From: Ward, Hillary Sent: Thursday, June 26, 2014 11:13 AM To: 'Higgins, Cortney' Cc: Cozzie, David Subject: Supporting Documentation for Landfills ANPRM Hi Cortney, Per your request, please see the attached file. Regards, Hillary Ward US EPA, Sector Policies and Programs Division Fuels and Incineration Group (919)541 ‐3154

Attachments: DRAFT Modeling Database Containing Inputs and Preliminary Impacts for Review of the MSW Landfill Emission Guidelines.zip (database not included in email correspondence but is available in electronic copy in Docket office)From: Ward, Hillary Sent: Thursday, June 26, 2014 10:57 AM To: 'Higgins, Cortney' Cc: Cozzie, David Subject: Supporting Documentation for Landfills ANPRM Hi Cortney, Per your request, please see the a ttached documents. Hillary Ward US EPA, Sector Policies and Programs Division Fuels and Incineration Group (919)541 ‐3154

Attachments: Draft Landfills Industry Profile 061014 ANPRM.pdf; Draft EG Impacts 061914.pdf; DRAFT Appendix B 060914.xlsx1

MEMORANDUM

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

Programs Division, Fuel and Incineration Group

FROM: Eastern Research Group, Inc. (ERG)

DATE: April 2014

SUBJECT: Preliminary Cost and Emissions Impacts for Review of t he MSW Landfill s Emission

Guidelines

Introduction
The purpose of this memorandum is to present the preliminary results of the analysis to estimate cost s and emission reductions for potential adjustments to the criteria and timeframes for landfill gas (LFG) collection and control as part of the r eview of the emission guidelines (EG) for m unicipal s olid

w aste (MSW) l andfills (40 CFR part 60, subpart Cc) . These impacts were calculated for existing landfills that accepted waste after 1987 and commence d construction, reconstruction, or modification before the proposal date of the related 2014 review of the new source performance standards (NSPS) at 40 CFR p art 60, subpart XXX

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

memora nda 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 (2 014

- 2023 ) using an interest rate of 7 percent

. Because existing landfills are in vari ous phases of their life cycle (i.e., some are no lo nger 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 eff ects 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 preli minary 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 E stimating 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 Impacts2

1. Overview of Preliminary Regulatory Options

D escription s of the current regulatory baseline and preliminary alternativ e 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 de sign capacity of 2.5 million m egagrams (Mg) and 2.5 million cubic meters or greater to report their NMOC emission rate. When the NMOC emission rate exceeds 50 Mg/yr, a landfill is required to control its emissions within 30 months of submitting a report in which the NMOC emissions exceeded the threshold.

 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 require ments of the current rule. T he regulatory baseline requires l andfills to install GCCS when the landfill exceeds the emission threshold and design capacity threshold

. T he 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 l andfills are allowed to remove GCCS when the emissions are below the emissions threshold , the landfill i s 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 mee t 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 s everal regulatory options were a nalyzed

. 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 was te 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. T he number of landfills subject to the rule remains the same as the baseline because the design capacity threshold remains the same. However , additional lan dfills are expected to exceed the NMOC emission threshold and install a GCCS by 2023.

 Some o ptions incorporat ed a further reduction in the NMOC threshold, to 34 Mg/yr. These options also made a corresponding reduction in the design capacity threshold, from 2.5 m illion Mg to 2.0 million Mg in order to include any smaller landfills that might exceed this lower NMOC emission threshold. These options required earlier installation of controls and achieved additional reductions as compared with the baseline.

 Another option increas ed the design capacity threshold t o 3.0 milli on Mg from 2.5 million Mg along with a reduced NMOC emission threshold of 40 Mg/yr. This option evaluated any potential reduction in the reporting burden from landfills that were subject to the rule but ha d not yet exceeded the emission threshol d.3

 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 sched ule for each subsequent expansion. However, because the same subset of landfills would require controls to b e installed under the current 3

- year lag times, the overall ad ditional emission reductions were not a s significant over time. Further, when installi ng 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 shorten ed 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, pai r ed with a tighter frequency of subsequent expansions.

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

2

. Estimating Preliminary Cost Impacts

For each preliminary option, the cost impacts analysis compare d 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 incorporate d 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 e stimates 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 include d 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,

an d 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 operat e the GCCS. The EPA intends to estimate the testing an d 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

Th e emission reductions of each preliminary regulatory option a re presented in terms of NMOC (Mg/yr) and methane ( ( Mg/yr ) and carbon dioxide equivalents (Mg CO 2 e/yr) based on a global warming4

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

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

3. ERG

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

- 1

Appendix A: Index of Preliminary Regulatory Options f or 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 yearsAppendix B-1 Summary of Preliminary Cost Impacts of Regulatory Options for EG Review, Average 2014-2023

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

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

**Flares Avg.**  **Annualized Mobilization/I** 

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

**Costs to Operate**  **Blowers Avg. Annual**  **O&M for Landfills with**  **LFG Engines Avg. Annual**  **O&M for**

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

1 Baseline (2.5/50) 608,994,245 37,737,214 4,630,505 96,672,387 140,306,997 187,739,570 518,186,341 2,994,700 203,328,398 1,800,590,356 1,407,394,161 393,196,196

2 2.5/50; IL = 2 years 616,096,219 38,280,231 4,714,221 97,766,012 142,084,718 189,490,001 524,229,330 3,048,842 205,904,615 1,821,614,189 1,425,783,444 395,830,745

3 2.5/40 634,612,079 39,928,490 5,172,740 102,462,584 151,816,342 194,227,485 539,984,267 3,345,381 220,007,371 1,891,556,739 1,467,606,589 423,950,149

4 2.5/40; IL = 2 years; EL = 2 years 642,369,294 40,589,477 9,908,089 105,919,517 157,038,795 199,705,434 546,584,794 3,420,385 227,575,582 1,933,111,367 1,487,316,224 445,795,143

5 2.0/40 635,859,151 40,138,535 5,234,183 102,785,431 152,624,740 194,787,753 541,045,387 3,385,119 221,178,875 1,897,039,174 1,470,709,135 426,330,038

6 2.0/40; IL = 2 years 643,806,598 40,835,622 5,359,373 104,113,459 154,926,369 196,888,640 547,807,780 3,466,083 224,514,322 1,921,718,248 1,490,890,062 430,828,185

7 2.0/34 648,329,879 41,434,393 5,592,089 106,268,069 160,038,453 198,502,463 551,656,589 3,616,588 231,922,591 1,947,361,113 1,497,976,638 449,384,476

8 2.5/34; IL = 2 years; EL = 2 years 656,974,841 42,227,743 10,767,097 110,100,287 166,046,510 204,323,326 559,012,490 3,716,925 240,629,275 1,993,798,494 1,520,590,281 473,208,213

9 3.0/40 633,047,953 39,694,751 5,105,921 102,094,890 150,782,579 193,618,987 538,653,371 3,302,167 218,509,276 1,884,809,895 1,463,870,141 420,939,754

10 3.0/40; EL = 2 years 633,047,953 39,694,751 9,565,637 104,184,166 153,678,210 196,969,171 538,653,371 3,302,167 222,705,532 1,901,800,958 1,463,870,141 437,930,817

11 2.0/50 609,564,939 37,828,342 4,655,850 96,821,269 140,618,394 187,979,252 518,671,938 3,011,091 203,779,664 1,802,930,740 1,409,001,443 393,929,297 12 2.5/50; EL = 2 years 608,994,245 37,737,214 8,674,974 98,702,997 143,086,604 191,033,938 518,186,341 2,994,700 207,356,515 1,816,767,527 1,407,394,161 409,373,366

IL = Initial Lag EL = Expansion Lag Totals

Average Annual Control CostsAppendix B-1 Summary of Preliminary Cost Im

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

1 Baseline (2.5/50)

2 2.5/50; IL = 2 years

3 2.5/40

4 2.5/40; IL = 2 years; EL = 2 years

5 2.0/40

6 2.0/40; IL = 2 years

7 2.0/34

8 2.5/34; IL = 2 years; EL = 2 years

9 3.0/40

10 3.0/40; EL = 2 years

11 2.0/50 12 2.5/50; EL = 2 years

IL = Initial Lag EL = Expansion Lag **Avg. Annualized Control Costs**  **Annual Revenue from LFG**  **Engines Net Avg.**  **Annualized Control Cost** 

