was conducted as follows.

10:00 Welcome and Introductions ( EPA )

10:15 RFA/SBREFA Overview ( EPA )

10:30 Background Presentation ( EPA )

11:15 Discussion (All)

11:50 Summary and Closing ( EPA )*** Draft

– Do Not Cite, Quote, or Release During Review ***

Summary of Written Comments from Potential Small Entity Representatives Submitted after the October 30, 2013 Outreach Meeting

Topic Comment
Emission threshold  Lower threshold could cause site to incur significant cost

 May impact existing beneficial use projects that have benefitted from being located at sites that are non

- NSPS and therefore eligible for additional revenues

 Most smaller landfills do not generate sufficient gas for LFGTE projects
Treatment definition  Retain non

- numeric definition

 A LFGTE project will treat the gas to meet the requirement of the proposed equipment in order to comply with the manufacturer’s warranty

 Numeric criteria would potentially require a modification/redesign of the existing equipment

 Have to install continuous monitoring equipment to demonstrate these criteria are met during operation

 Gas treatment system is not an emission point, but a physical process where LFG is prepared for combust ion in LFG fired generator sets

 Requirements for RICE MACT and spark ignition engines ensure appropriate emission reductions

 Increases burden with no measurable improvement in emissions

Surface monitoring  Retain EPA method 21

 Does not appear to have a quantifiable environmental benefit

 SEM is time consuming

 Rules already require additional monitoring be performed at cracks in the cover or in areas where vegetation is stressed

 Understand limitations on monitoring during high winds and precipitation, but that should be coupled site

- specific alternatives

 SEM pattern should remain unchanged. Do not include integrated and instantaneous measurements. All increase compliance burden.*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comment

 Is EPA considering changing the instantaneous compliance threshold of
500 ppm methane above background

 What thresholds are being considered for integrated measurements
Wellhead standards  Remove wellhead performance standards

 Eliminate or relax requirements for temperature and oxygen

Emission reductions  Share specific targets/goals for reductions and cost thresholds Wellfield expansion  More well extensions and redrilling adds significant cost

 Tighter timeline compromises ability to meet wellhead requirements

 Prescriptive corrective action requirement is unnecessary

 Reduction of time allowed for expansion of the wellfield, particularly in active areas, could result in operational difficulties

 It may be difficult to place a sufficient column of waste over a shorter time period in the affected areas for installation of gas extraction wells

 During the first 2 years of waste placement, portions of the waste are likely to be in the aerobic phase of LFG production

 Complying with NSPS operational standards may be difficult (specifically oxygen or balance gas limitations)

 Gas collection from low producing areas will also cause a reduction in gas quality, which will directly affect the ability to beneficially use LFG and creates more potential for subsurface fires*** Draft

– Do Not Cite, Quote, or Release During Review ***

The EPA met with small entity representatives on December 19 , 2013. The meeting was conducted as follows.

10:00 Welcome and Introductions

 Panel member introductions/remarks

 SER introductions

10:15 SER Presentations

10:45 Open Discussion (SERs and EPA)

This is an opportunity for SERs to provid e comments to EPA on the following:

 Clarifications that are needed in the landfill rules

 Options and ideas that EPA should consider beyond those that were presented at the October 30, 2013 Pre

- Panel Meeting

 Monitoring and recordkeeping: reactions to curr ent requirements and recommendations

 Technological advances that should be considered

 Availability of new models

 Additional issues

11:50 Summary and Closing (EPA)*** Draft

– Do Not Cite, Quote, or Release During Review ***

Summary of Written Comments from Small Entity Representatives S ubmitted after the December 19, 2013 Outreach Meeting

Topic Comments
Treatment Definition  Leave the definition as is. Facility meets definition as provided in EPA guidance documents (compressed, chilled, dehydrated)

 Existing equipment would potentially have to be redesigned or modified to meet numeric criteria

 Installing, maintaining, and operating continuous monitoring equipment to demonstrate ability to meet treatment criteria would increase compliance burden on landfills

 RICE MACT and NSPS for spark ignition engines already ensures appropriate emission reductions

 Specifying numeric criteria will not affect the resulting emissions engines, nor will it decrease NMOC

 Increases burden with no measurable improvement in emissions

 1996 NSPS rule does not include a definition of treatment system. EPA proposed the following definition in the May 23, 2002 proposed amendments to the original 1996 rule: Treatment system means a system that filters, de

- waters and compresses landfill gas (67 FR 36480). EPA shoul d adopt this definition.

