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 documents 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 Memo 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.pdf
From: 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 Group

(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.xlsx
From: 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,

Per 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.pdf













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: Summary of Landfill Dataset Used in the Cost and Emission Impacts Analysis of 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. (40 CFR part 60, subpart WWW and 40 CFR part 60, subpart Cc, respectively). 

Currently, the NSPS regulation requires 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 estimated 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, the NSPS/EG 

dataset contains landfill-specific information including:

 Landfill identification (ID) number

 Waste-in-place year

 Annual waste acceptance year

 Landfill closure year 

 Year landfill opened

 Landfill design capacity (in tons)

 Landfill design area (in acres)

 Landfill depth (in feet). 

The purpose of this memorandum is to summarize the source data and assumptions used to create

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 

Impacts of MSW Landfill Regulations. 

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

Landfill data were obtained from three sources: a landfill and LFG energy project database 

maintained by EPA’s Landfill 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

The LMOP database does not represent the entire universe of landfills in the United States; the 

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. In some cases, the 

amount of information about a particular landfill was very limited. For example, if the only publically 

available information for a landfill was 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 sources) showed

duplicate landfills, 2012 LMOP data were used over voluntary survey data because the LMOP data were 

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 installed 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. Landfill 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 were reporting year 2010 (which were 

made available in late 2011). Data are updated annually to the GHGRP and data from reporting year 2012 

were recently released in late October 2013. Reporting year 2012 data include new inputs to GHG 

equations that were previously deferred 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 database, the voluntary survey dataset, 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 are 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 closure 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, data reported 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 (2011-2018). Based on existing 

landfills, 37 model landfills were created to represent landfills opening in years 2012 to 2018. Of these 

landfills, 21 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 an “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 the landfills were combined, there would be fewer future landfills.

Because the dataset did not contain complete data for many landfills, methods were developed to

estimate the following parameters:

 Waste-in-place year 

 Annual waste acceptance year 

 Landfill closure year 

 Year landfill opened 

 Landfill design capacity 

 Landfill design area 
4

 Landfill depth. 

When there are multiple estimation methods for one of the parameters, the methods were 

followed sequentially as described below. Therefore, parameters were estimated using later methods only 

if the parameters were not estimated using an earlier method.

2.1 Waste-in-place Year 

If waste-in-place year was missing and the landfill is closed, it was assumed that the reported 

waste-in-place year represented the year that the landfill closed. Therefore, the waste-in-place year was 

set as equal to the landfill closure year.

2.2 Annual Waste Acceptance Year 

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. Therefore, the 

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

2.3 Landfill Closure Year

For the first estimation method, the landfill closure year was calculated based on waste-in-place, 

waste-in-place year, landfill design capacity, and annual waste acceptance rate. The 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 estimation method, 

a second estimation method was followed. The closure year was calculated based on the year the landfill 

opened, landfill design capacity, and annual waste acceptance rate. The number of years required to fill 

the landfill to capacity 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. Following this methodology for landfills that were reported as closed, the calculated 

closure year should be prior to 2020, because the landfill was reported to be closed; thus, any calculated 

closure years after 2019 were not included in the NSPS/EG dataset. For landfills that were reported to be

open, the 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, wastein-place year, landfill design capacity, and a calculated waste acceptance rate. The 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 subtracting the year the landfill opened from the 

waste-in-place year). The amount of waste to be added was calculated by subtracting the waste-in-place 

from the landfill design capacity. This value was divided by the calculated annual waste acceptance rate 

to estimate the number of years to reach capacity. The number of years to reach capacity was then added 

to the waste-in-place year to estimate the landfill closure year. 

If the landfill 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 were 1998. ERG calculated the annual waste acceptance rate by dividing the amount of wastein-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. This 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 was added to 1998

to estimate the landfill closure year. 

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. The 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, if annual waste acceptance rate, annual waste acceptance year, 

and waste-in-place were available, these parameters were used to estimate the year the landfill opened. 

The 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 this value did not exceed 100 years, it was subtracted from the 

annual waste acceptance year to estimate the year the landfill opened.

Finally, the year the landfill opened was calculated based on the closure year, landfill design 

capacity, and annual waste acceptance rate. The 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 Design Capacity (tons)

First, if 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 was set equal to the amount of waste-inplace.

If the landfill design capacity was available in cubic yards, it was converted to tons using an 

assumed waste density of 0.6 tons per cubic yard.

Next, if 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 had

accepted this amount of waste (which was determined by subtracting year the landfill opened from wastein-place year). The calculated waste acceptance rate was multiplied by the number of years until the 

landfill closes (which was calculated by subtracting the waste-in-place year from landfill closure year) to 

estimate how much waste would be added to the landfill to reach capacity. This amount was added to the 

waste-in-place to estimate the landfill design capacity. 

If the landfill had values for annual waste acceptance rate, year the landfill opened, and landfill 

closure year, then the landfill design capacity was calculated by multiplying the landfill lifetime by the 

annual waste acceptance rate. The landfill lifetime 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 opened 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. The 

years remaining before landfill closure were calculated by subtracting the waste-in-place year from the 

landfill closure year. This result was then multiplied by the annual waste acceptance rate to estimate the 
6

amount of waste to be added to the landfill to reach capacity. The added waste and the waste-in-place 

were summed to determine the design capacity. 

