1 From: Thundiyil, Karen <Thundiyil.Karen@epa.gov>
Se nt: Wednesday, July 08, 2015 12:10 PM
T o: Grossman, Andrea
C c: Ward, Hillary; Marsh, Karen; Cozzie, David
Su bject: Landfills review - requested documents
A ttachments: Draft Calculations_cost eqn updates_070815.docx; Landfill Dataset Memo 070815.docx; Ap pendix A-Modification Data.xlsx; Testing and Monitoring Methodology Memo_
070815.docx



### Hi Andrea,

Following on yesterday’s MSW Landfills package interagency kickoff call – here are the requested files:

-Summary of Updated Landfill Dataset Used in the Cost and Emission Reduction Analysis of Landfills Regulations. 2015. (Appendix A also attached. Appendix B&C are still under development; they are field definition lists to match the database tables posted to the FTP.)

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

-Updated Methodology for Estimating Testing and Monitoring Costs for the MSW Landfill Regulations. 2015.

-DRAFT database. https://ftp.erg.com/?u=MULJ&p=Xe73

The database link can be shared with federal agencies (as part of the interagency review process).

H owever, it should not be shared with industry, the general public, etc (even if they are involved in any EO 12866 meetings). Work is underway to provide a separate file sharing mechanism for those that are outside of the interagency review process.

To see landfills controlling under the rule, look at any of the Output tables in the Tables tab. Option 1 is the baseline and option 13 is the proposed option. Users can go to a particular year and pick an option to 

### see if a specific landfill has to control.



### To see all affected landfill (in response to the BLM question), click on the “Background data: Owners and FIPs...” table. Go to the “design cap_ tons_tab”. Divide by 1.1 and filter to 2.5 million.

R egarding your question about Tier 4 in the emission reductions calculations, I’ll send a follow-up email later today.

Please let me know if you have any questions,

Karen.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: June 2015

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

Regulations

Introduction

The EPA is reviewing the new source performance standards (NSPS) and emission guidelines (EG) for municipal solid waste (MSW) landfills. Currently, the regulations require landfills of at least 2.5 million megagrams (Mg) and 2.5 million 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 other memoranda. 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 1987 2 

### as well as future landfills that are predicted to open or modify 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 in year 2025. Costs were estimated using both a 7 percent and 3 percent interest rate.

The alternatives differ from the baseline by variations in the emission rate thresholds and the design capacity thresholds. Shorter lag times were only evaluated for wet landfills as discussed in another
memorandum. 3 

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

2 The designated facility under the EG is each existing MSW landfill that has accepted waste since November 8, 1987 and for which construction, reconstruction, or modification was commenced on or before July 17, 2014.

3 ERG. 2015. 

### Revised Cost and Emission Impacts Resulting from the Landfill EG Review.2



### • The design capacity threshold in the current rule is 2.5 million Mg and 2.5 million 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. For landfills reporting to GHGRP:

a. Historical annual waste acceptance rate (AWAR) data beginning with the year the landfill opened through 2013 were generally available in GHGRP data tables ‘HH_ANN_WASTE_DISPOSAL_QTY’ and ‘HH_HIST_YR_WASTE_QTY’. These data were used to compute cumulative waste-in-place (WIP) amounts for each year of the model.

b. If data were missing for 2012 or 2013 reporting years at open landfills, the last known year’s AWAR was used to fill data gaps.

c. To estimate future year AWAR for landfills open past 2013, one of four methods was used:

i. For landfills with calculated 2013 WIP less than reported landfill capacity: AWAR = (Design Capacity - 2013 WIP)/(Estimated landfill closure year - 2013)
ii. For landfills with calculated 2013 WIP greater than or equal to reported landfill capacity:

AWAR = 2013 AWAR
iii. For landfills with calculated future AWAR greater than 10% of the 2013 AWAR:

AWAR = 2013 AWAR
iv. For landfills with 2013 AWAR = 0, future annual AWAR = 0.

2. For other landfills that were not GHGRP reporters, the landfill waste data were calculated one of
two ways:

a. When a landfill’s AWAR and WIP values were available in the landfill dataset and associated with a particular year, those values were extrapolated to estimate the landfill’s AWAR and WIP for each year. This estimation method was designated Option A in the database table of Calculated Inputs_Annual Waste.3 

### • When a Landfill_WIP and Landfill_WIP_Year are reported, the AWAR up until the Landfill_WIP_Year is estimated based on the following relationship:
AWAR = Landfill_WIP / (Landfill_WIP_Year - Landfill _Year_Open+1).

• The AWAR after the Landfill_WIP_Year is based on the following relationship:
AWAR = (Landfill_Design_Cap_tons - Landfill_WIP) / (Landfill_Closure_Year -
Landfill _WIP_Year+1).

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

• AWAR = Landfill_Design_Cap_tons / (Landfill_Closure_Year - Landfill _Year_Open+1) Next, the annual WIP was calculated by summing the AWAR over time.

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. The dataset
includes annual emission estimates for 2014-2025-2039.

Eq. 1 : kt 0 t 4 

### eMLkC H − 

### ×××=



### Where:

CH 4t



### = Methane, ft 3 

### in year t k = Methane generation rate, year -1



### L 0 

### = Potential methane generation capacity, ft 3 

### methane per ton M = Mass of waste accepted in year t, tons t = Analysis year (year 1 through 50), year

The volume of LFG produced by a landfill was estimated using Equation 2.

Eq. 2 : LFG t



### = CH 4t 

### × 2

Where:

LFG t



### = Landfill gas, ft 3 

### in year t

CH 4t 

### = Methane, ft 3 

### in year t

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

methane), unitless

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 : NMOC t



### = LFG t 

### ÷ 35.32 × 595 × 3.6E -9



### Where:

NMOC t



### = NMOC in year t, Mg in year t

LFG t 

### = Landfill gas, ft 3 

### in year t 35.32 = Conversion, ft 3 

### per m 34



### 595 = Concentration of NMOC in LFG, ppm NMOC by volume as hexane 3.6E-9 = Conversion factor, Mg NMOC per m 3 

### LFG

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

Eq. 4a : Mg CH 4 

### = CH 4t



### × 0.0423 ÷ 2000 ÷ 0.90718

Where: Mg CH 4 

### = Methane in year t, Mg in year t

CH 4t



### = Methane, ft 3 

### in year t (From Equation 1) 0.0423 = Density of methane, lb per ft 3 

### 2000 = Conversion, lb per short ton 0.90718 = Conversion, short ton per Mg

The mass of methane emissions, in terms of carbon dioxide equivalents, produced by each landfill was estimated using the Equation 4b.

Eq. 4b : Mt CO 2 

### eq = Mg CH 4 

### × GWP CH4



### Where:

Mt CO 2 

### eq t 

### = Methane emissions as carbon dioxide equivalents, Mt in year t 4 

### Mg CH 4t



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

GWP CH4 

### = 25, Global Warming Potential of Methane

2.3 NSPS/EG and AP-42 Default Values for Calculating Emissions 5



### The current NSPS requires the use of Tier 1 default value for the potential methane generation capacity (L 0 

### ) and methane generation rate (k) to determine when the landfill exceeds the 50 Mg NMOC per year emission rate threshold. The NSPS L 0 

### is equal to 5,458 ft 3 

### methane per ton of waste and the NSPS k values are 0.05 per year for areas receiving 25 inches or more of rainfall per year and 0.02 per year for areas receiving less than 25 inches of rainfall. While the NSPS 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 L 0 

### and the NMOC concentration of 595 ppmv were used to represent how landfills currently calculate NMOC emissions to determine if they have to install controls under the NSPS. 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 LFG NSPS/EG 

### and NMOC NSPS/EG 

### . NSPS defaults tend to overestimate actual emissions at most landfills (due to the conservatively high L 0 

### and k values).

EPA has collected and compiled available emission factor data for landfills in the report Compilation of Air Pollutant Emission Factors (AP-42). 6 

### The AP-42 L 0 

### is equal to 3210 ft 3 

### 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

4 A megagram is equal to a metric ton.

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

6 USEPA AP-42, Fifth Edition, Volume I Chapter 2: Solid Waste Disposal. http://www.epa.gov/ttn/chief/ap42/ch02/index.html5



### 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 LFG AP-42 

### and NMOC AP-42



### .

As previously mentioned, for this evaluation, LFG NSPS/EG 

### and NMOC NSPS/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 L 0 

### and k defaults). Because the AP-42 values for L 0 

### and k produce results that more closely match actual gas flow rates and emissions, LFG AP-42 

### and NMOC AP-42 

### were used in this analysis to determine when 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, long-term precipitation data by county are available for most landfill locations. 7 

### Some landfills in remote areas or U.S. Territories did not have data available and data from nearby weather stations from the National Oceanic and Atmospheric Administration (NOAA) were obtained and averaged over the available data period for each location. 8 

### 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 LFG AP-42 

### and NMOC AP-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 NMOC NSPS/EG NMOC AP-42 Collected NMOC

1 50.2 27.7 0.0

2 50.4 27.9 0.0

3 50.6 28.0 0.0

4 50.8 28.2 28.2

5 51.0 28.3 28.2

7 Prism Climate Group. 30-year Normals (1981-2010). http://www.prism.oregonstate.edu/normals/

, Accessed September 2015.