21,023,833 18,389,283 2,634,550

90,966,382 60,212,429 30,753,954

132,521,010 79,922,063 52,598,947

96,448,817 63,314,974 33,133,843

121,127,891 83,495,901 37,631,990

146,770,757 90,582,477 56,188,280

193,208,137 113,196,120 80,012,017

84,219,539 56,475,980 27,743,559

101,210,602 56,475,980 44,734,621

2,340,384 1,607,282 733,101 16,177,171

- 16,177,171 Incrementals**Internal Option #**  **Option Name Average**  **Annual NMOC**  **Reductions**

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

**(Mg/yr) Average**  **Annual Methane**  **Reductions (Mg CO2e/yr)**  **Incremental Average**  **Annual NMOC**  **Reductions**

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

**(Mg/yr) Incremental**  **Average Annual**  **Methane Reductions**  **(Mg CO2e/yr)**  **$/Mg NMOC $/Mg CH**  **4 $/Mg**  **CO2e** 1 Baseline (2.5/50) 54,854 8,534,089 213,352,229 7,168 46 1.8 2 2.5/50; IL = 2 years 55,418 8,621,947 215,548,682 565 87,858 2,196,453 4,665 30 1.2 3 2.5/40 56,798 8,836,601 220,915,018 1,944 302,512 7,562,790 15,816 102 4.1

4 2.5/40; IL = 2 years; EL = 2

years 58,479 9,098,095 227,452,367 3,625 564,006 14,100,139 14,509 93 3.7 5 2.0/40 56,964 8,862,421 221,560,523 2,110 328,332 8,208,294 15,700 101 4.0 6 2.0/40; IL = 2 years 57,639 8,967,419 224,185,481 2,785 433,330 10,833,253 13,511 87 3.5 7 2.0/34 58,026 9,027,675 225,691,886 3,173 493,586 12,339,657 17,711 114 4.6

8 2.5/34; IL = 2 years; EL = 2

years 59,810 9,305,166 232,629,139 4,956 771,076 19,276,910 16,144 104 4.2 9 3.0/40 56,610 8,807,259 220,181,472 1,756 273,170 6,829,243 15,801 102 4.1 10 3.0/40; EL = 2 years 57,604 8,962,038 224,050,947 2,751 427,949 10,698,719 16,263 105 4.2 11 2.0/50 54,928 8,545,582 213,639,559 74 11,493 287,330 9,924 64 2.6 12 2.5/50; EL = 2 years 55,831 8,686,157 217,153,919 977 152,068 3,801,691 16,551 106 4.3 Incremental Total Cost Effectiveness Appendix B-2 Summary of Preliminary Emission Impacts of Regulatory Options for EG Review, Average 2014-2023*** Draft

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# Municipal Solid Waste Landfills Industry Profile

U

. S

. Environmental Protection Agency Office of Air and Radiation Office of Air Quality Planning and Standards Research Triangle Park, NC 27711

June 201 4*** Draft

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ii CONTACT INFORMATION

This document has been prepared by staff from the Office of Air and Radiation, U.S. Environmental Protection Agency. Questions related to this documen t should be addressed to Alexander Macpherson , U.S. Environmental Protection Agency, Office of Air and Radiation, Office of Air Quali ty Planning and Standards, C439

- 02 , Research Triangle Park, North Carolina 27711 (email: macpherson.alex@epa.gov ).

ACKNOWLEDGEMENTS

In addition to EPA staff from the Office of Air Quality Planning and Standards and the Office of Atmospheric Programs with the U.S. EPA Office of Air and Radiation, Eastern Research Group, Inc. (ERG) contributed data and analysis to this document.*** Draft

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iii TABLE OF CONTENTS

T ABLE OF C ONTENTS
................................ ................................ ................................ .................... III L IST OF T ABLES
................................ ................................ ................................ ............................. IV L IST OF F IGURE S
................................ ................................ ................................ ............................ V I NDUSTRY P ROFILE
................................ ................................ ................................ ........................ 1
1 I NTRODUCTION

................................ ................................ ................................ ................................ ................ 1 2 W ASTE S TREAM B ACKGROUND

................................ ................................ ................................ ....................... 3 2.1 Municipal Waste

................................ ................................ ................................ ................................ ......... 3 2.1.1 Generation of Municipal Solid Waste

................................ ................................ ............................... 3 2.1.2 Landfills Covered Under the NSPS/EG

................................ ................................ ............................ 4 2.1.3 Trends in Per Capita Waste Sent to Landfills

................................ ................................ ................... 4 2.1.4 Composition of MSW Sent to Landfills

................................ ................................ ............................ 5 2.2 Consolidation of Waste Streams

................................ ................................ ................................ ................. 7 3 D ISPOSAL F ACILITY B ACKGROUND

................................ ................................ ................................ .................. 8 3.1 Technical Background on Landfills as a Source Category

................................ ................................ ......... 8 3.1.1 Landfill Siting and Permitting

................................ ................................ ................................ ........... 8 3.1.2 Landfill Operations

................................ ................................ ................................ ........................... 9 3. 1.3 Landfill Closure

................................ ................................ ................................ .............................. 10 3.1.4 Management of Liquids

................................ ................................ ................................ .................. 10 3.2 Ownership and Characteristics of Landfills

................................ ................................ .............................. 11 4 C OSTS AND R EVENUE S TREAMS FOR L ANDFILLS

................................ ................................ ........................... 15 4.1 Major Cost Components for Landfills

................................ ................................ ................................ ...... 15 4.2 Landfill Revenue Sources

................................ ................................ ................................ ......................... 18 5 A IR P OLLUTANT E MISSIONS FROM L ANDFILLS

................................ ................................ .............................. 21 5.1 NMOC in LFG

................................ ................................ ................................ ................................ ......... 21 5.2 Methane in LFG

................................ ................................ ................................ ................................ ....... 22 5.3 Criteria Pollutants from Combustion of LFG

................................ ................................ ........................... 23 6 T ECHNIQUES FOR C ONTROLLING E MISSIONS FROM L ANDFILLS

................................ ................................ ..... 24 6.1 Introduction

................................ ................................ ................................ ................................ .............. 24 6.2 Gas Collection Systems

................................ ................................ ................................ ............................ 24 6. 3 Destruction

................................ ................................ ................................ ................................ ............... 26 6.4 Utilization

................................ ................................ ................................ ................................ ................. 27 6.4.1 Technologies

................................ ................................ ................................ ................................ ... 27 6.4.2 Revenues and Incentives

................................ ................................ ................................ ................. 32 7 R EFERENCES

................................ ................................ ................................ ................................ .................. 35*** Draft

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iv LIST OF TABLES

Table 1 Generation and Discards of MSW, 1960 to 2010 (in pounds per person per day)

................................ ......... 5 Table 2 Materials Discarded a In the MSW Stream, 1960 to 2010 (in thousands of tons)

................................ ........... 7 Table 3 Top 5 Waste Management Companies That Own or Operate MSW Landfills in 2011

................................ 13 Table 4 Typical Costs Per Acre for Components of Landfill Construction (D uffy, 2005a)

................................ ...... 16 Table 5 Average Regional and National Per

- Ton Tip Fees (Rounded): 1995

- 2012

................................ .................. 19 Table 6 Average LFG Power Production Technology Costs

................................ ................................ ..................... 29 Table 7 Average LFG Direct

- use Project Components Costs

................................ ................................ ................... 31*** Draft

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v LIST OF FIGURES

Figure 1 Material Composition of the MSW Stream, 2010

................................ ................................ ......................... 6 Figure 2 Landfill Cost Life Cycle

................................ ................................ ................................ .............................. 18 Figure 3 Typical LFG Generation Curve

................................ ................................ ................................ ................... 23 Figure 4 Vertical Well LFG Collection