Next, the landfill design capacity was calculated based on the landfill lifetime and the annual 

waste acceptance rate. The 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 waste-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 subtraction of the year the landfill 

opened from 1998. The 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 database, designed landfill area from the 

voluntary survey for the landfill was used. If the designed landfill area was not reported, but the current 

landfill area (acres) was reported and waste-in-place divided by the landfill design capacity was equal to 

or less than one, then the landfill design area was calculated using current landfill area, waste-in-place, 

and landfill design capacity. This calculation assumes 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. The landfill design area 

was 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 (acres) 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 assumed waste density of 45 cubic feet per

ton. 

Finally, if 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 analysis of a graph of the reported design areas and design capacities. Two 

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 tons:

Landfill Design Area (acres) = 0.0000044 * [Landfill design capacity (tons)] + 98.26

 Calculation for landfills with design capacities less than or equal to 5 million tons:

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 recorded 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 the 
7

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 feet per ton. The 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, if 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 analysis of a graph of the reported design depths and design capacities. 

Two 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 tons:

Landfill design depth (feet) = 0.00000086 * [Landfill design capacity (tons)] + 108

 Calculation for landfills with design capacities less than or equal to 5 million tons:

Landfill design depth (feet) = 0.000012 * [Landfill design capacity (tons)] + 56

3. Final Dataset

After filling the data gaps (for waste-in-place year, annual waste acceptance year, landfill closure 

year, year landfill opened, landfill design capacity, landfill design area, and landfill depth), 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, 1,853 landfills (76 percent of the total) had 

sufficient data to include in the NSPS/EG analysis–1,832 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 contents 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 OrganizatioOrganization 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 (tonsWaste 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 YeYear 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 DescriptionDescription 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 DescrDescription 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 landfill
Appendix 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 survey
Appendix 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: Eastern 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, subpart WWW and 40 CFR part 60, 

subpart Cc, respectively). Currently, the regulations require any landfills of at least 2.5 million 

megagrams (Mg) and 2.5 cubic meters in design capacity with estimated nonmethane organic compounds 

(NMOC) emissions 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 landfills. 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 baseline. All existing landfills that 

accepted waste after November 19872as well as future landfills that are predicted to open in the 5-year 

period of January 2014 through December 2018 are included in the analysis. Annual estimates of 

emission reductions and costs were 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 alternatives differ from the baseline by variations in the emission rate thresholds, the design 

capacity thresholds, 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 below:

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

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 Mg and 2.5 cubic meters. Other 

landfill design capacity thresholds were evaluated as alternatives. 

 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 

occurred. Shorter initial lag times were examined among the alternatives.

 The expansion lag time is the amount of time allotted for 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 complying 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, the 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, those 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 until 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 - Landfill_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 designated Option D 

in the database table of Calculated Inputs_Annual Waste.

 WAR = Landfill_Design_Cap_tons / (Landfill_Closure_Year - Landfill _Year_Open+1)

Next, the annual WIP was calculated by summing the WAR over time. The EPA is aware of 

historical WAR 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 emissions from each landfill for each year during the 

period of 2014-2023. 

Eq. 1:

kt

4t 0 CH k L M e



   

Where:

CH4t = Methane, ft3in year t

k = Methane generation rate, year-1

L0 = Potential methane generation capacity, ft3 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: LFGt = CH4t × 2

Where:

LFGt = Landfill gas, ft3in year t

CH4t = Methane, ft3in year t

2 = Multiplier to convert methane to LFG (assuming that LFG is 50 percent 

methane), unitless

The mass of NMOC emissions produced by each landfill was estimated based on the amount of 

LFG produced at the landfill, as shown in Equation 3.

Eq. 3: NMOCt = LFGt ÷ 35.32 × 595 × 3.6E-9

Where:

NMOCt = NMOC in year t, Mg in year t

LFGt = Landfill gas, ft3in year t

35.32 = Conversion, ft3 per m3

595 = Concentration of NMOC in LFG, ppm NMOC by volume as hexane 

3.6E-9 = Conversion factor, Mg NMOC per m3 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 4a.

Eq. 4a: Mg CH4 = CH4t × 0.0423 ÷ 2000 ÷ 0.90718 

Where: 

Mg CH4 = Methane in year t, Mg in year t

CH4t = Methane, ft3in year t (From Equation 1)

0.0423 = Density of methane, lb per ft3

2000 = Conversion, lb per short ton 

0.90718 = Conversion, short ton per Mg 
4

The mass of methane emissions, in terms of carbon dioxide equivalents, produced by each landfill 

was estimated using the Equation 4b.

Eq. 4b: Mg CO2eq = Mg CH4 × GWPCH4

Where: 

Mg CO2eqt = Methane emissions as carbon dioxide equivalents, Mg in year t

Mg CH4t = Methane, Mg in year t (From Equation 4a)

GWPCH4 = 25, Global Warming Potential of Methane

2.3 NSPS/EG and AP-42 Default Values for Calculating Emissions3

The current NSPS requires the use of Tier 1 default value for the potential methane generation 

capacity (L0) and methane generation rate (k) to determine when the landfill exceeds the 50 Mg NMOC 

per year emission rate threshold. The NSPS L0 is equal to 5458 ft3 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 offers 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 concentration of 595 ppmv.) Therefore, the combination of the Tier 1 defaults for k and L0 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. Because the 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 LFGNSPS/EG and NMOCNSPS/EG. NSPS defaults tend to overestimate actual 

emissions at most landfills (due to the conservatively high L0 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 L0 is equal to 3210 ft3 methane per 

ton of waste. The 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 concentration of 595 ppmv, result in estimates of LFG and NMOC that are 

in accordance with the AP-42; in this evaluation these estimates were called LFGAP-42 and NMOCAP-42. 