8 NOAA climate division data are available online at: http://www.ncdc.noaa.gov/cdo-web/6 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-Web), version 3.0, which was developed by EPA’s Landfill Methane Outreach Program (LMOP). LFGcost-Web estimates costs for gas collection, flare and energy recovery systems and was developed based on cost data obtained from equipment vendors and consulting firms that have installed and operated numerous gas collection and control systems. LFGcost-Web 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

c osts, and recovery credits. Direct annual costs are those that are proportional to a facility-specific metrics

s uch 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.

F or this evaluation, all costs are presented in 2012$. The costs included in LFGcost-Web are in 2013$ and were adjusted to 2012$ using a factor of 2 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. For landfills not reporting a GCCS area to GHGRP, 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). For GHGRP landfills who reported a GCCS area (as7



### discussed in section 2.3 of another memorandum) 9 

### this value was compared to the calculated area based on ratio of waste in place/design capacity discussed above. The maximum of the reported value or this calculated area was used as the starting point for an estimated GCCS area in year 2014, and that area grew overtime, tracking the ratio of waste in place/design capacity. In addition, it was assumed that each landfill would install one well per acre, consistent with the guidelines provided in the LFGcost-Web 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

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. Landfills using engines were assumed to have flares as the back-up 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-Web. The flares were sized based on the maximum LFG flow rate over the 15-year flare lifetime, which could be as late as 2039 for projects that were expected to begin operation in 2025.

Eq. 5 : 1 61.0
max15yr y15, capital 

### )02.1(600,4

525,600 LFG

z Flare

− 

### ××        

×=

9 Summary of Updated Landfill Dataset Used in the Cost and Emission Reduction Analysis of Landfills Regulations.
2015.8



### 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 or 0.03),

unitless

LFG 15yrmax 

### = Maximum LFG collected for 15 year project period, ft 3 

### per year 525,600 = Conversion factor, minutes per year $4,600 = Installed capital cost of knockout, blower, and flare system, 2013$ per

ft 3 

### /min LFG (1.02) -1 

### = Adjustment from 2013$ to 2012$, unitless 10



### Vertical Gas Extraction Well Capital Costs

The vertical gas extraction well capital costs were based on a dollar per linear foot of well depth installed estimate from LFGcost-Web. 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) × 85 × Wells annual 

### × (1.02) -1



### Where:

Well capital 

### = Installed annualized cost of vertical wells, 2012$

z 15,y 

### = Annualization factor where x=15 yrs and y=interest rate (0.07 or 0.03),

unitless Depth = Landfill waste depth, feet

10 = feet $85 = Installed capital cost of one vertical well, 2013$ per foot of well depth

Wells annual 

### = Number of vertical wells operated each year (1.02) -1 

### = Adjustment from 2013$ to 2012$, unitless

Wellhead Capital Costs

The capital wellhead cost covered the equipment associated with each well, including the wellhead and pipe gathering system (and any additional fittings/installations connecting the wells, and was dependent on the number of wells. In addition, this capital cost encompasses engineering, permitting, and surveying fees associated with the wellfield installation that are also dependent on the number of wells. The capital wellhead costs at each landfill were estimated using a dollar per well installed cost from LFGcost-Web for wellheads, pipe gathering system, engineering, permitting, and surveying and the

number of wells at each landfill.

Eq. 7 : Wellhead capital 

### = z 15,y 

### × 17,700 × Wells annual 

### × (1.02) -1



### Where:
Wellhead capital 

### = Installed annualized cost of wellheads, 2012$

z 15,y 

### = Annualization factor where x=15 yrs and y=interest rate (0.07 or 0.03),

unitless $17,700 = Installed capital cost of one wellhead, 2013$ per well

Wells annual 

### = Number of wells operated each year

10 Equation uses a formula of (1+inflation rate/100) t , where capital cost escalation is assumed to be 2 percent and t is equal to -1 year9



### (1.02) -1 

### = Adjustment from 2013$ to 2012$, unitless

Mobilization/ Installation Costs for Wellfield Expansion

The cost occurs upon installation of a new gas collection system (i.e., wellfield) and each time the 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, set-up, and mobilization costs to get the well drilling rig and pipe crew on site. This cost was estimated using the following equation from LFGcost-Web:

Eq. 8 : Installation capital 

### = z x,y 

### × 20,000 × (1.02) -1



### 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 or 0.03), unitless $20,000 = Mobilization/Installation costs, per occurrence, 2013$ (1.02) -1 

### = Adjustment from 2013$ 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 ft 3 

### per year of collected LFG (at 50 percent methane). Therefore, engines were assumed to be installed at
landfills that had at least 195 million ft 3 

### per year of collected LFG for at least 15 years, which could be as late as 2039 for engines there were installed in 2025.

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 $0.0594 per kWh at a 7 percent interest rate and greater than $0.0430 per kWh at a 3 percent interest rate; it was assumed engines were only installed in States with buyback rates exceeding those values.

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 ft 3 

### per year of collected LFG. To have two engines on site, the landfill must have had double that amount of LFG (390 million ft 3 

### per year) for at least 15 years after the project start date, which could be as late as 2037 for projects starting in

2023.

The capital costs for engines were based on the capital costs for standard reciprocating enginegenerator sets in LFGcost-Web. 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.10 

### Eq. 9 : Engine capital 

### = z 15 ,y, y 

### × 2,650,000 × (1.02)

- 1 

### × 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 or 0.03),

unitless $2,650,000 = Installed capital cost of one reciprocating engine-generator set, 2013$ per

engine (1.02) -1 

### = Adjustment from 2013$ 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 2012 commercial average retail electricity prices by State from the U.S. Energy Information Administration (EIA) to estimate electricity purchase prices at the landfill 11



### .

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 were calculated using 2012 resale generation and revenue data from EIA to estimate electricity buyback rates 12 

### . These wholesale prices generally fit in the range of typical buyback prices for LFG of $0.025 - $0.11/kWh, as discussed in LMOP’s Project Development

Handbook. 13 

### Additionally, LFGcost-Web uses a default buyback rate of $0.06/kWh and the U.S. average of the wholesale prices used is $0.0655/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 14 

### . The buyback rates were estimated by first determining the ratio of each State’s purchase price to the overall average U.S. purchase price. This ratio was then multiplied by the calculated average U.S. wholesale price to estimate a buyback rate. Electricity price data for the U.S. territories of Guam, Puerto Rico, and the Virgin Islands were not found. Therefore, EIA profile analyses for these three territories were used to escalate U.S. average prices to estimate electricity prices for each island 15



### .

Flare O&M Costs

11 U.S. DOE/EIA. Electricity: Detailed State Data, Annual Data for 2012. Average Price by State by Provider (EIA861), 1990-2012. Released November 12, 2013. http://www.eia.gov/electricity/data/state

12 U.S. DOE/EIA. Electric power sales, revenue, and energy efficiency Form EIA-861 detailed data files. 2012 Operational Data (Formerly File 1). Released October 29, 2013. http://www.eia.gov/electricity/data/eia861

13 U.S. EPA LMOP Chapter 4 of Project Development Handbook. http://epa.gov/lmop/documents/pdfs/pdh_chapter4.pdf

14 U.S. DOE/EIA. Electricity: Detailed State Data, Annual Data for 2012. Average Price by State by Provider (EIA861), 1990-2012. Released November 12, 2013. http://www.eia.gov/electricity/data/state

15 U.S. DOE/EIA. Territory Profile and Energy Estimates (for Guam, Puerto Rico, and the U.S. Virgin Islands). Profile Analysis, Electricity. December 18, 2013. http://www.eia.gov/state11



### An estimate of the flare O&M costs from LFGcost-Web was used to estimate the flare annual costs, as shown in the equation below:

Eq. 10 : Flare O&M 

### = 5,100 × (1.025) -1



### Where:
Flare O&M 

### = Flare annual O&M costs, 2012$ $5,100 = Annual O&M flare cost, 2013$ (1.025) -1 

### = Adjustment from 2013$ to 2012$, unitless 16



### Well O&M Costs

An estimate of the O&M costs for vertical gas extraction wells from LFGcost-Web was used to estimate the well annual costs, as shown in the equation below:

Eq. 11 : Well O&M 

### = 2,600 × Wells annual 

### × (1.025) -1



### Where:

Well O&M 

### = Well annual O&M costs, 2012$ $2,600 = Annual O&M well costs, 2013$ per well

Wells annual 

### = Number of wells operating each year (1.025) -1 

### = Adjustment from 2013$ to 2012$, unitless

Electricity O&M Costs

The electricity cost of operating the blowers was calculated using the electricity usage of blowers from LFGcost-Web and the electricity purchase price.