 In 2006 EPA proposed “treatment” standards to include operating limits and monitoring. We believe that proposal is inappropriate and unnecessary because:

- Treatment systems are not control devices,

- EPA’s proposal would not provide the operator of the treatment system with any information that would enable a reduction in emissions because neither the filtration, compression, nor the dewatering process produce emissions that could be reduced

- Regulati ng the operating limits and monitoring will inhibit the development of LFGTE at small entity facilities which are already challenged with numerous technical and financial barriers due to their small LFG flow. Adding more unnecessary regulatory and financia l burden to these projects is inappropriate.*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comments

 2006 proposal does not account for the site

- specific characteristics that may impact operating requirements for each LFG treatment system and control device

- Site

- specific preventative maintenance plan and a S tart

up, Shutdown and Malfunction Plan are sufficient and prescriptive standards not warranted

- Regulating the treatment of LFG is simply not necessary to ensure that LFG is properly combusted

 Any landfill gas that is collected and used for beneficial use should be allowed without prescriptive requirement. The LFGTE project will treat gas to the needed conditions to be used by the proposed equipment

 Placing requirements on the treatment process will only create a disincentive to do a LFGTE project

 The LF GTE project, not the treatment process, creates the real environmental benefit. As such, the treatment definition should not be changed Wellhead requirements  Remove wellhead performance standards

 Requirements result in an overly burdensome compliance exercise that does not result in NMOC reductions

 For wells installed in non

- producing areas, complying with the wellhead standards can be difficult

 Waste naturally degrades at varying temperatures, some of which occurs above the NSPS wellhead standard

 Landfill has several wells that naturally operate above 55°C (131°F) with no indication of fire in the vicinity of the well

 Should be the responsibility of the landfill/gas system owner/operator to ensure the system is

 operated to prevent a fire and not a requirement of NSPS

 Support the removal of the wellhead performance standards from NSPS and the continued use of SEM to directly measure emissions and demonstrate compliance*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comments

 Regulated community views the wellhead performance standards as overly prescriptive with extremely complex recordkeeping and reporting requirements and associated corrective actions that vary widely due to divergent agency interpretations

 Amount of data tracking and paperwork to demonstrate conformance with wellhead standard s is very burdensome and can delay or distract the regulated community and state agencies from accomplishing overarching goals of the NSPS

 Prescriptive wellhead standards are an obstacle to proper system operation and emission reductions

 State agencies d o not have resources to assess and respond to landfill operator requests for operating variances, and due to staff turnover, often lack knowledge and expertise

 Difficult to obtain higher operating variances and alternative timelines from agencies, so oper ators adjust LFG flow to the wells to meet specified temperature and oxygen values. This lowers the efficiency of the system and can result in less gas being extracted to fuel energy recovery projects or flares

 Unnecessary system expansions must be perfor med at great expense with no environmental benefit

 Expanding the collection system would further propagate a fire by introducing more oxygen into the landfill through drilling or
excavation activities

 Recommend the standards for oxygen and temperature be eliminated

 E xisting wellhead standards are not the best indicator of GCCS performance because they are arbitrary limits on a limited number of parameters which do not accurately represent proper GCCS performance

 Existing wellhead operating standards do not reduce NMOC
emissions

 Landfill owners are already heavily incentivized to maximize GCCS collection efficiency to control odor, control subsurface migration, minimize groundwater impacts, maintain cap stability*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comments and integrity, control surface emissions, and maximize energy

recovery

 Of the current wellhead operating standards, only pressure is indirectly tied to controlling emissions