As previously mentioned, for this evaluation, LFGNSPS/EG and NMOCNSPS/EG were used to 

determine when landfills would install controls. To determine when landfills may remove controls, the 

current rules allow landfills to measure the actual collected gas flow rate as well as the concentration 

(instead of relying on Tier 1 default L0 and k defaults). Because the AP-42 values for L0 and k produce 

results that more closely match actual gas flow rates and emissions, LFGAP-42 and NMOCAP-42 were used 

in this analysis to determine when landfills would remove controls.

Landfill-Specific k Factors

As noted above, the 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 period 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/ttn/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 assumed that the collection equipment 

was 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. As 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 was not expanding the gas collection system (i.e., by installing 

wells in new areas of waste placement) every year, the landfill may have produced more emissions than 

could be collected until the gas collection 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 LFGAP-42 and NMOCAP-42, estimates with the 

appropriate lag times. This 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 was 3 years and the expansion lag time 

was 4 years. 

Table 1. Example of Collected NMOC Estimate at a Landfill with an Initial Lag Time of 3 Years 

and an Expansion Lag Time of 4 Years

Year NMOCNSPS/EG NMOCAP-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. The amount of collected NMOC and methane destroyed by combustion controls was

estimated by multiplying the amount of collected gas by a destruction efficiency of 98 percent. The 

98 percent destruction efficiency accounts for the fact that combustion is not 100 percent efficient. 

3. Cost Equations

The cost equations used in this regulatory evaluation were derived from EPA’s Landfill Gas 

Energy Cost Model (LFGcost), version 2.3, which was developed by EPA’s Landfill Methane Outreach 

Program (LMOP). LFGcost estimates costs for gas collection, flare and energy recovery systems and was 
6

developed based on cost data obtained from equipment vendors and consulting firms that have installed 

and operated numerous gas collection and control systems. LFGcost 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, indirect costs, and 

recovery credits. Direct annual costs are those that are proportional to a facility-specific metrics such as 

the facility’s productive output or size. Indirect annual costs are independent of facility-specific metrics 

and may include categories such as administrative charges, taxes, or insurance. Recovery credits are for 

materials or energy recovered by the control system.

For this evaluation, all costs are presented in 2012$. The costs included in LFGcost are in 2008$

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 flares, wells, wellheads (including piping to 

collect gas) and engines over the lifetime of the equipment. It was assumed that the equipment would 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 assumed that flares, wells, 

well heads, and engines had a 15-year lifetime. 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 installation cost had 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 wells 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

13 140 140
7

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 control device used at landfills. All landfills required to comply with the 

control scenario were assumed to install flares; even landfills using engines would have flares as the backup control device for periods when the engines are not operating. The capital flare costs were estimated 

using the equation below, which was based on the installed cost of the knockout, blower, and flare system 

as determined in LFGcost. The flares were 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:

4

0.6 1

15yr max

capital 15,y 4,100 (1.01)

525,600

LFG

Flare z  

















 

Where:

Flare capital = Installed annualized cost of knockout, blower, and flare system, 2012$

z 15,y = Annualization factor where x=15 yrs and y=interest rate (0.07), unitless

LFG15yrmax = Maximum LFG collected for 15 year project period, ft3 per year 

525,600 = Conversion factor, minutes per year

$4,100 = Installed capital cost of knockout, blower, and flare system, 2008$ per 

ft3/min LFG

(1.01)4 = Adjustment from 2008$ to 2012$, unitless6

Well Capital Costs

The well capital costs were based on a dollar per foot of well depth installed estimate from 

LFGcost. As shown in the equation below, wells 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 capital = z 15,y × (Depth – 10) × 90 × Wells annual × (1.01)4

Where:

Well capital = Installed annualized cost of wells, 2012$

z 15,y = Annualization factor where x=15 yrs and y=interest rate (0.07), unitless

Depth = 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 years
8

Wells annual = Number of wells operated each year

(1.01)4 = Adjustment from 2008$ to 2012$, 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. The capital wellhead costs at each landfill were estimated using a dollar per wellhead 

installed cost from LFGcost and the number of wells at each landfill. 

Eq. 7: Wellhead capital = z 15,y × 15,000 × Wells annual × (1.01)4

Where:

Wellhead capital = Installed annualized cost of wellheads, 2012$

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

(1.01)4 = Adjustment from 2008$ to 2012$, 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 was dependent on the expansion lag time. This cost was independent of 

the number of wells being added. 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 capital = z x,y × 25,000 × (1.01)4

Where:

Installation capital= Mobilization/installation annualized cost, 2012$

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

rate (0.07), unitless

$25,000 = Mobilization/Installation costs, per occurrence, 2008$

(1.01)4 = Adjustment from 2008$ to 2012$, unitless

Engine Capital Costs 

Engines were assumed to be installed only at landfills that produced enough LFG to power the 

engine and only when the electricity buyback rates allowed the operation of the engine to be profitable. 

Standard engines used at landfills have approximately 1 MW capacity, which equates to 195 million ft3

per year of collected LFG (at 50 percent methane). Therefore, engines were assumed to be installed at 

landfills that had at least 195 million ft3 per year of collected LFG for at least 15 years, which could be as 

late as 2037 for engines there were installed in 2023.

The engine capital and operation and maintenance (O&M) equations were calculated and 

summed to determine at what electricity 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 engines 

were only installed in states with buyback rates exceeding those values. 
9

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

additional engines. As noted above, one engine required 195 million ft3 per year of collected LFG. To 

have two engines on site, the landfill must have had double that amount of LFG (390 million ft3 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 reciprocating enginegenerator sets in LFGcost. These costs included 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 × (1.01)4 × Engine multiplier

Where:

Engine capital = Installed annualized cost of engines, 2012$

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

(1.01)4 = Adjustment from 2008$ to 2012$, 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 needed. Landfills must purchase electricity to operate the blowers 

used to collect LFG. EPA used commercial average retail electricity prices by State from the U.S. Energy 

Information Administration to estimate electricity purchase prices at the landfill.