Eq. 12 : Electricity O&M 

### = 0.002 × Electricity purchase 

### × LFG collected



### Where: Electricity O&M 

### = Electricity annual O&M costs, 2012$ 0.002 = Electricity usage by blowers, kWh per ft 3 

### LFG Electricity purchase 

### = Electricity purchase price, 2012$ per kWh

LFG collected 

### = Amount of LFG collected, ft 3 

### per year

Engine O&M Costs

For landfills with engines installed, the O&M costs of the engine were estimated using the annual costs for standard reciprocating engine-generator sets from LFGcost-Web, and taking into account the amount of time that the engine was operating each year (assumed gross capacity factor in LFGcost-Web for engines) and the number of engines on site.

Eq. 13 : Engine O&M 

### = 0.025 × 1,000 × 8,760 × 0.93 × (1.025) -1 

### × Engine multiplier



### Where: Engine O&M 

### = Engine annual O&M costs, 2012$ 0.025 = Annual O&M engine cost, 2013$ per kWh

16 Equation uses a formula of (1+inflation rate/100) t , where O&M cost escalation is assumed to be 2.5 percent and t is equal to -1 year.12



### 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) -1 

### = Adjustment from 2013$ 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 in 2025 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. 17,

18, 19, 20

17 ERG. 2015. Updated Cost and Emissions Impacts Resulting from the Landfills NSPS Review.

18 ERG. 2015. Modeling Database Containing Inputs and Results of Supplemental Proposal for MSW Landfill

NSPS.

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

20 ERG. 2015. Modeling Database Containing Inputs and Results for Proposed 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: June 2015

SUBJECT: Updated Methodology for Estimating Testing and Monitoring Costs for the MSW

Landfill Regulations



### Introduction

This memo presents the assumptions and equations used to calculate testing and monitoring costs for landfills that would be affected by the review of the new source performance standards (NSPS) and emission guidelines for municipal solid waste (MSW) landfills. This memo summarizes those testing and monitoring costs for both uncontrolled and controlled landfills that would be subject to the landfills NSPS or emission guidelines. These costs are one element of the overall cost estimates used to analyze the impacts. Separate memoranda summarize the total cost (control, testing, and monitoring) of each regulatory option that EPA considered for each proposal. 1,2



### The types of testing and monitoring required by the proposal differ depending on whether the landfill is required to control its emissions. Table 1 shows the various testing and monitoring requirements that would apply to controlled and uncontrolled landfills. For this analysis, it was assumed that if controls were required to be installed by 2025, the landfill was considered to be a controlled landfill, and it would incur the testing and monitoring costs associated with being controlled. A separate memorandum discusses the approach for determining when and whether a landfill would install controls and the estimated schedule for installing controls on each landfill covered under the analysis. 3



### Table 1. Applicability of Various Testing and Monitoring Requirements 

### Testing and Monitoring Requir e ment Applicability

NMO C Emission Rate



### • Annual (Tier 1)



### • Once every 5 years (Tier 2) 

### Uncontrolled Landfills

Initial Performance Tests



### • NMOC % destruction or control device outlet ppmvd



### • Oxygen 

### Controlled Landfills

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

Landfills.

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



### .

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

### 2

Table 1. Applicability of Various Testing and Monitoring Requirements 

### Testing and Monitoring Requir e ment Applicability

Continuous Combustor Monitoring



### • Temperature



### • Flowrate 

### Controlled Landfills

Monthly Wellhead Monitoring



### • Nitrogen or 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 Rate 4 

### Adjustment Factor Loaded Wage Rate 

### Civil Engineer $ 40.45 39.76 + 110%( 40

. 45 ) $8 4.95 Civil Engineering

Technician 

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



### 2. Costs for Uncontrolled Landfills

2.1 NMOC Emission Rate

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

the NMOC emission rates to determine when the landfill must install controls. The NSPS allows landfills three methods (tiers) for determining their NMOC rates. Although the number of landfills using each tier of reporting is unknown, industry experience suggests that there are a significant number of landfills reporting under the Tier 2 method, which allows the site to measure a site-specific NMOC concentration instead of using the higher default NMOC concentrations required under the Tier 1 calculations. Similar industry experience suggests that the Tier 3 calculation option is not widely used. Although Tier 4 is a proposed option for the emission guidelines, given the site-specific nature of this tier, it is unknown how many landfills would use this option.

4 US Bureau of Labor and Statistics. May 2012 Occupational Employment Statistics. http://www.bls.gov/oes/current/oes_nat.htm#17-0000

### 3

This analysis assumes that 50 percent of uncontrolled landfills use Tier 1 calculations and 50 percent use Tier 2 calculations. Some uncontrolled landfills are small enough to use the Tier 1 defaults and still remain under the threshold requiring the site to control. However, many of the larger sites may opt to use Tier 2 testing if their Tier 1 calculations exceed the NMOC thresholds that trigger the control requirements

2.2 Tier 1 Costs

The cost to prepare and submit the NMOC report is based on an estimated 8 hours of a Civil Engineer’s time to collect the data (e.g., historic records of waste age, mass of waste in place, annual waste acceptance waste) used for the LandGEM modeling, to run the model, and to report the results. The Tier 1 report is required annually.

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

2.3 Tier 2 Costs

The cost to conduct a Tier 2 test for site-specific NMOC values, which can be obtained using Method 25, 25A, or 25C, was estimated using the EPA Monitoring Costs and Benefits tool, which estimates a Method 25A test to cost $10,067. 5 

### The EPA Monitoring Costs and Benefits tool does not include an estimate for Method 25 or 25C, but the costs estimated for Method 25A are expected to be similar to the methods allowed under the proposal. This test is incurred once every 5 years.

In addition to the capital costs to conduct this test, there is time associated with gathering the samples and reporting the results. An Information Collection Request (ICR) burden estimate of 12 hours of a Civil Engineer’s time or 12 * 84.95 = $1,019 was used. 6 

### The annualized cost of this test, including labor, over 5 years at a 7 percent and 3 percent interest rates is shown by Equations 2a and 2b:

Eq. 2a : ($10,067 + $1,019)*{0.07(1 + 0.07)^5} / {[(1 + 0.07)^5]-1} = $2,700 Eq. 2b : ($10,067 + $1,019)*{0.03(1 + 0.03)^5} / {[(1 + 0.03)^5]-1} = $2,400



### 3. Costs for Controlled Landfills

3.1 Initial Performance Testing

The current proposals require an initial test of the combustion control equipment in order to demonstrate compliance with the 98 percent NMOC reduction requirement or the 20 ppmvd NMOC concentration adjusted to 3 percent oxygen. This test will be conducted using Method 25, 25A, or 25C.

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

Benefits tool. 7 

### This cost was annualized over 15 years, consistent with the expected lifetime of the combustion control equipment, at a 7 percent and 3 percent interest rate. The annualized cost for the initial performance test is expressed in Equations 3a and 3b:

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

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

6 See supporting statement for approved ICR 1557.08, line item for Report of tier 2 and 3 NMOC sampling Change. ICR available online at http://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=201112-2060-017

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

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

3.2 Continuous Combustor Monitoring

The rules require continuous monitoring of the flowrate to the control device and the temperature of the enclosed flare or other enclosed combustion device. It is common practice for the flowrate and temperature to be monitored and recorded at landfills with energy projects in order to meet contractual requirements, safety protocols, and protect the investment in the energy infrastructure. The LFGcost model algorithms (used to estimate control costs) bases its enclosed flare and engine costs on landfills with energy projects. Therefore, these continuous monitoring costs are included in the control cost estimates described in the control cost memorandum because the flares and engines at these sites are typically equipped with sensors to monitor these parameters. 8



### 3.3 Monthly Wellhead Monitoring

The rules require monthly monitoring of nitrogen or oxygen, pressure, and temperature at gas wells. Such well monitoring activities are included in the well O&M costs estimated for the proposals using the LFGcost model algorithms. This model bases wellfield O&M cost data on landfills with LFG energy projects installed. These landfills would already monitor these wellhead parameters in order to maintain a well-balanced gas collection system and gas quality for their energy project. Therefore, these costs are already included in the well O&M cost line item discussed in the control cost memorandum. 9



### 3.4 Quarterly Surface Monitoring

The current rules require a technician to traverse the controlled sections of the landfill at 30 meter intervals to measure methane concentrations using a portable analyzer. This analysis assumes that most landfills will contract out their surface monitoring requirements and the contracted price to complete the monitoring requirement would include both an hourly labor rate and an equipment rental rate.

The length of time for each rental was estimated by determining the controlled acreage of each landfill, as discussed below, and multiplying this acreage by an hour per acre estimate to obtain an estimate of total hours per landfill for each quarterly monitoring occurrence. The 2010 California Landfill Methane Rule included estimates of 1 hour of a Civil Engineering Technician’s time per acre to complete surface monitoring requirements. 10 

### These labor estimates were based on a 25 feet traverse pattern requirement, compared with the 30 meter (~100 feet) traverse pattern in the current rules (40 CFR part 60 subparts WWW and Cf). Adjusting the CA LMR time estimates for a wider pattern and using the ratio of each pattern’s distance, we estimate that a 30 meter traverse pattern will require 0.254 hours per acre to complete.