 Do not believe that the wellhead pressure standard provides additional environmental protection

 Considering that the landfill cover soils have emission retention qualities even gas pressure under the cap is not an indicator of
emissions

 Wellhead standards do not measure emissions

 Let the landfill owners operate their well field consistent with their GCCS Design Plan su ch that surface emissions are maintained below the standard

 Creating prescriptive treatment system standards along with monitoring and recordkeeping requirements will add significant barriers to energy recovery and fuel conversion projects and could squas h further development

 Very prescriptive standards are not warranted and create a very complex and onerous set of monitoring and remediation standards

 Standards are not needed and requirement to expand GCCS will result in making operation of the GCCS wors e and not better

 Unnecessary expansions are costly; typical cost to install one well range from $12,000

- $15,000 which does not include drill crew mobilization charges

 Current wellhead performance standards actually impede and/or hinder a site from being able to maximize LFG collection

 If a site can meet SEM requirements, EPA should not dictate what individual parameters need to be met at each wellhead for pressure, oxygen, and temperature. Monitoring and remediation of these parameters is a significant c ost and creates an undue level of complexity in data tracking and regulatory correspondence that has no direct impact on reducing surface
emissions*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comments Surface monitoring  Direct measurement of surface emissions is a better means to assess the effectiveness of a gas system. This is similar to the sentiment indicated by EPA in the background information document (BID) for the final NSPS standards (EPA

- 453/R

- 94

- 021). The BID states “EPA considers surface emissions monitoring to be an appropriate tool for monito ring both cover integrity and the effectiveness of well spacing and vacuum in order to ensure adequate collection efficiency” .

 C urrent SEM requirements are appropriate and there does not appear to be data to indicate the current SEM procedures are inadeq uate

 Inclusion of enhanced SEM monitoring in a proposed rule change would be an increased compliance burden on the landfill

 Does not appear to be data to indicate that expanded SEM would result in a direct reduction in NMOC emissions

 Unless data can be provided to demonstrate enhanced SEM is better and will reduce NMOC emissions, there does not appear to be a valid reason to change the current SEM requirements

 Primary focus of the rule should be to control emissions which can be successfully accomplishe d utilizing the existing SEM, which can evaluate the effectiveness of active and passive gas collection systems and cover

 Focus of rule should be on controlling emissions. Can be accomplished using the existing surface emissions monitoring, which can evaluate effectiveness of active and passive gas collection systems and cover

 Does not appear that there is adequate quantifiable environmental benefit that can be determined from increasing spacing on monitoring

 Rules already require that additional mon itoring be performed at cracks in the cover or in areas where vegetation is stressed

 Current requirement adequately locates surface emissions through the cover

 SEM is a time

- consuming compliance activity*** Draft

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Topic Comments

 Tighter grid spacing requirement should be based on some demonstrable environmental benefit

- enhanced SEM nationwide, would be burdensome for small facilities (significant increase in cost, new equipment, and training of personnel)

 Current SEM method with NSPS is a very reliable method for determining i f a site is actually excess surface emissions and does not rely on theoretical models

 Recommend NSPS be revised to include SEM as an additional step in determining whether or not a GCCS needs to be installed at a landfill. Additional step of adding SEM ap plicability criteria would eliminate uncertainty associated with modeling and use actual site specific conditions to determine the need for a GCCS. If a site can show compliance with surface emission standards without the benefit of GCCS; then it should no t be required by NSPS to install one

 There may be other possible methods, but there does not appear to be any quantifiable results that suggest current requirements are not adequate or that another method would result in something better

 Adoption of a me thod only used in one part of the country does not seem to be an appropriate reason to make a global change to SEM, unless it was part of other proposed changes in the rule that would be related to a more stringent SEM requirement (e.g. removal of wellhead standards) Methodology  EPA’s [1996 final rule] analysis noted the selected size threshold exempted 90% of existing landfills, while missing only 15% of total NMOC emission potential. Total emissions potential should be much lower today given many of the small sites are closed landfills
General  EPA GHG inventory indicates over 11% decline in methane emissions from landfills since 1990