Landfills 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 state from the U.S. Energy Information Administration (EIA) were used to 

estimate electricity buyback rates7. These wholesale prices generally fit in the range of typical buyback 

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. Electric 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.html
10

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

found. Therefore, 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

An estimate of the flare O&M costs from LFGcost was used to estimate the flare annual costs, as 

shown in the equation below: 

Eq. 10: Flare O&M = 4,500 × (1.025)

4

Where:

Flare O&Ml = Flare annual O&M costs, 2012$

$4,500 = Annual O&M flare cost, 2008$

(1.025)

4 = Adjustment from 2008$ to 2012$, unitless9

Well O&M Costs

An estimate of the well O&M costs from LFGcost was used to estimate the well annual costs, as 

shown in the equation below: 

Eq. 11: Well O&M = 2,250 × Wells annual × (1.025)

4

Where:

Well O&Ml = Well annual O&M costs, 2012$

$2,250 = Annual O&M well costs, 2008$ per well

Wells annual = Number of wells operating each year

(1.025)

4 = Adjustment from 2008$ to 2012$, unitless

Electricity O&M Costs

The 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 × Electricitypurchase × LFG collected

Where:

Electricity O&M = Electricity annual O&M costs, 2012$

0.002 = Electricity usage by blowers, kWh per ft3 LFG

Electricity purchase = Electricity purchase price, 2012$ per kWh

LFG collected = Amount of LFG collected, ft3 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 LFGcost, 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 formula 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 × (1.025)

4 × Engine multiplier

Where:

Engine O&M = Engine annual O&M costs, 2012$

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

(1.025)

4 = Adjustment from 2008$ to 2012$, 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, 2012$

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, 2012$ per KWh

Engine multiplier = Number of engines

4. Summary 

This memorandum summarizes the emission reduction and cost equations used to evaluate the 

cost and emission impacts of various control scenarios considered under the review of the NSPS and EG. 

The EPA determined which landfills met the design capacity and emission rate thresholds for each 

regulatory option, then calculated the emission reductions and costs for each landfill for each year from 

2014 through 2023 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 Revisions 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 Protection 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 Landfills NSPS Review

Introduction

The purpose of this memorandum is to present the results of the analysis to estimate costs and 

emission reductions for the 2014 review of the new source performance standards (NSPS) for municipal 

solid waste (MSW) landfills. 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 equations and data inputs used to estimate the impacts are discussed in other memoranda

in the docket.

1,2,3

Results are presented in 2012 dollars ($2012) and are based on the annualized costs in 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 impacts 

associated with the current design capacity and NMOC emission thresholds currently 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 follows:

1.0 Overview of Regulatory Options

2.0 Estimating Cost Impacts

3.0 Estimating Emission Reductions Impacts

4.0 Estimating Impacts for Enhanced Surface Emission 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

Descriptions of the current regulatory baseline, the proposed revision, and alternative options are

included in this section. 
2

1.1 Baseline

 Currently, 40 CFR part 60, subpart WWW requires all landfills with a design capacity of 

2.5 million megagrams (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 

construction, 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 control system (GCCS) by 2023.

1.2 Proposal

 The proposal reduces the NMOC emission threshold from 50 Mg/yr to 40 Mg/yr. The number of 

landfills subject to the rule remains the same as the baseline because the design capacity threshold 

remains the same. However, 11 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 employs a modeled initial GCCS installation 

lag time of 3 years after exceeding the NMOC threshold, and an average GCCS expansion lag 

time of 4 years as discussed in another memorandum.

2 As a result, 2020 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 

Initial 10-year Period 

Control Parameters

Number of Landfills with Control 

Systems Installed

By Year

2014-

2019 2020 2021 2022 2023

Baseline (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 several 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 options incorporated 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 million 

Mg to 2.0 million Mg in order to include any smaller landfills that might exceed this lower 

NMOC emission 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 reductions, 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 lifecycle. 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 million 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 expansion. However, 

because the same subset of landfills would require controls to be installed under the current 3-

year lag times, the overall additional emission reductions are not as 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 shortened the expansion lag times. Reducing the expansion lag time achieves a

larger net emission 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 lag 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, paired with a tighter frequency of subsequent 

expansions. 

 Finally, some options combined reduced design 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 expenses 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 shown 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

The emission reductions of each regulatory option are presented in terms of NMOC (Mg/yr), 

methane (Mg/yr), and carbon dioxide equivalents (Mg CO2e/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 

CO2e/yr)

Incremental

Annual 

NMOC 

Reductions 

(Mg/yr)

Incremental

Annual 

Methane 

Reductions 

(Mg/yr)

Incremental 

Methane 

Reductions 

(Mg 

CO2e/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 $/CO2e

Baseline 

2.5/50 4,400 29 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 regulatory 

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 memorandum3, SEM costs were estimated for both the proposed SEM program and 

the enhanced SEM program.3 The costs for the proposed SEM program 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 proposal. 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 

approach, 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 path.

Table 5. Summary of Costs for Proposed Versus Enhanced Surface Emission Monitoring Program 

Control 

Option

Surface 

Monitoring 

Option

No. of 

Landfills 

Conducting 

Surface 

Monitoring

Average 

Annual 

Cost

Incremental 

Cost

Average 

Annual Cost 

Per 

Controlled 

Landfill

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. ERG. 2014. Summary of Landfill Dataset Used in the Cost and Emission Reduction 

Analysis of Landfill Regulations. 