The rental cost of a portable analyzer, such as the TVA 1000B, varies depending on the length of the rental. Rental rates were provided on a daily, weekly, and monthly basis from an equipment rental

company. 11 

### Daily equipment rental rates ($125 per day) were multiplied by the number of hours to complete each monitoring occurrence if the time was less than or equal to 24 hours (three 8-hour days). Weekly equipment rental rates were used if the number of hours to complete each monitoring occurrence was less than or equal 120 hours (three 40-hour weeks). Monthly equipment rental rates were applied if

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

9 Ibid.

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

11 Equipment Rental Rates TVA1000b. http://usenvironmental.com/air/fids/thermo-tva-1000b/

### 5

the number of hours to complete each monitoring occurrence was greater than 3 weeks. These rental costs were then multiplied by four occurrences per year to estimate an annual equipment rental cost for the quarterly monitoring requirements.

The EPA also estimated the cost to purchase calibration gases for the monitor at $204 per year, per landfill and hydrogen fuel to operate the monitor at $210 per year, per landfill. 12



### In addition to these equipment costs, there is a significant labor cost associated with traversing the path. Applying the labor rate for a Civil Engineering Technician, this annualized cost per acre is shown in Equations 4a and 4b:

Eq. 4a : $49.69/hr *0.254 hr/acre * 4 events/year = $50.49/acre (30 meter traverse pattern) Eq. 4b : $49.69/hr * 1 hr/acre * 4 events/year = $198.76/acre (25 foot traverse pattern)

The databases for each proposal 13,14 

### were used to estimate the surface area of each new controlled site. Year-specific acreages were estimated in the Annual_Landfill_Waste table using annual waste rate data and the fraction of the designed area that was filled for all landfills that were estimated to control gas
in 2025. 15



### 3.5 Integrated Sample Calculations and Transposing Field Data into Electronic Format

If an integrated surface emission concentration threshold were incorporated in the final rules, the EPA estimates that sites would use a data logger to collect the surface monitoring data in various grids of the landfills. After the samples were collected, they would be averaged to compute an integrated reading over each grid. The EPA understands that many landfills are using data loggers to facilitate the calculation of the integrated readings. For the analysis associated with the enhanced monitoring requirements, we assumed that 75 percent of sites would use a data logger. To estimate the additional burden of transposing the hand written sample values into an electronic spreadsheet and computing an integrated sample average, we estimated it would take one hour per acre to transpose the field data into an electronic format. We applied the same Civil Engineering Technician hourly labor rate of $49.69 per hour. We multiplied this hourly wage by 25 percent of the overall controlled acreage for the selected option to estimate the cost of manual calculations associated with an integrated sample reading.

3.6 Improved Surface Maintenance

If an enhanced surface monitoring approach were incorporated in the final rules, landfills would likely be doing more surface maintenance and repair to prevent or correct methane surface emissions. Thus, additional costs to maintain and repair the landfill cover are estimated on the basis that a tighter traverse pattern might identify a larger number of elevated methane readings. A factor of $50 per acre per monitoring occurrence, (or $200 per acre per year) was used to account for these additional repair costs, based on estimates provided in the 2009 CA LMR. 16

12 Pine Environmental. Cost to purchase (including shipping/handling) of: 105L of CH4-500ppm/Air; and 105 L Zero Air ( <1 ppm THC); and 620 L of hydrogen fuel.

13 ERG. 2015. Modeling Database Containing Inputs and Results of Supplemental Proposal for MSW Landfill
NSPS.

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

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

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

### 6

4. Summary of Costs

Table 3 summarizes the testing and monitoring costs for controlled and uncontrolled landfills. These costs are added to the control costs in order to develop a total cost for each regulatory option, as discussed in the Cost and Emission Reductions Impacts memo. 17,18



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

Affected
Landfill a Annualize

d Initial
Performa

nce Test ($) Continu

ous Combus

tor
Monitori

ng Monthly

Wellhead
Monitori

ng Quarterly Surface Monitoring

Annualized Improved
Surface
Maintenance ($/acre) NMOC

Testing ($) Equipment

Rental ($/period) Annual

Labor
Cost ($/acre) Calibrati

on/Fuel
Costs ($/period)

Uncontrolled Landfills Using
Tier 1 NA NA NA NA NA NA NA $680

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

For 30

- meter traverse pattern
Controll ed (<=95 acres) $1,105 Already

included b Already

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

Controll ed (>95

acres up to 472 acres) $1,105 Already

included b Already

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

Controll ed (>472 acres) $1,105 Already

included b Already

included b $1100/mont

h $50.48 $414/yr NA NA

For 25

- foot traverse pattern with integrated sample calculation c

Controll ed (<=24 acres) $1,105 Already

included b Already

included b $125/day $198.76 $414/yr $200 NA

Controll ed (>24

acres up to 120 acres) $1,105 Already

included b Already

included b $350/week $198.76 $414/yr $200 NA

Controll ed (>120 acres) $1,105 Already

included b Already

included b $1100/mont

h $198.76 $414/yr $200 NA

a The listed acreages correspond to the length of time a monitor would need to be rented to complete surface monitoring for a landfill (daily, weekly, monthly), as described under Section 3.4 of this memo, Quarterly Surface Monitoring.

17 ERG. 2015. Cost and Emission Impacts Resulting from the Landfills NSPS Review.

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

### 7 b Already included in the control cost estimates. See the memo: ERG. 2015. Updated Methodology for Estimating Cost and Emission Impacts of MSW Landfills Regulations.

c In addition to these costs, it was assumed that a portion of the sites would not have a data logger to compile the field data automatically and compute the integrated sample calculations. The sites without a data logger would include an additional $49.69 per acre in labor to transpose the field data into an electronic format as discussed under Section 3.5 of this memo, Integrated Sample Calculations and Transposing Field Data into Electronic

Format.1



### MEMORANDUM

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

Programs Division, Fuels and Incineration Group

FROM: Eastern Research Group, Inc. (ERG)

DATE: July 2015

SUBJECT: Summary of Updated Landfill Dataset Used in the Cost and Emission Impacts Analysis of

Landfill Regulations

Introduction

The EPA is reviewing the new source performance standards (NSPS) and emission guidelines (EG) for municipal solid waste (MSW) landfills (40 CFR part 60, subpart WWW and 40 CFR part 60, subpart Cc, respectively). Currently, the regulations require landfills that are at least 2.5 million megagrams (Mg) and 2.5 million cubic meters in size and that have 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 the 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) in July 2014. The purpose of this memorandum is to document changes made to the July 2014 dataset to reflect more recent and comprehensive data.

Using the updated NSPS/EG dataset as an input, a Microsoft ® 

### Access database was developed to calculate the emission reductions and costs. The assumptions and calculations used in the database are detailed in the 2015 memorandum, Updated Methodology for Estimating Cost and Emission Impacts of MSW Landfill Regulations.

1. Landfill Data Sources

The landfill databases 2,3 

### used in the July 2014 NSPS proposal and ANPRM were updated using data from the Greenhouse Gas Reporting Program (GHGRP), select web searches, and input from EPA Regions and state and local regulatory agencies on landfills expected to undergo a modification in the next 5 years. Landfills that stopped accepting waste on or before November 8, 1987 are not affected by the EG. To accommodate this rule applicability criterion for the purposes of the dataset, any landfill closing before 1988 was removed from the consolidated dataset. After each data source was reviewed, data from the various sources were combined appropriately. The entire dataset was then reviewed to remove duplicate

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 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.2



### landfills across reporting years or between the various data sources. The sources for data updates are

described below.

1.1 GHGRP Data

GHGRP reporting year (RY) 2013 data are the primary data source for this updated dataset. Where landfills did not have data for RY2013, data from RY2012 were used. When both RY2012-RY2013 were missing, RY2011 data were used. RY2010 data were used only if no other reporting data were available. The data tables in Appendix B of this memorandum show which reporting year basis was used for various key data parameters. Information about the landfill itself, current and historical annual waste acceptance rates, as well as gas collection and control system (GCCS) data (as applicable) were incorporated into the database. These annual historical waste rate data serve as a significant improvement to the data input file used to generate emission estimates. 1,217 of 1,970 landfills in the dataset were from GHGRP Subpart HH data.

1.2 Website Research for Select LMOP Landfills

Several landfills in the July 2014 dataset did not report to GHGRP but had data available from EPA’s Landfill Methane Outreach Program (LMOP) to model emissions. These GHGRP non-reporters were reviewed further if the landfill had design capacities above 2 million Mg and had a calculated emission rate above 30 Mg/yr NMOC, which is approximately equivalent to the reporting threshold of 25,000 mtCO 2 

### e threshold uses in GHGRP. After researching these landfills online, the data inputs at four LMOP landfills were adjusted and updated in the new dataset. The other LMOP landfills (744 of the 1,970 landfills) remained unchanged from the July 2014 dataset.