................................ ................................ ................................ ..................... 25 Figure 5 Horizontal Trench LFG Collection

................................ ................................ ................................ ............. 25*** Draft

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1 INDUSTRY PROFILE
1 Introduction
Municipal solid waste (MSW) is the stream of garbage collected by sanitation services from homes, businesses, and institutions. MSW typically consists of metals, glass, plastics, paper, wood, organics, mixed categories, and composite products. The majority of collected MSW that is not recycled is typically sent to landfills

— engineered areas of land where waste is deposited, compacted, and covered. The New Source Performance Standards (NSPS) and the state and federal plans implementing the emission guideline s for MSW landfills regulate air
emissions from landfills that receive household waste as defined in 40 CFR 60.751. Hereinafter these regulations are collectively referred to as the NSPS/EG. These MSW landfills can also
receive other types of waste, such a s construction and demolition debris, industrial wastes, or
nonhazardous sludge . MSW l andfills are designed to protect the environment from contaminants which may be present in the solid waste stream and as such are required to comply with federal
Resource Conservation and Recovery Act (RCRA) regulations or equivalent state regulations, which include standards related to location restrictions, composite liners requirements, leachate collection and removal systems, operating practices, groundwater monitoring requirements, closure and post

- closure care requirements, corrective action provisions, and financial assurance (EPA, 2012a ). EPA estimates the total amount of MSW generated in the United States in 2010 was approximately 250 million tons, a 20 percent inc rease from 1990. Despite increased waste generation, the amount of MSW deposited in landfills decreased from about 145.3 million tons in 1990 to 135.5 million tons in 2010. This decline is due to a significant increase in the amount of
waste recovered for recycling and composting as well as that combusted for energy recovery (EPA, 2011). T he number of active MSW landfills in the United States has decreased from approximately 7,900 in 1988 to 1,900 in 2009 (EPA, 20 10 a ). Landfills are different than many other traditionally regulated emissions source categories. Typically, entities regulated for air emissions are involved in manufacturing or production and their emissions are directly related to processes involved in creat ing products (e.g., vehicles, bricks) or commodities (e.g., natural gas, oil). When manufacturing or production facilities cease to operate, their emissions typically cease. Landfills are a service industry

— a repository for waste that needs to be properly disposed

— and their emissions are a by

- product of*** Draft

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2 the deposition of that waste. Landfills continue to emit air pollution for many years after the last waste is deposited. Landfill gas (LFG) is a by

- product of the decomposition of organic material in MSW in
anaerobic conditions in landfills . LFG contains roughly 50 percent methane and 50 percent carbon dioxide, with less than 1 percent non

- methane organic compounds and trace amounts of inorganic compounds. The amount of LFG created primarily depends on the q uantity of waste and its composition and moisture content as well as the design and management practices at the
site. LFG can be collected and combusted in flares or energy recovery devices to reduce emissions. MSW landfills receive approximately 69 percen t of the total waste generated in the United States and produce 94 percent of landfill emissions. The remainder of the emissions is generated by indust rial waste landfills (EPA, 2012b ).
E ntities potentially regulated under Standards of Performance for Mun icipal Solid Waste
Landfills include owners of MSW landfills and owners of combustion devices that burn
untreated LFG . At its core, firms engaged in the collection and disposal of refuse in a landfill operation are classified under the North American Industry Classification System (NAICS)
code s Solid Waste Landfill (562212) and Administration of Air and Water Resource and Solid Waste Management Programs (924110). Landfills are owned by private companies, government (local, state, or federal), or
indiv iduals. In 2004, 64 percent of MSW landfills were owned by public entities while
36 percent were privately owned (O’Brien, 2006). Affected entities comprise establishments primarily engaged in operating landfills for the disposal of non

- hazardous solid was te ; or the combined activity of collecting and/or hauling non

- hazardous waste materials within a local area and operating landfills for the disposal of non

- hazardous solid waste. This industry also includes government establishments primarily engaged in th e administration and regulation of solid waste management programs

. Private companies that own landfills range in size from very small businesses to large businesses with billions in annual revenue. Public landfill owners include cities, counties/parishes , regional authorities, state governments, and the federal government (including military branches, Bureau of Land Management
, Departme nt of Agriculture, Forest Service
, and Department of the Interior

- National Park Service ).*** Draft

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3 2 Waste Stream Background

2.1 Muni cipal Waste

2.1.1 Generation of Municipal Solid Waste
Municipal solid waste (MSW) is generally defined as nonhazardous waste from household, commercial, and institutional sources. These three broad categories of primary MSW generators are described as:

 Household

– solid waste from single

- and multiple

- family homes, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds, and day

use recreation areas.

 Commercial

– solid waste from stores, offices, restaurants, warehouses, and othe r nonmanufacturing activities.

 Institutional

– solid waste from public works (such as street sweepings and tree and brush trimmings), schools and colleges, hospitals, prisons, and similar public or quasi

- public buildings. Infectious and hazardous waste fro m these generators are managed separately from MSW. Households are the primary source of MSW, accounting for 55 to 65 percent of total MSW generated, followed by the commercial sector (EPA, 2011). Waste from commercial and
institutional locations amounts t o 35 to 45 percent of total MSW (EPA, 2011). The industrial sector manages most of its own solid residuals by recycling, reuse, or self

- disposal in industrial waste landfills. For this reason industry directly contributes a very small share of the MSW flow
, although some industrial waste do es end up in MSW landfills

. Various underlying factors influence the trends in the quantity of MSW generated over time. These factors include changes in population, individual purchasing power and disposal patterns, trend s in product packaging, and technological changes that affect disposal habits and the nature of materials disposed. Generators of MSW provide most of the demand for services that collect, treat, or dispose of MSW. Fluctuations in the quantity of MSW genera ted and changes in the cost and pricing structure of disposal services result in varying demand for landfill
services. Most MSW generators are charged a flat fee for disposal services, which can be paid through taxes for household garbage collection. This structure may provide little economic*** Draft

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4 incentive to lower waste disposal or to divert waste through recycling because generators are charged the same price regardless of the quantity of waste disposed. Less common are unit price programs, such as “pay

- as

- yo u

- throw ” (PAYT) . In PAYT programs, e ach unit of waste disposed has an explicit price, such that the total fee paid for MSW services increases with the quantity of waste discarded. Hence, the unit price can act as a disincentive to dispose of excess waste a nd also encourages recycling ( Callan, 2006)

.

2.1.2 Landfills Covered Under the NSPS/EG
The Landfills NSPS/EG applies only to landfills that accept “household waste” as defined in 40 CFR 60.751, which states “h ousehold waste means any solid waste (including garb age, trash, and sanitary waste in septic tanks) derived from households (including, but not limited to, single and multiple residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds, and day

- use recreation areas ).” Some of the MSW landfills subject to the Landfills NSPS/EG may also receive other types of wastes, such as commercial, industrial, and institutional solid waste, nonhazardous sludge, and construction and demolition
debris.