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

Landfill Regulations. 

3. ERG. 2014. Methodology for Estimating Testing and Monitoring Costs 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 do 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 Times

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/yr
Appendix 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 Costs
Appendix 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 CH4

$/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.

Total Incremental 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 2023
Appendix 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 Monitoring 
RunID 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 pattern
RunID 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 8,427 
RunID 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 7,421 
RunID 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: Estimating Secondary Impacts of the Landfills NSPS Review

The EPA is reviewing the new source performance standards (NSPS) for 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 proposed 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 secondary 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 the year 2023, which is 10 years after the NSPS is proposed. 

This is consistent with the presentation of the costs and emission impacts in the preamble. The 

methodologies for estimating costs and emission reductions are presented in the cost and emission 

impacts methodology memorandum1. 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. Using these values, it is 

possible to back calculate the amount of methane destroyed by the engines vs. the flares. Equations 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 (metric tons/yr), and the annual methane sent to flares (in cubic feet per 

year or ft3/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 ÷ Electricity_Price ÷ 1,000

Where:

Elec_Produced = Electricity produced (2023), MWh/yr

Eng_Revenue = $/yr (computed using equations in the cost and emission impacts 

methodology memorandum)

 

1 ERG. 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 = Conversion factor, kW per MW

Equation 2: Quantity of Methane Sent to Engines

CH4Engines = Elec_Produced × 11,100 × 1,000 ÷ 1,012 × 0.0423 ÷ 2,000 × 0.9072

Where:

CH4Engines = Methane sent to engines (2023), metric ton/yr

Elec_Produced = Electricity produced, MWh/yr, from Eqn. 1

11,100 = Engine heat rate, 11,100 Btu/kWh

1,000 = Conversion factor, kW per MW

1,012 = Heating value of methane, Btu/ ft3 CH4

0.0423 = Density of CH4, lb/ ft3

2,000 = Conversion factor, lb/ton

0.9072 = Conversion factor, metric ton per short ton

Equation 3: Quantity of Methane Flared

CH4flared = (CH4Total - CH4Engines) × 2,000 ÷ 0.9072 ÷ 0.0423

Where:

CH4flared = Methane sent to flares (2023), ft3/yr

CH4Total = Methane destroyed, (2023), (computed using equations in cost and 

emission impacts methodology memorandum, metric ton/yr)

CH4Engines = Methane sent to engines, from Eqn. 2

2,000 = Conversion factor, lb/ton

0.9072 = Conversion factor, metric ton per short ton

0.0423 = Density of CH4, lb/ ft3

2. Energy Impacts

As discussed in the cost and emission impacts methodology memorandum,

2

the regulatory 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 CFR 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 = CH4_flared × 0.002 × 2 ÷ 1,000

Where:

E_demand = Energy demand (2023), MWh

CH4_flared = Quantity of methane flared in each option, ft3/yr, from Eqn. 3

0.002 = Energy demand of LFG collection system, kWh/ft3LFG (see cost and 

emission impacts methodology memorandum)

2 = Multiplier, methane in LFG, assuming 50% methane

1,000 = Conversion factor kW/MW

Equation 5: Net Energy Impact

E_Impact = Elec_Produced – E_demand

Where:

Elec_Produced = Electricity produced (2023), MWh, from Eqn. 1

E_demand = Energy demand 2023, MWh, from Eqn. 4

Table 1 summarizes the energy impacts of the proposed 40 CFR 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 memorandum.

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 the 

regulatory options presented in the preamble.

Table 1 Summary of Incremental Energy Impacts of Proposed Subpart XXX in 2023 Above the 

Current NSPS

Option

Incremental 

Energy Demand 

(MWh)

Incremental 

Energy Supply 

(MWh)

Incremental Net 

Energy Impact 

(MWh)

Incremental 

Value of Net 

Energy Supply 

(2012$)

Proposed subpart to 

reduce NMOC 

threshold 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, the proposed subpart has secondary air 

impacts, which are expected to incur in three main components:

 

3 ERG. 2014. Methodology 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 on 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 flares, combustion by-product emissions such as SO2 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 6a and 6b and 7a and 7b along with emission factors from Chapter 

2 of EPA’s AP-424 were used to estimate the secondary air impacts resulting from the combustion of 

LFG.

Equation 6a: NOx Emissions from Flares

NOxflare = EFNOxflare × CH4_flared ÷ 2,000

Where:

NOxflare = NOx emitted from flared LFG (2023), tpy

EFNOxflare = NOx emission factor, 40lb/ 106 dscf methane, from AP-42

CH4_flared = Quantity of methane flared (2023), dscf/yr

2,000 = Conversion factor lb/ton

Equation 6b: NOx Emissions from Engines

NOxengine = EFNOxengine ÷ 1,012 × 11,100 × 1,000 × Elec_Produced ÷ 2,000

Where:

NOxengine = NOx emitted from LFG engines (2023), tpy

EFNOxengines = NOx emission factor, 250 lb/ 106 dscf methane, from AP-42

1,012 = Methane heating value, Btu/scf

11,100 = Engine heat rate, Btu/kWh

1,000 = Conversion factor kW/MW

Elec_Produced = Electricity produced 2023, MWh, from Eqn 1

2,000 = Conversion factor lb/ton

SO2 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 SO2 during combustion and uses the AP-42 default 

sulfur content for raw LFG rather than using landfill-specific data.