1.3 Modification Analysis

In fall 2014, EPA contacted EPA Regions and state agencies to request information about modifications to existing landfills that were pending or occurred over the past 5 years. This voluntary outreach was conducted to identify landfills expected to increase their permitted design capacity after the July 2014 proposal, rendering them applicable to standards for new landfills. EPA requested data on the characteristics of landfills undergoing a modification, such as timing of expansion and permit approval, amount of waste capacity being added, and identification of landfills known to be expanding. In addition, EPA performed online searches for permit modification information for states expected to have landfills being modified where state regulatory authorities have shared this type of information.

As a result of these combined outreach efforts, 25 landfills were flagged in the NSPS/EG dataset as landfills anticipated to modify their design capacity in the next 5 years (2014-2018), and 18 of these 25 landfills were updated to include expansion data such as updated design capacity, updated estimated closure year,updated acreage, anticipated year of modification, or updated annual waste acceptance rates. Appendix A1 summarizes the modification data collected for each EPA Region, by state/district/territory. If technical data parameters were updated as part of the modification, these landfills are denoted with a flag field of “Actual” in the ModFlag data field. If no technical data were updated, the landfill is denoted with a flag field of “Actual Flag only” in the ModFlag data field.

For states where modification information was unavailable, EPA estimated the landfills expected to modify based on significant changes in design capacity values. For this analysis, significant change threshold was identified based on at least a 5 percent increase in capacity when comparing GHGRP Subpart HH RY2013 data to each of the three prior years (RY2010-RY2012). A total of 108 landfills were flagged as anticipated to modify their design capacity in the next 5 years using Subpart HH data, and these landfills are shown in Appendix A-2. While these landfills likely modified prior to the July 17, 2014 applicability date of Subpart XXX, the number and characteristics of these mods were used to approximate the number and types of3



### landfills undergoing modifications in the near future. These landfills are denoted as “Surrogate” in the ModFlag data field.

Collectively, from actual and surrogate modification information, a total of 133 landfills were identified as ones expected to modify their design capacity between 2014 and 2018. Cost and emissions impacts for these 133 landfills will be transferred from the EG to the NSPS in the year the modification is anticipated to commence construction. It is important to note that landfills with a post-expansion permitted design capacity below 2.0 million Mg were excluded from the modification analysis because size thresholds below 2.0 million Mg were not considered in the impacts analysis for the proposed Emission Guidelines.

While conducting the research for landfills expected to modify in the near future, five new landfills were identified and added to the dataset. Some of these landfills opened or significantly modified recently or were permitted but not yet constructed. As such, open years were estimated for the purpose of generating LFG emission curves. These landfills are shown in Appendix A-3.

2. Filling Data Gaps

For LMOP landfills, the basis of the fields in the dataset and gap filling did not change since the July 2014 dataset except when corrections were made from more recent web research as noted above. 4 

### For GHGRP landfills, there were significant updates made to the dataset and sometimes reported and calculated parameters did not agree with one another, or there were multiple methods for filling a data gap. This section documents how the parameters were finalized for the dataset.

2.1 Design Capacity

Design capacity is reported to GHGRP HH Landfills Info data table. Generally the reported value was used in the regulatory database unless one of the two conditions below were met:

1. The calculated waste-in-place (WIP) in 2013 (based on the sum of all annual waste acceptance rates) exceeded the reported design capacity. This happened for 63 landfills.

2. The calculated future annual waste acceptance rates (AWAR) were +/- 10% different than the most recently reported AWAR when using the following equation: AWAR = (Design Capacity - 2013 WIP)/(Estimated landfill closure year - 2013)

If either of these two criteria were met, the calculated WIP based on the reported estimated closure year of the landfill (if before year 2078) or the calculated WIP in year 2078 (the maximum year included in the regulatory analysis) was entered in lieu of the design capacity.

As a final step, the capacity was converted from metric tons to short tons to be consistent with how the other design capacities were stored in the database.

2.2 Current Area

The Landfill surface area containing waste is reported in the GHGRP HH Landfills Info data table and is

stored in the field Landfill Surface Area in the GHGRP Landfill Inventory table of the regulatory database.

If the area of the landfill with a GCCS (see Section 2.3) exceeded the area with waste, the current area was set equal to the GCCS area. If there were reported areas less than 40,000 m 2 

### or greater than 9,000,000 m 2



### ,

4 ERG 2014. Summary of Landfill Dataset Used in the Cost and Emission Impacts Analysis of Landfill Regulations.4



### these areas were deemed outliers based on the area distributions of the remainder of the dataset and compared to LMOP acreage data. Five landfills were identified as outliers and reviewed against reported acreages in the LMOP database and in each of the five cases the acreage in GHGRP was replaced with the reported current acreage data in the LMOP database.

As a final step, the area was converted from m 2 

### to acres to be compatible with the costing equations.

2.3 GCCS Area

The acreage of a landfill with a GCCS installed was computed using surface area data reported in the GHGRP HH_LNDFIL_WTH_GAS_CLCT_WST_DEP data table. The areas are reported with different surface type codes, with codes A2-A5 representing areas with a GCCS installed. The sum of these area types represents the total area with a GCCS installed. See the data field SumOfSurfaceArea-GCCSArea in the GHGRP Landfill Inventory table of the regulatory database.

If there were reported areas <40,000 m 2 

### (but not zero, which would represent no GCCS is installed) or >9,000,000 m

2



### , these areas were deemed outliers based on the area distributions of the remainder of the dataset. The data were reviewed and the reported well count in the GHGRP HH_GAS_COLLECTION_SYSTEM_DETLS data table were used to estimate the GCCS area, assuming a well density of 1 well per acre.

There were also three landfills that had a calculated GCCS area greater than zero but had a GCCS indicator flag indicating no system was installed. These three landfills were reviewed against LMOP data and one of the three landfills (Landfill ID# 528332) had its GCCS area changed to zero since the LMOP database indicated this project shutdown due to lack of gas.

As a final step, the area was converted from m 2 

### to acres to be compatible with the costing equations.

2.4 Design Area

The total design area of a landfill was computed by summing the various types of surface areas reported for landfills in the GHGRP HH_LNDFIL_WTH_GAS_CLCT_WST_DEP. The area types A1, A2, A3, A4, and A5 were summed to compute a design area in square meters. See the data field SumOfSurfaceAreaTotalDesignedArea in the Background Data: GHGRP Landfill Inventory table.

If the current area described in Section 2.2 exceeded the calculated design area, the design area was set equal to the current area. If the current area was equal to the design area and the landfill was still open, the design area was flagged as suspect and was recalculated using the equation below. Similarly, if there were calculated areas less than 40,000 m 2 

### or greater than 9,000,000 m 2 

### , these areas were deemed outliers based on the area distributions of the remainder of the dataset and the design area was recalculated using the equations below.

1. If ratio of 2013 WIP/Design Capacity <=1; Design area = current area 5 

### /(WIP/DC).

2. If the above calculation was in the suspected outlier threshold range of less than 40,000 m 2 

### or greater than 9,000,000 m 2



### , the calculated value was compared to the reported design capacity in
the LMOP database, if available.

3. If the ratio of 2013 WIP/Design Capacity is >1, the reported design and current acreages in the LMOP database were compared to the calculated design area.

5 Current area, as corrected according to Section 2.2.5



### As a final step, the area was converted from m 2 

### to acres to be compatible with the costing equations.

2.5 Depth

Waste depth data were reported in the GHGRP HH_LNDFIL_WTH_GAS_CLCT_WST_DEP data table for landfills with a GCCS installed. The average and maximum depths reported for each landfill in surface area types A2, A3, A4, and A5 were computed. Areas with zero depth were excluded from the averaging. These calculated data fields are stored in MaxOfWaste Depth and AvgOfWaste Depth in the Background Data: GHGRP Landfill Inventory table.

The calculated maximum depth of waste was used in the cost analysis to be conservative.

For landfills without a GCCS, the designed depth of the landfill was calculated using the following equation and an assumed waste density of 45 cubic feet per short ton.

  = 
	   × 45  



###  ÷ 35.315  



### $  

### × 1.1 

 ÷ 
	%&	$ '



### If there were reported or calculated depths less than 5 meters or greater than 300 meters, these depths were deemed outliers based on the waste depth distributions of the remainder of the dataset. The data were reviewed against the depths in the 2014 dataset and four of the values were changed to be consistent with the reported depths in the proposal dataset.

As a final step, the depth was converted from feet to meters to be compatible with the costing equations.

3. Model Landfills

In the July 2014 dataset, model landfills were based on the number and characteristics of landfills opening between 2003 and 2010 to project new landfills. The data sources for the landfill inventory were considered complete through year 2010. Since the majority of revised data were based on GHGRP RY2013, the data were now considered complete through year 2012. As a result, landfills opening between 2005 and 2012 in the GHGRP and LMOP databases were used to project new greenfield landfills opening between 2013 and

2018.

Similar to the methods used in the July 2014 dataset, it was assumed that the sizes and locations of landfills opening in the most recent complete 8 years of data (2005-2012) would be similar to landfills opening in the future (2013-2018). Based on this analysis, five model landfills were created to represent landfills opening in year 2013 and were assigned to the Emission Guidelines database with a prefix identifier of “EG” (example: landfill ID EG1). All five of the EG greenfield model landfills has a design capacity of at least 2.5 million Mg.