2.1.3 Trends in Per Capita Waste Se nt to Landfills
In 2010, Americans generated about 250 million tons of trash, and recycled nearly
65 million tons of this material, equivalent to a 26 percent recycling rate (EPA 2011). Composting recovered more than 20 million tons of waste (
~ 8 percent of total waste) and about 29 million tons of waste were combusted for energy recovery (
~ 12 percent) (EPA 2011 ). After recycling, composting, and combustion with energy recovery, the net per capita discard rate to landfills was 2.40 pounds per p erson per day in 2010 (EPA 2011 ). This is a 4 percent decrease from the 2.51 per capita discard rate in 1960, when minimal recycling occurred in the United States (see Table 1). Since 1990, the total amount of MSW going to landfills has dropped by almost 10 million tons, from 145.3 million to 135.5 million tons in 2010 (EPA 2011 ). While the number of U.S. landfills has steadily declined over the years, the average landfill size has increased. At the national level, landfill capacity appears to be sufficient, although it is limited in some areas (EPA 2011)

.*** Draft

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5 Table 1 Generation and Discards of MSW, 1960 to 2010 (in pounds per person per day) 1 Activity 1960 1970 1980 1990 2000 2005 2007 2008 2009 2010
Generation
2.68 3.25 3.66 4.57 4.72 4.67 4.64 4.53 4.35 4.43
Discards to landfill a 2.51 3.02 3.24 3.19 2.71 2.61 2.52 2.45 2.36 2.40
Discards to landfill (% of total generation) 94% 93% 89% 70% 57% 56% 54% 54% 54% 54%

a Discards after recovery minus combustion with energy recovery. Discards include combustion without energy recovery

. 2.1.4 Composition of MSW S ent to Landfills
Organic materials continue d to be the largest component of MSW in 2010. Yard trimmings and food scraps account for 29.1 percent and paper and paperboard account for
another 16.2 percent. Plastics comprise 17.3 percent while metals and wood make up 8.8 percent
and 8.2 percent, respectively. Textiles account for 6.8 percent and glass accounts for 5.1 percent. Rubber and leather follow at 4.0 percent. Other miscellaneous wastes make up approximately
4.4 percent of the MSW generated in 2010 (EPA 2011 ). Figure 1 displays material composition percentages of the MSW stream in 2010, and Table 2 shows the amounts of different m aterials
discarded in the MSW stream from 1960 to 2010.

1 Table adapted from U.S. Environmental Protection Agency. 2011. “ Municipal Solid Waste Generation, Recycling, and Disposal in the United States Tables and Figures for 2010.” Table 4

. EPA

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- 0 05. Washington, DC: U.S. EPA. Available at < http://www.epa.gov/osw/nonhaz/municipal/pubs/2010_MSW_Tables_and_Figures_508.pdf>. As obtained on October 30, 2011.*** Draft

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6 Figure 1 Material Composition of the MSW Stream, 2010 2

2 Figure adapted from U.S. Environmental Protection Agency. 2011. “ Municipal Solid Waste Gene ration, Recycling, and Disposal in the United States Tables and Figures for 2010.” Table 3. EPA

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- 0 05. Washington, DC: U.S. EPA. Available at < http://www.epa.gov/osw/nonhaz/municipal/pubs/2010_MSW_Tables_and_Figures_508.pdf>

. As obtained on October 30, 2011.*** Draft

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7 Table 2 Materials Discarded a In the MSW Stream, 1960 to 2010 (in thousands of tons) 3

Wastes 1960 1970 1980 1990 2000 2005 2010 Paper and Paperboard 24,916 37,540 43,420 52,500 50,180 42,880 26,740
Glass 6,620 12,580 14,380 10,470 9,890 9,950 8,400
Metals 10,770 13,350 14,290 12,580 12,340 13,400 14,540
Plastics 390 2,900 6,810 16,760 24,050 27,470 28,490
Rubber and Leather 1,510 2,720 4,070 5,420 5,850 6,200 6,610
Textiles 1,710 1,980 2,370 5,150 8,160 9,670 11,150
Wood 3,030 3,720 7,010 12,080 12,200 12,960 13,580
Other Materials b 70 470 2,020 2,510 3,020 3,080 3,380 Food Scraps 12,200 12,800 13,000 23,860 29,130 31,300 33,790 Yard Trimmings 20,000 23,200 27,500 30,800 14,760 12,210 14,200 Miscellaneous Inorganic
Wastes 1,300 1,780 2,250 2,900 3,500 3,690 3,840
Total MSW Discarded 82,516 113,040 137,120 175,030 173,080 172,810 164,720

a Discards after materials and compost recovery. In this table, discards include combustion with energy recovery. Does not include construction and demolition debris, industrial process wastes, or certain other wastes

. b Includes electrolytes in batteries a nd fluff pulp, feces, and urine in disposable diapers. Details may not add to totals due to rounding.

2.2 Consolidation of Waste Streams
Collection and transportation are necessary components of all MSW management systems regardless of the specific disposal options. Collections of MSW vary by service arrangements between local governments and collectors and by level of service provided to households. Depending on the arrangement type and other considerations for particular jurisdictions, MSW being sent to lan dfills may be deposited in a local landfill or routed to a regional landfill through a transfer process. Local landfills are generally located in the

3 Table adapted from U.S. Environmental Protection Agency. 2011. “Municipal Solid Waste Generation, Recycling, and Disposal in the United States Tables and Figures for 2010.” Table 3. EPA

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8 communities in which they serve whereas regional landfills are often located outside of the
communities th ey serve and receive waste from several cities and towns. Solid waste transfer is the process in which collection vehicles unload their waste at centrally located transfer stations. Transfer stations can minimize hauling costs by decreasing the
number of d rivers and vehicles hauling waste to disposal sites and reducing the turn

- around time of vehicles because they do not have to haul waste to distant regional landfills. Smaller loads are consolidated into larger vehicles, usually tractor

- trailer trucks, tra ins, or barges, which are better suited for the long

- distance hauls often required to reach the final disposal site, often a regional landfill. As public opposition to local MSW disposal facilities increases and the cost of disposal at locations near gener ators rise, long

- distance hauls to regional landfills are becoming more

common.

3 Disposal Facility Background

3.1 Technical Background on Landfills as a Source Category

An MSW landfill refers to an area of land or an excavation where MSW is placed for

permanen t disposal. MSW landfills do not include land application units, surface impoundments, injection wells, or waste piles. Modern MSW landfills are well

- engineered disposal facilities that are sited, designed, operated, and monitored to protect human health a nd the environment from pollutants that may be present in the solid waste stream (EPA, 2012 c ).

3.1.1 Landfill Siting and Permitting
MSW landfills are required to comply with federal regulations contained in Subtitle D of the Resource Conservation and Recovery Ac t (RCRA) [40 CFR Part 258], or equivalent state regulations. RCRA requirements include location restrictions that ensure landfills are constructed away from environmentally

- sensitive areas, including fault zones , wetlands, flood plains, or
other restricted areas (EPA, 2012 c )

. Site selection for landfills is an integral part of the design

process.

Construction and operating permit applications for new landfills must be submitted to and approved by state and local regulatory agencies as part of the siting and design process. Often, states require a registered professional engineer to design the landf ill (Guyer, 2009). Additional*** Draft

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9 permits must be issued for each expansion of the landfill from its originally permitted waste design capacity and footprint area. New or modified landfills may also require air permits under the New Source Review (NSR) permitt ing program, which includes Prevention of Significant Deterioration (PSD) requirements for landfills sited in attainment areas, or areas where the air quality meets the National Ambient Air Quality Standards (NAAQS), and more stringent NSR requirements for landfills located in non

- attainment areas.

Developing a new landfill or expanding an existing landfill has become increasingly difficult, especially in metropolitan areas, due to the urbanization of suitable sites, permitting barriers, elevated land costs , and other factors. If a new landfill is proposed or when expansion plans for existing landfills are announced, adjacent communities may mount opposition that can hinder issuance of required permits and thus development of the landfill (Alva, 2010).

3.1.2 Landf

ill Operations
The two most common methods for active disposal of waste into landfills are the area fill
method and the trench method. The area fill method involves waste placement in a large open
section of a lined landfill and then spreading and compacti ng waste in uniform layers using heavy equipment

. The trench method of filling waste in a modern landfill involves placing and compacting waste into a trench and then using material from the trench excavation as daily

cover. Local conditions often determine the most appropriate method for a particular landfill, and a combination of the two methods can be utilized. The trench method is less commonly used than the area fill method, mostly due to the expense of lining side slopes of the landfill (Guyer
, 2009). As required by Subtitle D of RCRA, c over material is applied on top of the waste mass at the end of each day t o prevent od ors and fires and reduce litter, insects, and rodents. Materials used as daily cover include soil, compost, incinerator ash, foam, and tarps (NSWMA, 2008). Similarly, intermediate cover is used when an area of the landfill is not expected to receive waste or a cap for a n extended period of time. Intermediate covers have traditionally consisted of layers of soil, geotextiles, or other materials. The reason s for using intermediate cover are similar to
those for using daily cover and may also include erosion control. It is important to maintain anaerobic conditions within the landfill waste mass to avoid
excess air infiltration that can cause fires. Landfill fires can be avoided by closely monitoring*** Draft

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10 landfill conditions and maintaining the landfill as a controlled facility. If active LFG c ollection systems are instal led , t hen gas wells are monitored to ensure oxygen is not being pull ed into the
landfill due to excessive vacuum levels.