Equation 7a: SO2 or Hg Emissions from Flares

Pollflare = PconcLFG ÷ 106 × MWpoll ÷ LFGstd ×2 × CH4_flared ÷ 2000

Where:

Pollflare = Pollutant 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

PconcLFG = Pollutant concentration of LFG5, ppmv

MWPoll = Molecular weight of SO2 (64.06) or Hg (200.61), lb/lb-mol

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

2 = Multiplier, ratio of LFG to methane, assuming 50% methane

CH4_flared = Quantity of methane flared, (2023), dscf/yr, from Eqn 3

2,000 = Conversion factor lb/ton

Equation 7b: SO2 or Hg Emissions from Engines

Polleng = PconcLFG ÷ 106 × MWpoll ÷ LFGstd *2 ÷ 1,012 × 1,000 × 11,100 × Elec_Produced ÷ 2,000

Where:

Polleng = Pollutant emitted from LFG engines (2023), tpy

PconcLFG = Pollutant concentration of LFG6

MWPoll = Molecular weight of SO2 (64.06) or Hg (200.61), lb/lb-mol

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

2 = Multiplier, ratio of LFG to CH4, assuming 50% methane

1,012 = Methane heating value, Btu/scf

1,000 = Conversion factor kW/MW

11,100 = Engine heat rate, 11,100, Btu/kWh

Elec_Produced = Electricity produced (2023), MWh, from Eqn. 1

2,000 = Conversion 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 quantified 

using Equation 2, and emission factors from EPA eGRID (9th edition)7can be applied to estimate the 

emissions associated with this purchased electricity. While cap and trade mechanisms in place for SO2

and NOx emissions in the electricity sector prevent quantifying emissions resulting from purchased 

electricity, the eGRID factors can be used to estimate the increase in CO2 and Hg emissions from 

purchased electricity. However, eGRID data are unavailable to estimate the impacts on CO or PM from 

purchased 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 factors 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 does not 

include a factor for mercury, so the 2007 eGRID data set was used to estimate mercury emissions.

Equation 8: CO2 or Hg Emissions from Grid Purchased Electricity

Pollgrid = 0.002 × CH4_flared × 2 × EFgrid ÷ 2,000 ÷ 1,000

Where:

 

5 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.

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/energyresources/egrid/index.html.
6

Pollgrid = Pollutant emitted from grid purchased electricity in 2023, tpy

EFgrid = Emission factor from grid purchased electricity, lb/MWh from Table 2

0.002 = Electricity consumption by LFG collection blowers, kWh/ft3 LFG

CH4_flared = Quantity of CH4 flared(2023), dscf/yr, from Eqn. 3

2 = Multiplier, ratio of LFG to CH4, assuming 50% methane

1,000 = Conversion factor kWh/MWh

2,000 = Conversion 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 

CO2 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 purchased 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 CO2 and Hg Emissions from LFG Energy Supply

Pollavoided = Elec_Produced × EFgrid ÷ 2,000 

Where:

Pollavoided = Pollutant avoided from grid electricity (2023), tpy

EFgrid = Emission factor from avoided grid electricity, lb/MWh from Table 2

Elec_Produced = Average annual electricity produced (2023), MWh, from Eqn. 1

2,000 = Conversion 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.

Equation 10: Net Secondary Emissions Impact

Net Emissions = Polleng + Pollflare + Pollgrid - Pollavoided

Where:

Net Emissions = Net emissions (2023), tpy

Polleng = Pollutant emitted from LFG engines (2023), tpy

Pollflare = Pollutant emitted from flared LFG (2023), tpy

Pollgrid = Pollutant emitted from grid purchased electricity (2023), tpy

Pollavoided = Pollutant avoided from grid electricity (2023), tpy
7

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

requirements. The CO2 emission reductions presented in this table are in addition to the CO2e 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 Proposed Subpart XXX in 2023

Pollutant

Emissions Created 

(LFG Flares and 

Engines) (tpy)

Emissions Avoided 

(tpy) Net Emissions (tpy)

SO2 5 Cannot compute Cannot compute

Hg 9 586 -577

NOx 62 Cannot compute Cannot compute

CO2 415 26,554 -26,139
*** Draft – Do Not Cite, Quote, or Release During Review ***

SUMMARY OF SMALL ENTITY OUTREACH. 2014

The EPA held 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 combustion 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 provide 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 current 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 Submitted 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 should 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 

- Regulating 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 financial 

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 Startup, 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 LFGTE 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 standards 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 do 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 operators 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 performed 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

 Existing 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 such 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 squash 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 worse 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 cost 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 monitoring both cover 

integrity and the effectiveness of well spacing and vacuum in 

order to ensure adequate collection efficiency” .

 Current SEM requirements are appropriate and there does not 

appear to be data to indicate the current SEM procedures are 

inadequate

 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 accomplished 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 monitoring 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 – Do Not Cite, Quote, or Release During Review ***

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 if 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 applicability 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 not 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 method 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. significant 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 for 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 the 

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 landfills 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 system 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 modeled 

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 significant 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 system to damage from 

operations

 Increased sediments in the landfill affects landfill gas header 

alignment. Results in more operational troubleshooting, repairs, 

and replacement costs

 Earlier 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 States 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 3rd party entities

 If responsible for actions of independent 3rd 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 regulating 

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 of 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 scale

 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 investment

 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 supported 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 options 

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 

since 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 mean 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 incurred

 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 / metric 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 appropriately 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 by 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 found 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 cover 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 current 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 final 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 have 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 increase 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 demonstrated 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 beginning 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 stormwater 

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 based 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 nonproducing 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 Costs for the MSW Landfill 

