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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: Preliminary Cost and Emissions Impacts for Review of the MSW Landfills Emission 

Guidelines 

Introduction 

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

costs and emission reductions for potential adjustments to the criteria and timeframes for landfill gas 

(LFG) collection and control as part of the review of the emission guidelines (EG) for municipal solid 

waste (MSW) landfills (40 CFR part 60, subpart Cc). These impacts were calculated for existing landfills 

that accepted waste after 1987 and commenced construction, reconstruction, or modification before the 

proposal date of the related 2014 review of the new source performance standards (NSPS) at 40 CFR part 

60, subpart XXX. The equations and data inputs used to estimate the impacts are discussed in other 

memoranda in the docket. 1,2

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

the next 10-year period (2014-2023) using an interest rate of 7 percent. Because existing landfills are in 

various phases of their life cycle (i.e., some are no longer accepting wastes, some opened recently, some 

already have controls installed), an average over a 10-year period is an appropriate time period to analyze 

the effects of each preliminary option. 

The results are presented for several preliminary options as incremental impacts relative to 

impacts associated with the current requirements of 40 CFR part 60, subpart WWW and the state and 

federal plans implementing the EG (40 CFR part 60, subpart Cc). These results provide some background 

data on the Advanced Notice of Proposed Rulemaking (ANPRM) for the review of the MSW landfills 

EG. 

Landfill-specific details of each preliminary option under consideration are documented in the 

modeling database.3

 This memorandum is organized as follows: 

1.0 Overview of Preliminary Regulatory Options 

2.0 Estimating Preliminary Cost Impacts 

3.0 Estimating Preliminary Emission Reductions Impacts 

4.0 References 

Appendix A: Index of Preliminary Regulatory Options for Landfill EG Review 

Appendix B: Summary of Preliminary Cost and Emission Reduction Impacts 
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1. Overview of Preliminary Regulatory Options 

Descriptions of the current regulatory baseline and preliminary alternative options are included in 

this section. 

1.1 Baseline 

 Currently, 40 CFR part 60, subpart WWW and the state and federal plans implementing 40 CFR 

part 60, subpart Cc require 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. 

 The database model estimated GCCS that would be in place as a result of the current rule 

(baseline). GCCS installation and removal were modeled based on the timeline and 

requirements of the current rule. The regulatory baseline requires landfills to install 

GCCS when the landfill exceeds the emission threshold and design capacity threshold. 

The current rule was amended in 1998 and allowed 30 months (approximately 3 years) 

for compliance. Therefore, GCCS were assumed to be in place for landfills exceeding the 

current rule’s thresholds since 2001. GCCS removal was modeled based on rule 

requirements that landfills are allowed to remove GCCS when the emissions are below 

the emissions threshold, the landfill is closed, and the controls have been in place for at 

least 15 years. 

 Based on the characteristics of the 1,832 landfills with sufficient data to analyze preliminary cost 

and emission impacts, approximately half (954) of these landfills are expected to meet the design 

capacity threshold. Of these 954 landfills, 691 are expected to have a gas collection and control 

system (GCCS) installed during one or more years over the next 10-year period. 

1.2 Preliminary Regulatory Options 

The impacts of several regulatory options were analyzed. The options varied one or more of the 

control parameters and/or lag times. Lag time refers to the time allotted to install and expand the GCCS 

after the threshold has been exceeded and as the landfill expands to accept waste in new areas not covered 

by the initial GCCS installation. 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. 

 One option reduced 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, additional landfills are expected to exceed the NMOC emission 

threshold and install a GCCS by 2023. 

 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. These options required earlier installation of controls and achieved 

additional reductions as compared with the baseline. 

 Another option increased 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 were subject to the rule but had not yet 

exceeded the emission threshold. 
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 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 were not as significant over time. 

Further, when installing controls a year earlier as a result of a shortened lag time, the initial 

system would 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 achieved 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. 

2. Estimating Preliminary Cost Impacts 

For each preliminary option, the cost impacts analysis compared net average annualized costs of 

the baseline over the 10-year period to the net annualized costs of each preliminary option over the same 

time period. The costs incorporated 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 the cost and 

emission reduction methodology memorandum.2

 Detailed landfill-specific cost estimates for each affected 

landfill are shown in the landfill modeling database outputs.3 

In addition to the control costs to comply with the regulation, the costs also included 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. Although testing and monitoring costs were not estimated for 

each option as part of the background information supporting the ANPRM, these costs are expected to be 

nominal relative to the costs to install and operate the GCCS. The EPA intends to estimate the testing and 

monitoring costs for the review of the emission guidelines. 

The costs and revenues associated with the baseline and the incremental costs associated with the 

other preliminary regulatory alternatives as well as a summary of each individual cost component are 

shown in Appendix B. 

3. Estimating Preliminary Emission Reduction Impacts 

The emission reductions of each preliminary regulatory option are presented in terms of NMOC 

(Mg/yr) and methane ((Mg/yr) and carbon dioxide equivalents (Mg CO2e/yr) based on a global warming 
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potential of 25 for methane). The detailed emission reductions equations are shown in the cost and 

emission reduction methodology memorandum.2

 

The overall cost effectiveness of the baseline is provided for reference and was calculated by 

dividing the total emission reductions achieved under the baseline by the total costs associated with the 

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

costs of the proposal by the incremental reductions of the proposal. 

Additional details about the emission impacts and cost effectiveness of other preliminary 

regulatory alternatives can be found in Appendix B. 

4. 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. Modeling Database Containing Inputs and Preliminary Impacts for Review of 

the MSW Landfill Emission Guidelines.
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Appendix A: Index of Preliminary Regulatory Options for Landfill EG 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 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