### 1 MEMORANDUM

TO: Hillary Ward, U.S. Environmental Prot ection 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 pr eliminary results of the analysis to estimate costs and emission reductions for potential adjustme nts 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 construc tion, reconstruction, or modification before the proposal date of the related 2014 review of the ne w 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) usi ng 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-y ear period is an appropriate time period to analyze the effects of each preliminary option.

The results are presented for several preliminar y 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 Rulemaki ng (ANPRM) for the review of the MSW landfills EG.

Landfill-specific details of each preliminary optio n 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 Regul atory Options for Landfill EG Review Appendix B: Summary of Preliminary Cost and Emission Reduction Impacts

### 2 1. Overview of Preliminary Regulatory Options



### D escriptions 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 th e 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 require d 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 remova l were modeled based on the timeline and requirements of the current rule. The regulator y baseline requires landfills to install GCCS when the landfill exceed s the emission threshold and design capacity threshold. The current rule was amended in 1998 and a llowed 30 months (approximately 3 years) for compliance. Therefore, GCCS were assume d 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 w ith sufficient data to analyze preliminary cost and emission impacts, approximately half (954) of these landfills are expect ed to meet the design capacity threshold. Of these 954 landfills, 691 are ex pected 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 an alyzed. The options varied one or more of the control parameters and/or lag times. Lag time refers to the time allotte d to install and expand the GCCS after the threshold has been exceed ed 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 require ments. 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 th e 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 installa tion 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.

### 3  Some options shortened the initial lag times for in stalling the GCCS. For example, shortening the initial lag time from 3 years to 2 years would requir e some landfills to install the controls earlier and would also trigger an earlier installation sch edule 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 earlie r 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 s ubsequent expansion is on a shorter 2-year cycle. However, the same subset of landfills w ould still require controls to be installed under either lag time.

 Other options shortened both the initial and expansion lag times. Th is combination of initial and expansion lag time reductions achieved the larg est amount of reductions over time because they achieved an earlier installation start date, pair ed with a tighter frequency of subsequent expansions.

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

2. Estimating Preliminary Cost Impacts

For each preliminary option, the co st impacts analysis compared net average annualized costs of the baseline over the 10-year period to the net annuali zed 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 re levant, 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 c ontrol 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 w ith preparation of NMOC emission rate reports, conducting initial performance tests, monthly wellhead monitoring, continuous combustor monitoring, and quarterly surface emission monitoring. Although tes ting and monitoring costs were not estimated for each option as part of the background information sup porting the ANPRM, these cost s 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 regu latory option are presented in terms of NMOC (Mg/yr) and methane ((Mg/yr) and carbon dioxide equivalents (Mg CO 2 e/yr) based on a global warming

### 4 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 a nd 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.

### A-1 Appendix A: Index of Preliminary Regu latory 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