 No need to modify the rule for additional emission reductions

 Landfills have demonstrated that cover soils will oxidize organic compounds

 With increased permitting requirements associated with greenhouse gas permitting under the Tailoring Rule, it could*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comments take over a year to get an air permit to install a control device or longer if biogenic emissions are not exempt
Cost  Emission reductions to date have been at a reasonable cost

 Additional emission reductions can only be achieved through very high costs

 Cost burden for installing a landfill gas system is significantly greater for a small facility than a large one (e.g. s ignificant cost to incurred to simply mobilize a drill rig)

 Mobilization costs can be distributed over the cost of the wells for a facility that installs many wells

 Individual well cost higher for smaller facilities with fewer wells

 Cost will be high fo r smaller landfills (e.g. design, permitting and construction, monitoring and operations

 Request no changes to the NSPS thresholds because there does not appear to be enough justification for lowering emissions. GCCS impose a substantial cost to landfills and there is a desire not to increase disposal rates to its citizens

 Requiring systems and components to be installed earlier will greatly increase cost of operating and maintaining the system

 Placing GCCS components within the active working areas of t he landfill is already an issue but requiring them to be installed even earlier will result in more well extensions and redrilling, which adds significant cost
Emission threshold  Consider allowing use of surface emissions monitoring to confirm whether modeled excess emissions actually exist

 Adding a SEM applicability criterion to the NMOC threshold criteria will assure gas systems are installed and/or expanded at the appropriate time to maximize emissions reductions

- would require many additional landf ills to comply and the cost to comply versus the emission reductions would be unreasonable at approximately $14,000 / metric ton
NMOC reduction

 Lowering the emission threshold could require site to install and operate landfill gas collection and control s ystem in the next couple of years at a significant cost. Initial GCCS costs about*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comments $2million. Monitoring, recordkeeping, and reporting costs under the current NSPS are estimated to be $50,000/year.

 Proposed lowering of emission threshold is based on model ed emissions of NMOC and not actual emissions, including model variables that are not site

- specific

 Does not seem to be any technical or scientific justification for a downward adjustment to the emission s threshold

 Any downward adjustment would have a s ignificant impact on the operations and costs from smaller landfill owners

 No new technology has been developed since the implementation of the current NSPS that would warrant or justify changing the current emission threshold

 Current emission threshold appropriately identifies those landfills that may need to have controls installed

 Current emissions threshold (based on modeling) coupled with actual SEM data, would be recommended before a GCCS is required to be installed
Installation timeframe  Ability for regulated community to comply with shortened installation timeframe is jeopardized

 Compressed schedule is a burden on construction and operation
activities

 Requires installing LFG collection system during active operations which subjects collection s ystem to damage from operations

 Increased sediments in the landfill affects landfill gas header alignment. Results in more operational troubleshooting, repairs, and replacement costs

 E arlier operation will lead to significantly greater numbers of [ well] exceedances requiring greater number of system expansions which adds to the cost burden of earlier collection

- Considering the rules of procurement for municipalities it will be difficult to reduce this time

- Approval period has been very long in most Stat es and some States have never approved a submitted design,*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comments making it very cumbersome for the landfill owner to go to bid for construction

- Shortening the time allotted for installation of the GCCS would create added burden on small entities and should

not be pursued

 Shortening of time would be burdensome, if not impossible

 Process of getting designs, permits, city council approvals, plus the time needed for advertisement, bidding, and construction, would be difficult under the current timeframes.