3.1.3 Landfill Closure
Once an area of the landfill, or cell, has reached its permitted height, that cell is closed and a low permeability cap made of compacted clay or synthetic material is installed to preve nt infiltration of precipitation. To divert water off of the top of the landfill, a granular drainage layer is placed on top of the low

- permeability barrier layer. A protective cover is placed on top of the filter blanket and topsoil is placed as the final layer to support vegetation. The final cap and cover inhibit soil erosion and provide odor and LFG control (NSWMA, 2008)

. If an LFG collection and control system is in place, then expansion of the collection system into filled cells
or areas of the landfi ll may require additional gas wells to be installed soon after these cells are closed and capped. Gas collection system design is discussed further in Section 6. RCRA Subtitle D regulations contain closure and post

- closure care requirements, including writ ten closure and post

- closure care plans and maintaining the final cover, leachate collection system, and groundwater and LFG monitoring systems. The required post

- closure care period is 30 years from site closure, but this can be shortened or extended if a pproved by state regulatory agencies (EPA, 2012 d )

.

3.1.4 Management of Liquids
Leachate is the liquid that passes through the landfilled waste and strips contaminants from the waste as it percolates. Precipitation is the primary source of this liquid. To prevent water pollution and protect soil beneath
, RCRA Subtitle D re quires liners for landfills as well as
leachate collection and removal and groundwater monitoring systems. Composite l iner systems

are used along the bottom and sides of landfills as impermeable barriers and are typically constructed with layers of natural materials with low permeability ( e.g., compacted clay) and/or synthetic materi als (e.g., high

- density polyethylene) (NSWMA, 2008). Lan dfill liner systems also help prevent off

- site migration of LFG. Leachate collection systems remove leachate from the landfill as it collects on the liner using a perforated collection pipe placed in a drainage layer ( e.g., gravel)

. Waste is placed*** Draft

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11 directl y above the leachate collection system in layers. Collected leachate can be treated on

- site or transported off

- site to treatment facilities. For landfills with LFG collection systems, LFG condensate can be combined with leachate prior to treatment. Althoug h traditional landfills tend to minimize the infiltration of liquids into a landfill using liners, covers, and caps (sometimes referred to as “dry tombs”), some landfills recirculate all or a portion of leachate collected to increase the amount of moisture within the waste mass. This practice of leachate recirculation results in a faster anaerobic biodegradation process and increased rate of LFG generation. Similarly, landfills may introduce liquids other than leachate, such as sludge and industrial wastewa ter. Conventional landfills typically have in

- situ moisture contents of approximately 20 percent, whereas landfills recirculating leachate or other liquids

may maintain moisture content s ranging from 35 to 65 percent ( E PA, 2012 e ). Often, landfills injectin g or recirculating liquids are termed bioreactors, but bioreactor landfills are defined differently amongst industry and regulatory agencies. In addition, bioreactor landfills may have air injected in a controlled manner to further accelerate biodegradatio n of the waste, which occurs for aerobic and hybrid bioreactor configurations.

3.2 Ownership and Characteristics of Landfills
Since the 1980’s, the number of active MSW landfills in the United States has decreased by approximately 75 percent (from ~7,900 in 19 88 to ~1,900 in 2009) and the share of sites that are publicly owned has also decreased

— from 83 percent in 1984 to 64 percent in 2004 (EPA,
20 10 b ; O’Brien, 2006). However, the overall volume of disposal capacity has remained fairly constant, indicating a t rend of growing individual landfill capacity (SWANA, 2007). In 2004, privately owned sites represented 83 percent of the permitted MSW landfill capacity and
77 percent of the MSW landfilled in that year, an indication that private landfills are likely to b e significantly larger than public ones (O’Brien, 2006). In 2004, the average daily amount of MSW disposed at public sites was just under 200 short tons, whereas the average private site landfilled nearly 1,200 short tons of MSW per day

— further evidence th at publicly owned landfills are generally much smaller than their private counterparts (O’Brien, 2006). EPA recognized as early as 2002 that a nationwide trend in solid waste disposal is toward the construction of larger, more remote, regional landfills. E conomic considerations, influenced by regulatory and social forces, are compelling factors that likely led to the closure of many*** Draft

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12 existing sites and to the idea of regional landfills (EPA, 2002 b ). The passage of federal environmental regulations that affec ted landfills (e.g., RCRA in 1976, Subtitle D of RCRA in 1991), established requirements which made it more expensive to properly construct, operate, maintain, and close landfills (O’Brien, 2006; EPA 2012 f ; EPA, 2002 b ). Large, private companies are better able to accommodate the increased costs of owning a landfill, since owning multiple sites, many of which have large capacities, provides an economy of scale for cost expenditures (O’Brien, 2006). To offset the high cost of constructing and maintaining a mo dern landfill, facility owners construct large facilities that attract high volumes of waste from a large geographic area. By maintaining a high volume of incoming waste, landfill owners can keep tipping fees relatively low, which subsequently attracts mor e business (EPA, 2002 b ). As older, public landfills near their capacities, communities must decide whether to construct new landfills or seek other options. Many find the cost of upgrading existing facilities or constructing new landfills to be prohibitiv ely high, and opt to close existing facilities. Also, public opposition often makes siting new landfills near population centers difficult and adequate land may not be available near densely populated or urban areas. Many communities are finding
that the m ost economically viable solution to their waste disposal needs is shipping their waste to regional landfills. In these circumstances, a transfer station serves as the critical link in making the shipment of waste to distant facilities cost

- effective (EPA, 2002 b ).
Waste transfer stations are facilities where MSW is unloaded from collection vehicles and reloaded into long

- distance transport vehicles for delivery to landfills or other treatment/disposal facilities. By combining the loads of several waste colle ction trucks into a single shipment, communities and waste management companies can save money on the labor and operating costs of transporting waste to a distant disposal site. They can also reduce the total
number of vehicular miles traveled to and from the disposal site(s) (EPA, 20 12 g ). Given the dramatic decrease in the number of active landfills in the past 20 years, transfer stations play an important part in facilitating the movement of solid waste from the areas in which it originates to
its end loc ation, often a large, centrally located landfill. The role of transfer stations in waste management has become even more prominent with the increase in the number of “regional”
landfills

— sites with very large capacities, often located in remote areas, and usually privately owned. As more and more publicly owned landfills reach capacity and close, the waste must go somewhere, and often that is to a regional landfill by way of a transfer station.*** Draft

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13 There are more than 200 private companies that own and/or opera te landfills, ranging from large companies with numerous landfills throughout the country to local businesses that own a single landfill (EPA, 2012 b ). The handling of MSW in the United States generated $55 billion of revenue in 2011 (EBI, 2012). In terms o f 2011 revenue, the top two companies that own and/or operate MSW landfills in the United States were Waste Management ($13.38 billion) and Republic Services ($8.19 billion), which together accounted for 39 percent of the revenue share in 2011 (Bloomberg, 2012WM; Bloomberg, 2012RSG). The next tier of companies involved in landfill management includes Veolia Environmental Services North America Corp. ($1.88 billion), Progressive Waste Solutions ($1.84 billion), and Waste Connections ($1.51 billion) (Gerlat, 2012; Bloomberg, 2012BIN; Bloomberg, 2012WCN). Table 3 contains a summary of the 2011 revenue for the top five companies, as well as information about their
MSW landfills and transfer stations.
Table 3 Top 5 Waste Management Companies That Own or Operate MSW Landfills in 2011

Company 2011
Revenue (billion $) No. of MSW

Landfills Owned and/or Operated MSW

Received at
Landfills (million tons) No. of Transfer

Stations Owned and/or Operated

Waste Management (Bloomberg, 2012WM) 13.38 266 91.2 287

Republic Services (Bloomberg, 2012RSG) 8.19 191 active/
130 closed NA 194

Veolia
Environmental
Services North America Corp. (Gerlat, 2012) a 1.88 29 NA 43*** Draft

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14 Table 3 Top 5 Waste Management Companies That Own or Operate MSW Landfills in 2011

Company 2011
Revenue (billion $) No. of MSW

Landfills Owned and/or Operated MSW

Received at
Landfills (million tons) No. of Transfer

Stations Owned and/or Operated

Progressive Waste
Solutions (Bloomberg, 2012BIN) 1.84 NA NA NA

Waste Connections (Bloomberg, 2012WCN) 1.51 46 14.9 58

a In 2012, VESNA agreed to sell its U.S. solid waste operations, Veolia ES Solid Waste, Inc., to Star Atlantic Waste Holdings LP, a unit of Highstar Capital; the sale is to be completed by end of 2012. Highstar also owns Advanced Disposal Services Inc. and Interstate Waste Services Inc. NA = Not available.