Regulations

Introduction

This memo presents the assumptions and equations used to calculate testing and monitoring costs 

for landfills that would be affected by the review of the new source performance standards (NSPS) for 

municipal solid waste (MSW) landfills. This memo summarizes those testing and monitoring costs for

both uncontrolled and controlled landfills that would be subject to the landfills NSPS. These costs are one 

element of the overall cost estimates used to analyze the impacts. A separate memorandum summarizes 

the total cost (control, testing, and monitoring) of each regulatory option that EPA considered for 

proposal.1

The types of testing and monitoring required by the proposal differ depending on whether the

landfill is required to control its emissions. Table 1 shows the various testing and monitoring

requirements that would apply to controlled and uncontrolled landfills. For this analysis, it was assumed 

that if controls were required to be installed by 2023, the landfill was considered to be a controlled 

landfill, and it would incur the testing and monitoring costs associated with being controlled. A separate 

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

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

Table 1. Applicability of Various Testing and Monitoring Requirements

Testing and Monitoring Requirement Applicability

NMOC Emission Rate

 Annual (Tier 1)

 Once every 5 years (Tier 2)

Uncontrolled Landfills

Initial Performance Tests

 NMOC % destruction or control device 

outlet ppmvd

 Oxygen

Controlled Landfills

 

1 ERG. 2014. Cost and Emission Impacts Resulting from the Landfill NSPS Review.

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

Table 1. Applicability of Various Testing and Monitoring Requirements

Testing and Monitoring Requirement Applicability

Continuous Combustor Monitoring

 Temperature

 Flowrate

Controlled Landfills

Monthly Wellhead Monitoring

 Nitrogen or oxygen

 Gauge pressure

 Temperature

Controlled Landfills

Quarterly Surface Monitoring Controlled Landfills

Integrated Sample Calculations Controlled Landfills – Enhanced Monitoring 

Option Only

Improved Surface Maintenance Controlled Landfills – Enhanced Monitoring 

Option Only

1. Labor Rates

Several of the testing and monitoring requirements require labor to complete the activities in 

addition to capital expenditures for purchasing the monitoring equipment. This analysis assumes that a 

Civil Engineer or Civil Engineer Technician completes the testing and monitoring requirements of the 

proposal. The mean hourly wage for these professions is presented in Table 2. The latest wage data are 

from May 2012. The wage rates were adjusted to include benefits and office overhead-related expenses.

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

Occupation

Unloaded National 

Mean Wage Rate3 Adjustment Factor Loaded Wage Rate

Civil Engineer $40.45 39.76 + 110%(40.45) $84.95

Civil Engineering 

Technician

$23.66 23.66 + 110%(23.66) $49.69

2. Costs for Uncontrolled Landfills

2.1 NMOC Emission Rate

The only testing and monitoring requirement for uncontrolled landfills is to periodically calculate

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

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

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

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

instead of using the higher default NMOC concentrations required under the Tier 1 calculations. Similar 

industry experience suggests that the Tier 3 calculation option is not widely used.

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

50 percent use Tier 2 calculations. Some uncontrolled landfills are small enough to use the Tier 1 defaults 

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

 

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

http://www.bls.gov/oes/current/oes_nat.htm#17-0000
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 place, annual 

waste acceptance waste) used for the LandGEM modeling, to run the model, and to report the results. The 

Tier 1 report is required annually.

Eq. 1: 8 hours * $84.95/hr = $680

2.3 Tier 2 Costs

The cost to conduct a Tier 2 test for site-specific NMOC values, which can be obtained using 

Method 25 or 25C, was estimated using the EPA Monitoring Costs and Benefits tool, which estimates a 

Method 25A test to cost $10,067.4 The EPA Monitoring Costs and Benefits tool does not include an 

estimate for Method 25 or 25C, but the costs estimated for Method 25A are expected to be similar to the 

methods allowed under the proposal. This test is incurred once every 5 years. 

In addition to the capital costs to conduct this test, there is time associated with gathering the 

samples and reporting the results. We used the Information Collection Request (ICR) burden estimate of 

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

5 The annualized cost of this test, including 

labor, over 5 years at a 7 percent interest rate is shown by Equation 2:

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

3. Costs for Controlled Landfills

3.1 Initial Performance Testing

The current NSPS and EG rules 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 the initial performance test is expressed in Equation 3:

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

 

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

5 See supporting statement for approved ICR 1557.08, line item for Report of tier 2 and 3 NMOC sampling Change. 

ICR available online at http://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=201112-2060-017

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

3.2 Continuous Combustor Monitoring

The NSPS and EG require continuous monitoring of the flowrate to the control device and the 

temperature of the enclosed flare or other enclosed combustion device. It is common practice for the 

flowrate and temperature to be monitored and recorded at landfills with energy projects in order to meet 

contractual requirements, safety protocols, and protect the investment in the energy infrastructure. The 

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

engine costs on landfills with energy projects. Therefore, these continuous monitoring costs are included 

in the control cost estimates described in the control cost memorandum because the flares and engines at 

these sites are typically equipped with sensors to monitor these parameters.7 

3.3 Monthly Wellhead Monitoring

The rule requires monthly monitoring of nitrogen or oxygen, pressure, and temperature at gas 

wells. Such well monitoring activities are included in the well O&M costs estimated for the NSPS and 

EG using the LFGcost model algorithms. This model bases wellfield O&M cost data on landfills with 

LFG energy projects installed. These landfills would already monitor these wellhead parameters in order 

to maintain a well balanced gas collection system and gas quality for their energy project. Therefore, 

these costs are already included in the well O&M cost line item discussed in the control cost 

memorandum.8

3.4 Quarterly Surface Monitoring

The current NSPS 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 

assumes that most landfills will contract out their surface monitoring requirements and the contracted 

price to complete the monitoring requirement would include both an hourly labor rate and an equipment 

rental rate.