Eleven model landfills were created to represent landfills opening in 2014-2018 and these models were assigned to the NSPS database with a prefix identifier of “NSPS” (example: landfill ID NSPS1). Of the 11 model landfills, ten had a design capacity of at least 2.5 million Mg.

4. Final Dataset

Considering models and actual landfills from the GHGRP, LMOP, and other data sources, there are 1,986 landfills in the dataset. Of these, 147 landfills are in the EG database and 1,839 are in the NSPS database.6



### Appendix B 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 C provides a similar listing for the
data tables in the NSPS database. The contents of each dataset are available in a database format. 6,7

6 ERG. 2015. Modeling Database Containing Inputs and Results of Supplemental Proposal for MSW Landfill NSPS.

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

Guidelines.Appendix A-1: Summary of Modification Data CollectedList of Surrogate Mods based on Significant Changes in GHGRP Design Capacity between RY2013 and RY2010-RY2012Surrogate Mod DataUsed in ModelCount of TotalPending Mod LFsFlaggedCount of PendingMods LFs FlaggedWith ExpansionDataCount of Mod LFsFlagged UsingGHGRP DataMod InfoProvided byRegion/State?1CT0NoYes1MA44No1ME11No1NH11No1RI11No1VT0NoYes2NJ101YesNoEPA Region 2 provided partial modification datafor one NJ landfill.2NY313YesNoEPA Region 2 provided partial modification datafor 2 NY landfills.2PR22NoDid not receive modification data for landfills.2VI0NoYesDid not receive modification data for landfills.3DC0YesYesRegion 3 confirmed no modified landfills in DC3DE0NoYesDid not receive modification data for landiflls.3MD0NoYesDid not receive modification data for landiflls.3PA222YesYesRegion 3 provided data for PA.3VA111YesBased on permit data from VA DEQ website.3WV0YesYesRegion 3 provided info for WV4AL88YesNo4FL66YesNo4GA66YesNo4KY33YesNo4MS66YesNo4NC66YesNo4SC11YesNo4TN66YesNo5IL55NoDid not receive modification data for landiflls.5IN1010NoDid not receive modification data for landiflls.5MI77NoDid not receive modification data for landiflls.5MN33NoDid not receive modification data for landiflls.5OH111YesBased on permit data from OH EPA website.5WI77NoDid not receive modification data for landiflls inRegion 10 and data was not found on WI state6AR11No6LA55No6NM22No6TX545YesBased on permit data from TCEQ website.6OK444YesNoOK DEQ commented on this topic during thepublic comment period and provided modificationdata.7IA33No7KS11No7MO22No7NE22No8CO44No8MT11No8ND11No8SD0NoYes8UT11No8WY111YesNoWDEQ commented on this topic during the publiccomment process and EPA sent follow-up toWDEQ on 11/19/14 requesting permit files andsite identification.9AZ111YesYesRegion 9 provided data and permits for AZ.9CA333YesYesRegion 9 provided spreadsheet and hyperlink toCA data.http://www.calrecycle.ca.gov/Actions/Default.aspx?Grouped=False&TimeFrameIndex=3&ActionItemTypeCategoryID=13.9GU0YesYesRegion 9 provided data for GU9HI101YesYesRegion 9 provided data for HI.9NV202YesyesRegion 9 provided data for Nevada. Class II siteswere excluded as those are by definition smalllandfills in arid areas without much gas potential.10 AK0NoYes10ID11No10OR0NoYes10WA11No2518108133*Excluded mod info for landfills with a design capacity below 2.0 million Mg (after mod) from model since the options under consideration did not look at these small landfills..SUMMARY OF MODIFICATION DATA GAPS:Count of states using surrogate data (from GHGRP) due to lack of real data =31Count of states where no real data were received and surrogate data are not available from GHGRP =8Region StateNotes for Region/State Mod InfoMod Info fromRegion/StateComplete?Real Mod Data Used in ModelCount of TotalMod LFs Usedin Model*State WithoutReal Data andSurrogate DataNot Availablefrom GHGRP? (SeeAppx. A2)TOTAL LANDFILL COUNTDid not receive modification data for landiflls inRegion 1.Region 4 provided a partial list of air permitmodifications but modifications for increases inlandfill capacity were not available.Did not receive modification data for landiflls inRegion 7.Did not receive modification data for landiflls inRegion 8.Did not receive modification data for landiflls inRegion 10 and data was not available on ID, OR,and WA state websites.No response from EPA request to Region 6

### Appendix A-2: List of Surrogate Mods based on Significant Changes in GHGRP Design Capacity between RY2013 and RY2010-RY2012

CommentsFacilityIdentificationNumber

Facility NameState Abbreviation

Likely expansion in 2013 524935 CHASTANG SANITARY LANDFILL AL increase in multiple years 525965 Jefferson County Landfill No.1 AL increase in multiple years 524864 SALEM LANDFILL AL Likely expansion in 2013 535899 SHELBY COUNTY HIGHWAY 70 LANDFILL AL Possible expansion in 2012 525795 SOLID WASTE DISPOSAL AUTHORITY AL increase in multiple years 524870 Three Corners Landfill AL Likely expansion in 2013 522258 VEOLIA ES CEDAR HILL AL Likely expansion in 2013 522257 VEOLIA ES STAR RIDGE LANDFILL AL increase in multiple years 523990 CRITTENDEN COUNTY LANDFILL AR Likely expansion in 2011 525721 BROADACRE LANDFILL - FOUNTAIN LANDFILL CO Likely expansion in 2013 527715 Colorado Springs Landfill CO Likely expansion in 2013 527716 Midway Landfill CO Likely expansion in 2013 524833 NORTH WELD SANITARY LANDFILL CO increase in multiple years 527427 J.E.D. SOLID WASTE MANAGEMENT FACILITY FL Likely expansion in 2013 525172 Medley Landfill FL Likely expansion in 2013 525166 Naples Landfill FL increase in multiple years 524679 NEW RIVER SOLID WASTE ASSOCIATION FL Likely expansion in 2012 525168 Okeechobee Landfill FL Likely expansion in 2012 522526 PINELLAS COUNTY RESOURCE RECOVERY FL Likely expansion in 2013 523270 ATHENS & CLARKE COUNTIES-DUNLAP ROAD LF GA Likely expansion in 2013 525946 EAGLE POINT LANDFILL, LLC GA increase in multiple years 524491 Gordon County (Redbone Ridges) Landfill GA Likely expansion in 2011 524500 MURRAY COUNTY LANDFILL GA increase in multiple years 524985 SUPERIOR LANDFILL & RECYCLING CENTER GA Likely expansion in 2013 525947 Wolf Creek Landfill, LLC GA Likely expansion in 2011 525541 DICKINSON LANDFILL INC IA Likely expansion in 2013 523469 DUBUQUE METROPOLITAN SANITARY LANDFILL IA Likely expansion in 2012 523482 SCOTT AREA SANITARY LANDFILL IA Likely expansion in 2013 528699 FIGHTING CREEK FARM LANDFILL ID Likely expansion in 2013 522264 ADVANCED DISPOSAL ORCHARD HILLS LANDFILL INC IL Likely expansion in 2013 522266 ADVANCED DISPOSAL VALLEY VIEW LANDFILL INC IL Likely expansion in 2013 525149 DEKALB COUNTY LANDFILL IL Likely expansion in 2011 527806 Milam Recycling and Disposal Facility IL Likely expansion in 2012 526068 QUAD CITIES LANDFILL PHASE IV IL Likely expansion in 2013 522877 BARTHOLOMEW COUNTY LANDFILL II IN Likely expansion in 2012 524117 CGS Services Inc. IN Likely expansion in 2012 525687 HAYES LANDFILL IN Likely expansion in 2013 525164 JAY COUNTY LANDFILL IN Likely expansion in 2013 523490 LIBERTY LANDFILL IN Likely expansion in 2012 524681 MEDORA SANITARY LANDFILL IN Likely expansion in 2013 523487 OAK RIDGE RECYCLING & DISPOSAL FACILITY IN Likely expansion in 2012 523841 PRAIRIE VIEW RDF IN Likely expansion in 2013 522268 VEOLIA ES BLACKFOOT LANDFILL IN Likely expansion in 2013 522270 VEOLIA ES HOOSIER LANDFILL IN increase in multiple years 526337 DEFFENBAUGH INDUSTRIES, INC. KS Likely expansion in 2011 526821 BIG RUN LANDFILL KY Likely expansion in 2013 526424 BLUE RIDGE RECYCLING & DISPOSAL FACILITY KYLikely expansion in 2013 522273 VEOLIA ES MOREHEAD LANDFILL KY