The industry that deposits MSW in landfills encompasses a wide range of job types, including garbage collectors, truck drivers, heavy equipment operators, engineers of various disciplines, specialized technicians, executives, MSW department directors, admi nistrative staff, weigh scale operators, salespersons, and landfill operations managers. In 2007, 1,501 private establishments had 21,766 employees in the continental United States under NAICS 562212 (Solid Waste Landfill) (Census, 2012). In 2011, solid wa ste management departments of local governments reported 98,957 full

- time employees and 14,679 part

- time employees (Census, 2011); however, statistics are not readily available solely for landfill

- related aspects of these departments. As the population con tinues to grow in the United States the amount of waste generated will continue to increase, but the amount of waste landfilled may remain the same or decrease (EPA, 2012 h ). Employment within the waste management industry overall will likely remain strong, perhaps with an increased shift of employees from the public sector to the private

sector.*** Draft

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15 4 Costs and Revenue Streams for Landfills

4.1 Major Cost Components for Landfills
EPA promulgated Criteria for Municipal Solid Waste Landfills (40 CFR Part 258) under
the RCRA on October 9, 1991 (EPA, 2012 i ). The law requires that non

- hazardous MSW be disposed of in specially designed sanitary landfills. The criteria include location restrictions, design and operating standards, groundwater monitoring requirements, correct ive actions, financial assurance requirements, landfill gas (LFG) migration controls, closure requirements, and post

- closure requirements (EPA, 2012 j ). It can cost more than $1 million per acre to construct, operate, and close a landfill in compliance with these regulations (Fitzwater, 2012). Landfill costs are site specific and vary based on factors such as terrain, soil type, climate, site restrictions, regulatory issues, type and amount of waste disposed, preprocessing, and potential for groundwater contamination. Landfill costs fall into the following categories: site development, construction, equipment purchases, operation, closure, and post

- closure. Site development includes site surveys, engineering and design studies, and permit package fees. Su rveys are necessary to determine if a potential site is feasible. Permits are required from local, state, and federal governments. As an example, engineering design and a permit application for an MSW landfill in Kentucky can cost approximately $750,000 to $1.2 million (KY SWB, 2012). Construction costs encompass building the landfill cells as well as development of permanent on

- site structures needed to operate the landfill. Cortland County, New York estimated that the cost for site development and cell co nstruction (not including on

- site building construction) for a 224.5

- acre site would be approximately $500,000 per acre (EnSol, 2010). In 2005, a series of articles was written that estimated costs for a hypothetical landfill based on
known market conditio ns and cost data. The theoretical landfill had a design capacity of
4 million cubic yards and a footprint of 33 acres. The study determined that the cost of constructing a landfill of this size would be between $300,000 and $800,000 per acre. Table 4

summa rizes typical construction costs per acre by individual task for this example site (Duffy, 2005a).*** Draft

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16 Table 4 Typica l Costs Per Acre for Components of Landfill Construction (Duffy, 2005a) Task Low End High End
Clear and Grub $1,000 $3,000 Site Survey $5,000 $8,000
Excavation $100,000 $330,000
Perimeter Berm $10,000 $16,000 Clay Liner $32,000 $162,000
Geomembrane $24,000 $35,000 Geocomposite $33,000 $44,000
Granular Soil $48,000 $64,000 Leachate System $8,000 $12,000 QA/QC $75,000 $100,000
TOTAL $336,000 $774,000

Excavation of the landfill site comprises a notable portion of the construction costs. Installation of a landfill liner can vary greatly in cost depending on the site’s geology. Most states require only a single liner and leachate collection system for MSW , but requirements vary for the minimum thickness of clay liners. Landfill sites may have good quality clay located on

site that would significantly lower the cost of a clay liner. The QA/QC task in Table 4 refers to management and quality oversight which is usually performed by independent third

- party consultants. For the hypothetical landfill in the study, total building and additional structure costs could total between $1.165 million and $1.77 million. Operation of the landfill requires a truck scale, s cale house, wheel wash facility, and buildings to accommodate an office and provide space for maintenance. The cost of each building structure varies depending on its functions and could range from $10 to $100 per square foot. Office buildings cost more wh ile maintenance buildings and tool sheds cost less. In addition, fencing around the facility and roadways are required and add to the costs (Duffy, 2005a). Operating costs of the example landfill include staffing, equipment (payments and maintenance), lea chate treatment, and facilities and general maintenance. Landfill operations and maintenance activities are performed using a variety of heavy construction equipment with*** Draft

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17 operating costs dependent on fuel, repairs, and maintenance. Operating costs are rela tively small when compared to the capital costs; estimated annual operating costs from this study are (Duffy, 2005a):

 Operations (equipment, staff, facilities and general maintenance): $500,000

.

 Leachate collection and treatment (assumes sewer connection and discharge cost of $0.02/gallon): $10,000

.

 Environmental sampling and monitoring (groundwater, surface water, air gas, leachate): $30,000

.

 Engineering services (consulting firms and in

- house staff): $60,000

. Once a landfill no longer accepts waste, the closure process includes the installation of a
final cover and cap . Capital costs for installation of a cap can run between $80,000 and $500,000

per acre . For example, at a Maryland sanitary landfill costs were $150,000 per acre (MDE, 2012). The capping co sts for a 249.4

- acre site in Cortland County, New York were estimated to
be approximately $134,000 per acre. Factors influencing these costs include the materials used for the cap, site topography, and the availability of clay or soil suitable for use as t he cover. Similar to the costs of the clay liner during the construction of the landfill, availability of nearby clay would significantly reduce this cost (EnSol, 2010). The closure process can include the installation of an LFG collection system which is necessary to collect and destroy or beneficially use the methane gas that is generated . (However, many landfills install gas collection and control systems as the landfill is being filled, or as areas within the landfill reach final grade, rather than wait ing until closure to begin gas collection system installation

. ) The costs associated with an LFG collection and flare system are minimal as compared to the capital costs for landfill construction, annual landfill operating costs, and other
closure costs. S ection 6 discusses average installation costs for gas collection systems and flares.
Post

- closure care requires maintenance to ensure the integrity and effectiveness of the final cover system, leachate collection system, groundwater monitoring system, and methane gas monitoring system. These activities prevent water and air pollution from escaping into the surrounding environment. The required post

- closure care period is 30 years from site closure, and can be shortened or extended by the director of an app roved state program as necessary to ensure protection of human health and the environment. Over a 30

- year period, p ost

- closure care and maintenance can cost from $64,000 to $88,000 per acre (Duffy, 2005b).*** Draft

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18 Figure 2 shows that landfill costs peak prior to the landfill opening and again following the landfill closing (EPA, 1997).