 Given the time needed to properly design, permit, bid, and construct a project, the shortening of timeframes for any site, especially a municipality, would create hardship

 Having to install components at a site early will greatly increase the cost of operating and maintaining the system and the need to have those components replaced in the future Owner/operator issues  Common control establishes a disincentive for landfill gas to energy projects

 Being held responsible for actions or inactions of an independent contractor is untenable

 Permits should allow clear division of responsibilities between landfill owner and the owner of the LFGTE facility

 Does not want to be held responsible for actions and/or the equipment of independent 3 rd party entities

 If responsible for actions of independent 3 rd parties through rule revisions, likelihood of pursuing a landfill gas to energy project is very low

 Not willing to allow equipment not owned and personnel not controlled to potentially put city in a noncompliance situation

 Change in rules would hurt the potential for a LFGTE project, which could otherwise be very viable, create jobs, and reduce
emissions

 Support allowing a division of liabilities to be established between parties which could be provided to the r egulating entity*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comments
Closed landfills  Additional relief from performance and monitoring should be granted to closed landfills (e.g. landfill may not have sufficient LFG to maintain and operate a LFG collection system for 15 years, meet the 5% oxygen wellhead standard, and perform system expansion)

 Much of the LFG emissions might have oxidized through cover soils resulting in minimal pollution

 Consideration should be available for oxidation of the LFG

Decommissioning Wells  Rule should be revised to allow for decommissioning of portions of the LFG system

 Make provisions for both temporary and permanent decommissioning based on site specific conditions Landfill lifecycle  Rule does not adequately address the lifecycle of a landfill, including phasing

- in gas collection systems for newer landfills or newly developed areas of landfills, or tapering down collection systems for older landfills where gas production is diminished

 Compliance with wellhead performance standards is difficult at the beginning or end o f the landfill’s life

 Sites need operational flexibility to rely on interim collection in the early generation years and intermittent system operations in the low gas producing years

 Rule does not address ramping up the gas collection and control system (GCCS) for new landfills or tapering down the GCCS for old landfills Cost analysis  Cost shown in spreadsheet seem low, especially considering that the facilities that would be impacted are significantly smaller and would not enjoy the same economies of sc ale

 Cost assumptions assumed many of the facilities would benefit from beneficial use and that rationale does not seem to consider the size of the facilities

 Closed landfills are unlikely to provide gas for a period long enough to see a return on investm ent

 Many smaller landfills do not generate sufficient gas to enjoy the opportunity to install beneficial use options.*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comments

 Cost benefits to small facilities are minimal

 Small landfill adjacent to an industrial user may see benefits but this situation is rare

 Cost will be significantly larger than EPA estimates

 Cost benefit would need to be clearly defined before suggesting changes that would increase or expand the scope of SEM

 EPA’s [final rule] cost benefit analysis ($/ton NMOC reduced) that supporte d the 2.5 million Mg and 2.5 million cubic meter design capacity remain relevant today

- EPA’s [final rule] cost benefit analysis ($/ton NMOC reduced) that supported the 50 Mg/yr threshold remains relevant today

- Options that propose early installation of wells needs to include costs for additional repairs and needed replacements. Vertical well installed in an area that will receive additional waste will need to be extended and eventually replaced

 Extension and replacement costs will greatly increase for o ptions that require earlier installations. As a general rule, each 5ft well extension costs about $400 , and once a well has been extended 4 times (20 ft), the well will need to be replaces

 Horizontal collectors will fail sooner and require replacement
si nce more lifts of refuse will be placed over them after installation

 Cost for bringing needed power service to the site need to be included in cost calculations (for options that lower the applicability threshold and require new sites to install a GCCS)

 Cost of electrical service (to provide sufficient power to run blowers) is site specific, but recent experience shows costs can be as high as $500K

 Benefit of a LFGTE project is very site specific. Changes in energy markets, tax laws, and regulations me an some LFGTE projects make little to no money*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comments

 In many cases it is currently more economical to flare gas than to install and operate a LFGTE project (as such it would seem appropriate to apply a reduction in compliance costs)

 Assumption that a site could have a LFGTE project and that it could generate enough revenue to offset compliance costs cannot be applied across all sites

 As a small entity, the economies of scale may not allow the costs to be viable, but the cost of compliance would still be in curred