The length of time for each rental was estimated by determining the controlled acreage of each 

landfill, as discussed below, and multiplying this acreage by an hour per acre estimate to obtain an 

estimate of total hours per landfill for each quarterly monitoring occurrence. The 2009 South Coast Air 

Quality Management District (SCAQMD) landfill regulations included estimates of 1 hour of a Civil 

Engineering Technician’s time per acre to complete surface monitoring requirements.

9 These labor 

estimates were based on a 25 feet traverse pattern requirement, compared with the 30 meter (~100 feet) 

traverse pattern in the NSPS. Adjusting the SCAQMD time estimates for a wider pattern and using the 

ratio of each pattern’s distance, we estimate that a 30 meter traverse pattern will require 0.254 hours per 

acre to complete.

The rental cost of a portable analyzer, such as the TVA 1000B, varies depending on the length of 

the rental. Rental rates were provided on a daily, weekly, and monthly basis from an equipment rental 

company.10 Daily equipment rental rates ($125 per day) were multiplied by the number of hours to 

complete each monitoring occurrence if the time was less than or equal to 24 hours (three 8-hour days). 

Weekly equipment rental rates were used if the number of hours to complete each monitoring occurrence 

was less than or equal 120 hours (three 40-hour weeks). Monthly equipment rental rates were applied if 

the number of hours to complete each monitoring occurrence was greater than 3 weeks. These rental costs 

 

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 occurrences 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 4a and 4b:

Eq. 4a: $49.69/hr *0.254 hr/acre * 4 events/year = $50.49/acre (30 meter traverse pattern)

Eq. 4b: $49.69/hr * 1 hr/acre * 4 events/year = $198.76/acre (25 foot traverse pattern)

The Modeling Database Containing Inputs and Results of Proposed Revisions to MSW Landfill 

NSPS11 was used to estimate the surface area of each new controlled site. Year-specific acreages were 

estimated in the Annual_Landfill_Waste table using annual waste rate data and the fraction of the 

designed area that was filled for all landfills that were estimated to control gas in 2023.

12

3.5 Integrated Sample Calculations and Transposing Field Data into Electronic Format

EPA estimates that most sites subject to integrated surface monitoring requirements under the 

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

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

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

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

into an electronic spreadsheet and computing an integrated sample average, we estimated it would take 

one hour per acre to transpose the field data into an electronic format. We applied the same Civil 

Engineering Technician hourly labor rate of $49.69 per hour. We multiplied this hourly wage by 

25 percent of the overall controlled acreage for the selected option to estimate the cost of manual 

calculations associated with an integrated sample reading.

3.6 Improved Surface Maintenance

If a tighter traverse pattern were incorporated in the NSPS and EG rules, landfills would likely be 

doing more surface maintenance and repair to prevent or correct methane surface emissions. Thus, 

additional costs to maintain and repair the landfill cover are estimated on the basis that a tighter traverse 

pattern might identify a larger number of elevated methane readings. A factor of $50 per acre per 

monitoring occurrence, (or $200 per acre per year) was used to account for these additional repair costs, 

based on estimates provided in the 2009 SCAQMD Landfill rule.

13

4. Summary of Costs

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

These costs are added to the control costs in order to develop a total cost for each regulatory option, as 

discussed in the Cost and Emission Reductions Impacts memo.14

 

11

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

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

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

14 ERG. 2014. Cost and Emission Impacts Resulting from the Landfills NSPS Review.
6

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

Affected 

Landfilla

Annualized 

Initial 

Performance 

Test ($)

Continuous 

Combustor 

Monitoring

Monthly 

Wellhead 

Monitoring

Quarterly Surface 

Monitoring

Annualized 

Improved 

Surface 

Maintenance

($/acre)

NMOC 

Testing

($)

Equipment 

Rental 

($/period)

Annual

Labor Cost 

($/acre)

Uncontrolled Landfills

Using Tier 1 NA NA NA NA NA NA $680

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

For 30-meter traverse pattern

Controlled 

(<=95 acres)

$1,105 Already 

includedb

Already 

includedb $125/day $50.48 NA NA

Controlled 

(>95 acres up 

to 472 acres)

$1,105 Already 

includedb

Already 

includedb $350/week $50.48 NA NA

Controlled 

(>472 acres) $1,105 Already 

includedb

Already 

includedb $1100/month $50.48 NA NA

For 25-foot traverse pattern with integrated sample calculationc

Controlled 

(<=24 acres)

$1,105 Already 

includedb

Already 

includedb $125/day $198.76 $200 NA

Controlled 

(>24 acres up 

to 120 acres)

$1,105 Already 

includedb

Already 

includedb $350/week $198.76 $200 NA

Controlled 

(>120 acres) $1,105 Already 

includedb

Already 

includedb $1100/month $198.76 $200 NA

a The listed acreages correspond to the length of time a monitor would need to be rented to complete surface 

monitoring for a landfill (daily, weekly, monthly), as described under Section 3.4 of this memo, Quarterly Surface 

Monitoring. 

b Already included in the control cost estimates. See the memo: ERG. 2014. Methodology for Estimating Cost and 

Emission Impacts for MSW Landfills Regulations.

c

In addition to these costs, it was assumed that a portion of the sites would not have a data logger to compile the 

field data automatically and compute the integrated sample calculations. The sites without a data logger would 

include an additional $49.69 per acre in labor to transpose the field data into an electronic format as discussed 

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

Format.