Figure 2 Landfill Cost Life Cycle

4.2 Landfill Revenue Sources
The cost to dispose of MSW at a landfill is c ommonly known as a “tip fee” or “gate fee”. Typically, reported tip fees represent the “spot market” price for MSW disposal, i.e., the drive

- up cost to dispose of a ton of waste (NSWMA, 2011). Other tip fees exist at MSW facilities (e.g., waste accepted un der a long

- term contract, volume discounts, and special wastes); these fees may be higher or lower than the spot market price (Repa, 2005). In September 2012, t he average
national spot market price to dispose of one ton of waste in a U.S. landfill was roug hly $45, up 3.5 percent over 2011 (WBJ, 2012). This compares to average national tip fees of approximately $32 in 1998 (EPA, 2002) and $8 in 1985 (NSWMA, 2011). Average tip fees vary by region of the country, as shown in Table 5

. Tip fees in
northeastern states have historically been and continue to be higher than those in other regions.*** Draft

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19 The next most expensive areas, on average, are the Mid

- Atlantic and western states. Tip fees tend to be higher near large population centers (Wright, 2012); this is likely influenced by the fact that metropolitan areas have less land area for waste disposal and therefore, fewer landfills. There is variation in tip fees within states as well, depending on landfill ownership (public or private) and proximity of other landfill s.

Table 5 Average Regional and National Per

- Ton Tip Fees (Rounded): 1995

- 2012 U.S. Region 1995 a 1998 a 2000 a 2002 a 2004 a 2008 b 2010 c 2012 d
Northeast $73 $67 $70 $69 $71 $67 NA $73
Mid

- Atlantic $46 $44 $46 $45 $46 $56 NA NA
South $29 $31 $31 $30 $31 $32 NA NA
Midwest $31 $31 $33 $34 $35 $39 NA NA
South Central $20 $21 $22 $23 $24 $34 NA NA
West Central $23 $23 $22 $23 $24 $39 NA NA
West $38 $36 $35 $39 $38 $44 NA NA
National $32 $32 $32 $34 $34 $42 $44 $45

Northeast: CT, ME, MA, NH, NY, RI, VT Mid

- Atlantic: DE, MD, NJ, PA, VA, WV South: AL, FL, GA, KY, MS, NC, SC, TN Midwest: IL, IN, IA, MI, MN, MO, OH, WI South Central: AZ, AR, LA, NM, OK, TX West Central: CO, KS, MT, NE, ND, SD, UT, WY West: AK, CA, HI, ID , NV, OR, WA

a Source: Repa, 2005. b Source: Data from Biocycle, 2010. Data were not available for all states. For nine states, 2006 or 2009 data were substituted for missing year 2008 data.

c Source: WBJ, 2010. d Source: WBJ, 2012.
Publicly owned landfills set tip fees based on the need to cover landfill and other waste management

- related costs, while privately owned landfills’ tip fees are set based on competition or the lack thereof (Wright, 2012). For municipalities that depend on landfill tip fees to fund programs and services , more waste d isposed in the local community

- owned landfill means more
money generated to fund their solid waste system s , including non

- disposal s ervices like recycling. Conversely, if more waste starts going to private landfills instead, less revenue is generated for community programs . An increasing presence of private facilities that can set*** Draft

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20 competitive tip fees has caused some communities to reduce their own tip fees in an effort to attract enough disposal volume to keep revenues at a sufficient level (Burgiel, 2003)

. Historically, the construction and operating costs of public MSW landfills have been funded by tip fees, tax revenues (e.g., county/city property tax revenue that goes into a general fund), or a combination of these. Factors influencing tip fee values have included population and economic growth, recycling rates, operating and transportation costs, land values, and legislation. Traditionally, 30 percent of landfills receive all revenue from tip fees, 35 percent receive all revenue from taxes, and 35 percent cover the costs of waste disposal through a combination of tip fees and taxes. The use of taxes as a revenue source rather than tip fees has implications on waste disposal services. When disp osal costs are included in taxes, most people are not aware of the actual costs involved and there is little incentive to reduce waste generation rates. Also,

tax

- supported facilities are typically underfunded relative to actual disposal costs, resulting i n poorer operation than fully funded landfills supported by tip fees. Factors that influence the choice of revenue sources include landfill size and ownership. Landfills receiving small quantities of waste are likely to rely heavily on taxes for their reve nue while larger landfills rely on both taxes and tip fees (EPA, 2002 a ). Private owners of landfills rely heavily on tip fees relative to other landfill owners. It remains unclear whether private landfills rely on tip fees because they are larger, or larg er landfills rely heavily on tip fees because they are private (EPA, 2002 a ).
As shown in Table 5 , average tip fees by region remained fairly steady between 1995 and 2004, with minor declines in some years but with a gradual upward trend. The greatest incre ases in average tip fees occurred between 1985 and 1995, with the national average tip fee increasing by $24 (293 percent) or an average of $2.40 per year. By contrast, between 1995 and 2004, the national average tip fee increased by only 7 percent, or an average of 23 cents per year. Tip fees are expected to continue to increase gradually, based on recent data and given rising fuel costs, insurance costs, and other operating costs (Wright, 2012). A landfill can also generate revenue by entering an agreemen t to sell carbon credits for voluntary destruction of methane, entering a gas sales agreement to sell LFG for beneficial use, or entering a power purchase agreement to sell electricity generated from LFG and/or renewable energy credits from the generation of that electricity. These types of revenue are small relative to tip fees and total landfill revenues, but can help offset some landfill expenses, for example, the*** Draft

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21 cost of installing a gas collection system or energy recovery equipment. More information a bout these potential revenue sources is available in Section 6.

5 Air Pollutant Emissions from Landfills
Municipal solid waste (MSW) landfills are a source of non

- methane organic compounds (NMOC) which include volatile organic compounds (VOC) , methane, a potent greenhouse gas (GHG), and hazardous air pollutants. LFG is formed during the decomposition of landfilled waste and, if not controlled, can emit numerous pollutants into the air

. Several factors affect the amount of LFG generated and its components, including the age and composition of the waste,
the amount of organic compounds in the waste, and the moisture content and temperature of the

waste (EPA, 2012 k )

. LFG generated from established waste (waste that has been in place for at least a year) is typ ically composed of roughly 50 percent methane (CH 4 ) and 50 percent carbon dioxide (CO 2 ) by volume, with trace amounts of non

- NMOC and inorganic compounds (e.g., hydrogen sulfide) (EPA, 2010 c ; EPA, 2012 k ).

5.1 NMOC in LFG
The NMOC portion of LFG, while a small amount of LFG by volume, can contain a variety of significant air pollutants. NMOC include various organic hazardous air pollutants (HAPs) and VOC. If left uncontrolled, VOC can contribute to the formation of ground

- level ozone, a common pollutant with adv erse health impacts. Nearly 30 organic hazardous air pollutants have been identified in uncontrolled LFG, including benzene, toluene, ethyl benzene, and vinyl chloride (EPA, 2012 k )

. NMOC in LFG results mainly from the volatilization of organic compounds c ontained in the landfilled waste, while some NMOC may be formed by biological processes and chemical reactions within the waste (EPA, 1998). Waste materials that contribute to the formation of
NMOC include items such as household cleaning products and mate rials coated with or containing paints and adhesives; d uring decomposition , NMO C can be stripped from these
materials by other gases (e.g., CH 4 or CO 2 ) and become part of the L FG (EPA, 2012 k )

. The concentration of NMOC in uncontrolled LFG depends on severa l factors, including waste types in the landfill and the local climate. EPA’ s Compilation of Air Pollutant Emiss ion Factors (AP

– 42) provides a default NMOC concentration of 595 parts per million by volume*** Draft

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22 (ppmv) , of which 110 ppmv are considered HAP compou nds. The total uncontrolled organic
HAPs volume in LFG from MSW landfills is typically less than 0.02 percent of the total LFG (EPA, 2012 k ).