 Some of the NSPS options would increase costs and thus reduce the viability of being able to do a LFGTE project at smaller sites
Size threshold  Lowering NSPS thresholds may also impact beneficial use projects that have benefitted from being located at sites that are

non

- NSPS and therefore eligible for additional revenues

- lowering threshold would require many additional landfills to comply and the cost to comply versus the emission reductions would be unreasonable at approximately $18,000 / m etric ton NMOC reduction

 Landfills with a design capacity of less than 2.5 million Mg and 2.5 million cubic meters is very small by today’s standards and most likely would not be able to support the additional burden placed on it by more stringent NSPS requirements

 Smaller landfills have less gas generation, less opportunity for

gas

- to

- energy projects, and fewer emissions

 No new technology has been developed that would warrant or justify a change in the size threshold

 Current size threshold appropria tely identifies those landfills that need to be further evaluated for potential controls
Fires  If minimizing the risk of a fire is truly the concern for the EPA, the requirement for system expansion in many circumstances would further propagate the fire b y introducing more oxygen into the system through drilling or excavation activities.

 If EPA remains concerned about potential fire risks, it is recommended that the facility include prevention and mitigation practices in the GCCS Design Plan, sealed by a professional engineer*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comments

 40 CFR 258.21 already requires controls to reduce landfill fires namely: “Cover material requirements

Failed tier 2 test option  If an owner fails a tier II test (i.e.: the calculated NMOC emissions are greater than 50Mg/year) then they must conduct tier III testing or install/operate an active LFG collection system; recommend another option be allowed, namely, an SEM demonstration

 SEM demonstration would be performed using current NSPS procedures and if methane emissions were foun d or repaired to be lower than 500 ppm below background, then installation of a GCCS could be delayed

 Believe numerous GCCS have been installed and operated at great expense that are not justified because they reduce very few emissions that a good soil co ver could achieve at much lower capital and operating costs
Passive flares  Use of passive flare devices may allow reductions of NMOCs in remote areas such as landfill cleanouts to the leachate collection system and low methane producing areas

 Under curre nt NSPS rules this installation is not possible because the NSPS requires open flares to meet 60.18 and have continuous flow recorders and flare pilot flame monitoring

 Equipment is not cost effectively available at remote locations such as the leachate cleanout devices

 If EPA wants to promote destruction of more NMOCs then EPA will need to waive the requirements for flow measurement and pilot flame monitor in remote areas and low methane producing

areas Wellfield expansion  Waste is typically not to fin al grade for at least 7 years at most landfills so the 2 year rule is rarely applicable at today’s modern landfill

 Most landfill owners / LFG operators in wet climates are installing temporary LFG collectors before the 5 year rule is invoked, partially in an effort to comply with NSPS/EG but also partially to maintain control of odors or to capture energy

 Early installation is not typically occurring in dry climates*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comments

 Early GCCS installations almost never comply with the wellhead standards but they don’t h ave to comply until the 5 year clock is triggered

 Since landfill owners / LFG operators in wet climates already typically install the GCCS before 5 years if the EPA changes the rule to less than 5 years it would result in no less emission reductions than the current rule already provides

 Lowering the 5 year rule would create more administrative burden for LFG collectors that can’t meet the existing NSPS/EG wellhead standards, would not lower emissions, and would create undue expense on the landfill owners / LFG operators

 Do not recommend any change to the 2yr/5yr rule

 Gas system expansion every couple of years would cost approximately $250,000 for each event. Additional costs would be incurred to operate associated blowers. Cost would likely lead to an i ncrease in disposal rates for citizens served by the landfill

 Shortening of time would be burdensome if not impossible New technology  Landfill industry has not developed new control technologies since the original implementation of NSPS

 Best demonstrate d technology remains flares

 Barriers identified in the 1996 rulemaking to control technologies other than flaring still exist today

 Important that any rule revisions seek to remove and not add barriers to technologies such as energy recovery and fuel
conversion

 Industry has made improvements to wellhead and collector designs, and improved data collection and tracking. Because the NSPS/EG rule is so prescriptive, it is difficult to develop new technology Emissions modeling  Landfill industry is beginni ng to invest in research that will ultimately improve our ability to predict LFG generation and collection rates more accurately