likely expansion in 2013 523067 IESI TIMBERLANE LANDFILL LA Likely expansion in 2013 523054 LA SALLE/GRANT PARISH SANITARY LANDFILL LA Likely expansion in 2013 524950 Magnolia Landfill LA Likely expansion in 2013 523060 SABINE PARISH LANDFILL LA Likely expansion in 2013 523062 TENSAS PARISH LANDFILL LA Likely expansion in 2011 527428 BOURNE LANDFILL MA increase in multiple years 525317 CHICOPEE SANITARY LANDFILL MA Likely expansion in 2013 525307 GRANBY SANITARY LANDFILL MA increase in multiple years 525347 TAUNTON SANITARY LANDFILL MA increase in multiple years 524124 CROSSROADS LANDFILL ME Likely expansion in 2012 524818 GLEN\S SANITARY LANDFILL MI increase in multiple years 523754 HASTINGS SANITARY LANDFILL MI Likely expansion in 2013 524984 RIVERVIEW LAND PERSERVE MI Likely expansion in 2013 526626 SMITHS CREEK LANDFILL MI Likely expansion in 2012 525269 TRI-CITY RDF MI Likely expansion in 2013 524824 WASTE MANAGEMENT OF MICHIGAN INC MI Likely expansion in 2012 525804 WEXFORD COUNTY LANDFILL MI Likely expansion in 2012 524796 ELK RIVER SANITARY LANDFILL, INC. MN Likely expansion in 2012 527356 PONDEROSA LANDFILL/BLUE EARTH COUNTY MN Likely expansion in 2011 525539 SPRUCE RIDGE RESOURCE MGMT FACILITY MN Likely expansion in 2012 528397 CENTRAL MISSOURI LANDFILL MO Likely expansion in 2012 525185 COURTNEY RIDGE LANDFILL MO Likely expansion in 2013 524927 Central Landfill MS Likely expansion in 2013 524889 CHAMBERS OF MISSISSIPPI INC, CLEARVIEW ENVIRONMENTAL CONTROL FACILITY LANDFILL MS Likely expansion in 2013 527745 PINE RIDGE SANITARY LANDFILL MS Likely expansion in 2013 524944 WASTE MANAGEMENT OF MISSISSIPPI INC, PECAN GROVE LANDFILL AND RECYCLING CENTER A MS Likely expansion in 2013 524957 WASTE MANAGEMENT OF MISSISSIPPI INC, PLANTATION OAKS MUNICIPAL LANDFILL AND RECY MS increase in multiple years 524840 WASTE MANAGEMENT OF TUNICA LANDFILL INC MS Likely expansion in 2012 531797 GALLATIN COUNTY LOGAN LANDFILL MT increase in multiple years 524136 Coastal Regional Solid Waste Management Authority NC Likely expansion in 2012 524620 EAST CAROLINA REGIONAL LANDFILL NC increase in multiple years 530259 IREDELL CO-TWINS OAKS RD;3260 NC increase in multiple years 525055 ROBESON COUNTY LANDFILL NC increase in multiple years 526642 ROCKINGHAM COUNTY LANDFILL NC Likely expansion in 2012 524621 UPPER PIEDMONT REGIONAL LANDFILL NC increase in multiple years 525271 DAKOTA MUNICIPAL SOLID WASTE LANDFILL ND Likely expansion in 2011 522811 BLUFF ROAD LANDFILL NE Likely expansion in 2012 522814 Grand Island Regional Landfill NE Likely expansion in 2013 525361 WM of NH - TREE (Turnkey Landfill) NH Likely expansion in 2013 526122 CLOVIS REGIONAL SOLID WASTE FACILITY NM increase in multiple years 524968 SAN JUAN COUNTY REGIONAL LANDFILL NM Likely expansion in 2011 525162 El Coqui Landfill PR Likely expansion in 2011 525160 Mayaguez Landfill PR Likely expansion in 2012 525985 RHODE ISLAND Resource Recovery Corporation RI Likely expansion in 2012 524982 PALMETTO LANDFILL AND RECYCLING CENTER SC increase in multiple years 524948 BRADLEY COUNTY LANDFILL TN Likely expansion in 2013 523375 CARTER VALLEY LANDFILL TN Likely expansion in 2011 524875 CEDAR RIDGE LANDFILL TN increase in multiple years 524866 IRIS GLEN ENVIRONMENTAL CENTER TN increase in multiple years 523979 Matlock Bend Landfill TN increase in multiple years 524842 WEST CAMDEN SANITARY LANDFILL TN increase in multiple years 527957 WM - Tekoi Landfill UT Likely expansion in 2011 524918 WASTE MANAGEMENT GREATER WENATCHEE LANDF WA Likely expansion in 2013 522300 ADVANCED DISPOSAL GLACIER RIDGE LANDFILL LLC WILikely expansion in 2013 522296 ADVANCED DISPOSAL HICKORY MEADOWS LANDFILL, LLC WI

Likely expansion in 2013 523174 ADVANCED DISPOSAL MALLARD RIDGE LANDFILL, INC WI Likely expansion in 2011 529918 DANE CNTY LANDFILL SITE #2 RODEFELD WI Likely expansion in 2013 522738 MARATHON COUNTY LANDFILL WI Likely expansion in 2011 527676 Metro Recycling and Disposal Facility WI increase in multiple years 527678 Pheasant Run Recycling and Disposal Facility WI

### Appendix A-2: List of Surrogate Mods based on Significant Changes in GHGRP Design Capacity between RY2013 and RY2010-RY20122010-LandfillCapacity2011-LandfillCapacity2012-LandfillCapacity2013-LandfillCapacity 2013-2010-
Capacity-

%Diff 2013-2011-

Capacity-%Diff 2013-2012-

Capacity-

%Diff Maximum

%Diff
30,346,069 30,346,069 30,346,069 33,717,854 11% 11% 11% 11%
15,642,907 16,245,755 16,674,993 17,060,890 9% 5% 2% 9%
28,286,170 28,637,988 29,904,533 31,663,624 12% 11% 6% 12%
1,975,611 1,975,611 1,975,611 4,100,000 108% 108% 108% 108%
3,169,311 2,468,105 3,492,581 3,492,581 10% 42% 0% 42%
27,794,882 27,903,316 30,722,563 36,144,191 30% 30% 18% 30%
50,749,743 50,749,743 50,749,743 69,595,340 37% 37% 37% 37%
33,897,875 33,897,875 33,897,875 42,579,989 26% 26% 26% 26%
1,847,114 1,963,392 2,088,449 2,342,046 27% 19% 12% 27%
8,714,585 16,742,726 16,742,726 16,742,726 92% 0% 0% 92%
28,915,228 28,915,228 28,915,228 31,066,278 7% 7% 7% 7%
25,420,316 25,420,316 25,420,316 27,640,648 9% 9% 9% 9%
10,812,191 10,812,191 10,812,191 11,418,012 6% 6% 6% 6%
38,609,783 56,753,477 59,152,458 59,152,458 53% 4% 0% 53%
30,139,606 30,810,716 30,810,716 34,589,571 15% 12% 12% 15%
14,591,446 14,591,446 14,591,446 21,584,511 48% 48% 48% 48%
3,338,535 3,114,338 4,598,603 5,712,980 71% 83% 24% 83%
195,003,529 190,518,359 219,096,113 219,096,113 12% 15% 0% 15%

24,500,000 27,215,542 27,215,542 11% 0% 11%
4,515,012 4,515,012 4,515,012 6,118,141 36% 36% 36% 36%
25,643,028 25,643,028 25,643,028 42,426,014 65% 65% 65% 65%
8,668,640 9,386,753 9,732,277 13,086,323 51% 39% 34% 51%
7,461,977 10,796,888 10,622,373 10,604,882 42% -2% 0% 42%
7,092,785 15,599,830 15,599,830 16,379,821 131% 5% 5% 131%
8,876,770 8,876,770 8,876,770 9,801,675 10% 10% 10% 10%
4,740,461 5,358,225 5,358,225 5,358,225 13% 0% 0% 13%
5,394,289 5,394,289 5,394,289 6,473,152 20% 20% 20% 20%
8,754,086 8,754,086 9,887,232 9,887,232 13% 13% 0% 13%
2,110,000 2,110,000 2,110,000 3,283,104 56% 56% 56% 56%
32,876,375 32,876,384 32,876,375 46,097,439 40% 40% 40% 40%
6,392,969 6,392,969 6,392,969 15,833,215 148% 148% 148% 148%
3,597,068 3,597,068 3,597,068 6,089,219 69% 69% 69% 69%
22,301,957 36,780,626 36,780,626 36,780,626 65% 0% 0% 65%
3,724,842 3,724,842 21,200,046 21,200,046 469% 469% 0% 469%
5,307,669 5,307,669 5,307,669 5,557,444 5% 5% 5% 5%
4,451,000 4,451,000 18,811,000 18,811,000 323% 323% 0% 323%
3,597,750 3,597,750 3,856,091 3,856,091 7% 7% 0% 7%
17,819,149 17,819,149 17,819,149 19,315,957 8% 8% 8% 8%
26,761,066 26,761,066 26,761,066 28,253,198 6% 6% 6% 6%
11,021,480 11,021,480 13,580,528 13,580,528 23% 23% 0% 23%
21,792,207 21,792,207 21,792,207 23,317,662 7% 7% 7% 7%
20,528,566 20,528,566 22,435,591 22,054,186 7% 7% -2% 7%
22,227,575 22,227,575 22,227,575 27,798,568 25% 25% 25% 25%
7,620,354 7,620,354 7,620,354 8,388,717 10% 10% 10% 10%
33,935,741 33,935,742 57,371,430 58,876,290 73% 73% 3% 73%
30,519,036 43,235,299 43,235,299 43,235,299 42% 0% 0% 42%
6,136,386 6,136,386 6,136,386 8,741,279 42% 42% 42% 42%6,336,001 7,234,290 14% 14%