 Widely thought that the methane generation rate (k) varies over time, lowering when the landfill cap is installed and stormwat er is cutoff*** Draft

– Do Not Cite, Quote, or Release During Review ***

Topic Comments

 Widely thought in our industry that NMOC, VOC, Siloxane, H2S, and other compounds typically found in landfill gas have varying emission factors over time, lowering as waste decomposition

progresses

 More funding is needed to advance the state of practice in this regard and better understand what the “real” emissions from landfills are

 Solid waste industry is working hard to develop more accurate methods to estimate actual emissions; but there is not currently a sufficiently accurate method to determine actual emissions for compliance purposes

 LandGEM overestimates emissions

 Current gas generation model can overestimate emissions by up
to 400%

 Recommend EPA incorporate methane oxidation into emission calculation methodology for estimating landfill emissions 15 yr GCCS requirement  Recommend changes to address how a site/ area is able to remove or be excluded from GCCS operations

 Recommend criteria be included in the rule to allow a site to cease NSPS operation and control requirements base d on NMOC emissions and/or SEM compliance (regardless of how long the GCCS has been online)

 For example, a site that can demonstrate that it does not have surface emission exceedances and/or is below 50 Mg/yr threshold of NMOCs should be allowed to cease GCCS operations under the NSPS requirements
1% exclusion  Landfills should be able to decommission collection in non

producing areas based on SEM results and not modeling

 If a percentage of NMOC s continues to be used in the rule, the percentage should be increased from 1%, which has shown to be an unattainable standard for almost all sites

### 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 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 ) 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

. The se 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 consi dered for proposal. 1

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 2023 , the landfill was considered to be a controlled landfill, and it would incur the testing and monitoring costs associated with being control led. 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 Requir e ment 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 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 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 201 2

. The wag e 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 3 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.

This 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

3 US Bureau of Labor and Statistics. May 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 plac e, 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 * $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 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 Metho d 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 gathe ring the samples and reporting the results. We used the 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

. 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 + $1,0 19 )*{0.07(1 + 0.07)^5} / {[(1 + 0.07)^5]

- 1} = $2,700



### 3. Costs for C ontrolled Landfills

3.1 Initial Performance Testing

The current NSPS and EG rule s 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 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 t he 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 and EG 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 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 and EG control costs) base s its enclosed flare and engine costs o n 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 and EG usin g 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 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 and EG 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 surf ace 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 deter mining the controlled acreage of eac h landfill, as discussed below, and multiplying 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 2009 South Coast Air Quality Management District (SCAQMD) l andfill 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)

trav erse 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 ana lyzer, 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 hou rs 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 the number of hours to complete each monitoring occur re nce was greater than 3 weeks. These rental costs

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/

### 5

were then multiplied by four occur re nces per year to estimate an annual equipment rental cost for the quarterly monitoring requirements.

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 Modeling Database Containing Inputs and Results of Proposed Revisions to MSW Landfill NSPS 11 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 fract ion 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 mon itoring 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 ass ociated 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 sampl e 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 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 and E G 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 tighter 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 SCAQMD Landfill rule

. 13



### 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. 14

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 Landfill s NSPS Review.

### 6

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

Affected Landfill a Annualized

Initial Performance Test ($) Continuous

Combustor Monitoring Monthly

W ellhead M onitoring 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 $6 80 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 $ 19 8

. 76 $ 20 0 NA

Controlled (> 24 acres up to 120 acres) $1,105 Already included b Already

included b $ 350/week $ 19 8

. 76 $ 20 0 NA

Controlled (> 120 acres) $1,105 Already included b Already

included b $ 1100/month $ 19 8

. 76 $ 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.

b Already included in the control cost estimates. See the memo: ERG. 2014

. Methodology for Estimatin g Cost and Emission Impacts for MSW Landf ill s Regulat ions

.
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 si tes 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.