25,550,041 25,550,041 25,550,041 27,146,919 6% 6% 6% 6%
25,747,930 25,747,930 25,747,930 26,983,521 5% 5% 5% 5%
21,021,335 21,021,335 18,342,365 26,508,619 26% 26% 45% 45%
2,294,161 2,294,161 2,294,161 2,407,683 5% 5% 5% 5%
10,282,450 10,282,450 10,282,450 14,295,996 39% 39% 39% 39%
1,960,043 2,121,898 2,121,898 2,121,898 8% 0% 0% 8%
10,385,896 10,385,896 11,539,884 12,693,873 22% 22% 10% 22%
5,276,315 5,276,315 5,276,315 5,569,444 6% 6% 6% 6%
3,411,753 3,619,158 3,667,284 3,763,537 10% 4% 3% 10%
9,230,136 9,546,779 9,930,185 10,062,458 9% 5% 1% 9%
17,508,665 17,508,666 18,423,665 18,423,665 5% 5% 0% 5%
3,278,660 3,465,780 3,490,186 3,490,186 6% 1% 0% 6%
28,633,990 28,633,990 28,633,990 35,380,208 24% 24% 24% 24%
11,058,412 11,058,412 11,058,412 27,010,568 144% 144% 144% 144%
12,005,048 12,005,048 19,073,264 19,073,264 59% 59% 0% 59%
10,873,045 10,701,296 10,701,296 19,044,995 75% 78% 78% 78%
4,569,943 4,569,943 11,780,000 11,780,000 158% 158% 0% 158%
20,593,329 20,593,330 24,822,843 24,822,843 21% 21% 0% 21%
1,606,822 1,606,822 2,241,234 2,241,234 39% 39% 0% 39%
15,208,400 20,556,290 20,556,290 20,556,290 35% 0% 0% 35%
6,555,321 6,555,321 10,646,230 10,646,230 62% 62% 0% 62%
17,205,852 17,205,852 20,676,470 20,676,470 20% 20% 0% 20%
9,607,891 9,607,891 9,296,053 12,317,809 28% 28% 33% 33%
17,753,037 17,753,037 17,270,824 21,650,046 22% 22% 25% 25%
6,638,581 6,638,581 6,148,065 8,565,911 29% 29% 39% 39%
15,752,813 15,752,813 15,316,144 19,691,017 25% 25% 29% 29%
8,052,019 7,625,613 7,625,613 10,065,024 25% 32% 32% 32%
20,966,134 21,255,989 21,255,989 22,946,806 9% 8% 8% 9%
2,410,000 2,410,000 3,122,738 3,122,738 30% 30% 0% 30%
2,740,996 2,914,754 3,080,508 3,242,207 18% 11% 5% 18%
16,398,511 16,398,511 21,811,177 21,811,177 33% 33% 0% 33%
3,484,522 3,625,364 3,769,077 3,916,386 12% 8% 4% 12%
2,081,954 2,343,114 2,219,800 2,302,487 11% -2% 4% 11%
2,120,668 2,199,220 2,277,617 2,352,933 11% 7% 3% 11%
5,564,973 5,564,973 17,387,198 17,387,198 212% 212% 0% 212%
2,471,413 2,551,408 2,630,561 2,630,561 6% 3% 0% 6%
10,909,100 12,064,447 12,064,447 12,064,447 11% 0% 0% 11%
1,869,102 1,869,102 3,965,826 3,965,826 112% 112% 0% 112%
15,963,032 15,620,092 14,770,452 39,268,871 146% 151% 166% 166%
2,169,605 2,169,605 2,169,605 9,911,400 357% 357% 357% 357%
12,991,590 15,481,561 15,888,887 16,255,571 25% 5% 2% 25%
9,171,106 15,987,633 15,987,633 15,987,633 74% 0% 0% 74%
355,782 3,246,941 3,246,941 3,246,941 813% 0% 0% 813%
21,659,427 21,659,427 36,768,885 36,768,885 70% 70% 0% 70%
17,996,695 17,996,695 20,024,491 20,024,491 11% 11% 0% 11%
10,418,872 11,118,348 11,545,232 11,619,893 12% 5% 1% 12%
13,303,504 13,303,504 13,303,504 14,438,047 9% 9% 9% 9%
4,646,942 6,615,452 6,507,002 6,507,002 40% -2% 0% 40%
9,605,204 9,662,721 10,651,326 10,352,915 8% 7% -3% 8%
2,909,821 3,570,953 3,741,949 3,883,798 33% 9% 4% 33%
19,412,633 19,869,085 19,869,085 23,493,851 21% 18% 18% 21%

41,947,579 42,164,082 45,542,397 9% 8% 9%
31,545,873 37,717,892 39,888,859 39,175,814 24% 4% -2% 24%
15,002,659 15,002,663 15,002,659 15,685,326 5% 5% 5% 5%6,845,618 6,845,618 6,845,616 19,127,591 179% 179% 179% 179%

14,742,659 14,742,663 14,742,663 16,250,731 10% 10% 10% 10%
4,065,046 4,254,696 4,254,696 4,254,696 5% 0% 0% 5%
3,486,919 3,486,919 3,486,919 5,967,311 71% 71% 71% 71%
26,119,663 29,024,701 29,024,701 29,049,382 11% 0% 0% 11%
28,345,432 35,357,806 35,357,806 35,497,560 25% 0% 0% 25%Appendix A-3: List of Additional Landfills for Dataset Identified During Fall 2014 Modification Data GatheringFRS_ID Landfill_IDLandfill_NameLandfill_CityLandfill_County FIPSLandfill_StateRD&DPermitLandfill_Year_OpenedLandfill_Closure_Year ModFlagModStartYearLandfill_Current_StatusLandfill_Designed_AreaLandfill_Designed_DepthLandfill_Design_Cap_tonsLandfill_WIPLandfill_WIP_YearLandfill_Ann_WARLandfill_Ann_WAR_YearLandfill_SubmitterLandfill_SourceLandfillOwnerTypeLandfillOwnerOrganizatiN-AZ-1DurhamRegionalLandfillApacheJunction Pinal 04021 AZ 2020 2130183.85 194.425 28596100NewNovember2014 PrivateWasteTechnologies, LLCN-AZ-2 N-AZ-2MaranaRegionalLandfill Marana Pima 04019 AZ2013 2138415 225.904 75000000NewNovember2014 PrivateWasteManagementN-AZ-3Silver BarMineRegionalLandfill Florence Pinal 04021 AZ2018 2084226 467.367 84500000NewNovember2014 PrivateAK MineralMountain,WelchMineralMountain,POGMineralMountain110005996663 N-CA-1MesquiteRegionalLandfill BrawleyImperialCounty 06025 CA2000 2097open2290 50 1300000007300000NewNovember2014 PublicCounty ofLosAngelesSanitationDist. 2N-OK-1DilworthLandfill Kay 40071 OK 2014 2083155 34.723 430560062400NewNovember2014 PrivateDilworthDevelopmentCompany1 From: Thundiyil, Karen <Thundiyil.Karen@epa.gov>
Se nt: Thursday, July 09, 2015 9:20 AM
T o: Grossman, Andrea
C c: Marsh, Karen; Ward, Hillary; Cozzie, David
Su bject: Landfills review - Tier 4 info

* ** EO 12866 Deliberative – Do not cite, quote or release during the review ***



### Hi Andrea,

Here’s the requested information about Tier 4:

1. Tier 4 is a proposed option for the Emission Guidelines; it provides an alternative site- 

### specific emission threshold determination for when a gas collection and control system (GCCS) is required.

2

. We do not believe proposing the Tier 4 option for existing landfills would alter our emission reduction estimate. The rule does not allow corrective action for a Tier 4 exceedance. As such, landfills would not be able to perpetually avoid installing controls. Upon exceedance of the 500ppm threshold, controls are required.

3. Given the site-specific nature of this option, it is unknown how many landfills would use this option and we are unable to predict the change in timing of controls that could occur as a result of its use.

4. The emission reductions were estimated using modeled LFG rates and NMOC concentrations to determine the timing of GCCS installation and removal. The model inputs do not factor in site-specific surface concentrations as the frequency of use of this approach is currently unknown. See Section 2.3 of the draft Updated Methodology for Estimating Cost and Emission Impacts of MSW Landfill Regulations memo.

5. Tier 4 provides a surface measurement option which was supported by industry, small entities, and environmental organizations.

If you have additional questions about the topic, the program can be available for a call.

Karen.