5.2 Methane in LFG

Methane is 25 times more effective at retaining heat in the earth’s atmosphere than CO 2 and therefore is considered a potent GHG ( IPCC 2007) . The CO 2 generated from MSW landfills is deemed biogenic because the CO 2 would have been generated anyway as a result of natural decomposition of the organic waste materials if they had not been deposit ed in the landfill (EPA,
2010 c )

. When waste is first placed in a landfill, it enters an aerobic decomposition stage during
which little CH 4 is produced. However, within a year or less, the waste environment becomes anaerobic, CH 4 generation increases, and the amount of CO 2 produced begins to level out (EPA,
2010 c ). Figure 3 presents a sample LFG generation curve over time for a typical MSW landfill. Significant CH 4 generation can continue for 10 to 60 years after initial waste placement (EPA,
2012 k ).*** Draft

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23 F igure 3 Typica l LFG Generation Curve

In 201 2 , landfills were the third

- largest anthropogenic source of CH 4 emissions in the United States, accounting for approximately 1 8 percent (EPA, 201 4 ). Increasing attention is being given to mitigation of CH 4 , given its global warming potential 25 times greater than CO 2 and its relatively short atmospheric lifetime of about 12 years (as compared to 50

- 200 years for
CO 2 ) (EPA, 2014 ).

5.3 Criteria Pollutants from Combustion of LFG

While collection and combustion of LFG in a flare or energy project equipment (e.g., reciprocating engine, boiler, turbine) greatly reduces emissions of methane and NMOC (including VOC and organic HAP), the combustion process generates criteria pollutants
includ ing carbon monoxide (CO), nitrogen oxides (NO X ), sulfur dioxide (SO 2 ), and particulate matter (PM) (EPA, 1998). NO X formation is strongly tied to the combustion temperature in the equipment, while CO and PM emissions are primarily the result of incomplete combustion of the*** Draft

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24 gas. SO 2 production depends upon the amount of sulfur in the LFG ( EPA, 2000 )

. More
information about LFG combustion devices is available in Section 6.
6 Techniques for Controlling Emissions from Landfills

6.1 Introduction

Emissions from landfil ls can be controlled by installing gas collection systems and either flaring the LFG or utilizing it as an energy source. Large landfills with emissions exceeding 50

megagrams per year (Mg /yr ) of nonmethane organic compounds (NMOC) are required by the
MSW landfills NSPS to control and/or treat LFG to significantly reduce the amount of toxic air pollutants released. However, many landfills voluntarily choose to control emissions, in part because of the economic benefits of LFG energy projects.
This section describes the equipment and costs associated with LFG emission controls. The control technologies are divided into three categories: gas collection systems, destruction,
and utilization. Much of the information in this s ection was obtained from the U.S. EPA’s Landfill Methane Outreach Program (LMOP) Landfill Gas Energy Project Development
Handbook (EPA 2010 d ).

6.2 Gas Collection Systems

LFG collection typically begin s after a portion of the landfill (known as a “cell”) is closed to additional waste plac ement. Gas vents are installed to collect LFG from the closed cell. The gas vents may be configured as vertical wells or horizontal trenches, and some collection systems involve a combination of the two. Vertical wells ( Figure 4 ) are the most common
method of LFG collection and involve drilling wells vertically in the waste to collect gas.
Horizontal trenches ( Figure 5 ) use piping laid horizontally in trenches in the waste; these systems are useful in deeper landfills and in areas of active filling. Both ty pes of collection systems connect the wellheads to lateral piping that transports the gas to a collection header

.*** Draft

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25 Source: EPA, 2010 d
Figure 4 Vertical Well LFG Collection

Source: EPA, 2010 d
Figure 5 Horizontal Trench LFG Collection

Collection from the gas vents may be either passive or active. Passive systems rely on the natural pressure gradient between the waste mass and the atmosphere to move gas to collection systems. Most passive systems intercept LFG migration and the collected gas is vented to the atmosphere. Active systems use mechanical blowers or compressors to create a vacuum that optimizes LFG collection (ATSDR, 2001).*** Draft

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26 Collection efficiency is a measure of the ability of a gas collection system to capture generated LFG. Although rates of LFG capture can be measured, rates of actual generation in a landfill cannot be measured; therefore, consider able uncertainty exists regarding actual collection
efficiencies achieved at landfills. C ollection efficiencies at landfills with comprehensive gas collection systems typically range from 60 to 85 percent, with an average of 75 percent most commonly assume d (EPA, 1998)

. Total collection system costs vary widely, based on a number of site

- specific factors. For example, if the landfill is deep, collection costs tend to be higher because well depths will need
to be increased. Collection costs also increase wit h the number of wells installed. Based on data from the LMOP’s Landfill Gas Energy Cost Model (LFGcost), the estimated capital cost (in 2008 $’s) required for a 40

- acre collection system designed for 600 cubic feet per minute (cfm) of LFG is $784,000, assu ming one well is installed per acre. Typical annual operation and maintenance (O&M) costs (in 2008 $’s) for collection systems are $2,250 per well. If an LFG energy project generates electricity, a landfill will often use a portion of the electricity gener ated to operate the system and sell the rest to the grid in order to offset these operational costs.

6.3 Destruction
Collected LFG is typically combusted in flares or combustion devices that recover energy, such as boilers, internal combustion engines, and gas turbines. Properly designed and operated combustion equipment generally reduces NMOC by 98 percent or to a 20 pp mv outlet concentration, as specified in the current MSW landfill NSPS (40 CFR 60.752). Combustion also destroys over 98 percent of the methane.
Flares are the most common control device used at landfills. Flares are also a component of each energy recove ry option because they may be needed to control LFG emissions during energy recovery system startup and downtime and to control any gas that exceeds the capacity of the energy conversion equipment. In addition, a flare is a cost

- effective way to gradually increase the size of the energy recovery system at an active landfill. As more waste is placed in the landfill and the gas collection system is expanded, the flare is used to control excess gas between energy conversion system upgrades (e.g., before additi on of another engine). Flare designs include open (or candlestick) flares and enclosed flares. Open flares employ simple technology where the collected gas is combusted in an elevated open burner. A*** Draft

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27 continuous or intermittent pilot light is generally used to maintain the combustion. Enclosed flares typically employ multiple burners within fire

- resistant walls, which allow them to maintain a relatively constant and limited peak temperature by regulating the supply of combustion air (ATSDR, 2001b). Enclosed flares are more expensive but may be preferable (or required by state regulations) because they provide greater control of combustion conditions, allow for stack testing, and might achieve slightly higher combustion efficiencies than open flares. They can also reduce noise and light nuisances. Flare costs vary based on the gas flow of the system. LFGcost estimates for flares include condensate collection and blowers. Condensate collection (also called knockout devices) is necessary because c ondensate forms when warm gas from the landfill cools as it travels through the collection system. If condensate is not removed, it can block the co llection system

. Blowers are needed to ensure a steady flow of gas to the flare. The size, type, and number of blowers
neede d depend on the gas flow rate and distance to downstream processes. Based on data from LFGcost (in 2008 $’s), a flare for a system with an average of
600 cfm of LFG will cost $207,000 (including condensate collection and blowers ). Typical
annual O&M costs are approximately $ 4,500 per flare

. Electricity costs to operate the blower for a 600 cfm active gas collection system average $44,500 per year.

6.4 Utilization
After collection, LFG may be used in an energy recovery system to combust the methane
and other tr ace contaminants

. LMOP’s Landfill and LFG Energy Project Database, which tracks the development of U.S. LFG energy projects and landfills with project development potential, indicates that approximately 600 LFG energy projects are currently operating in 48 states. Roughly three

- fourths of these projects generate electricity, while one

- fourth are direct

- use projects in which LFG is used for its thermal capacity (EPA, 2012m ). This section summarizes LFG utilization technologies in four general categories: po wer production, cogeneration, direct use, and alternative fuel. This section also provides a discussion of the economic benefits of LFG utilization projects.

6.4.1 Technologies It is important to note that all of the technologies discussed below typically require treatment of LFG prior to entering the control device to remove moisture, particulates, and other*** Draft

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28 impurities. (While “treatment” has a specific meaning within the MSW la ndfill NSPS, the term is used more generally in common usage and as discussed here.) The level of treatment can vary depending on the type of control and the types and amounts of contaminants in the gas

. LFG is typically dehumidifi ed , filt ered , and compres s ed before being sent to energy recovery devices. For most boilers and internal combustion engines, no additional treatment is used. Some internal combustion engines and many gas turbine and microturbine projects apply siloxane removal using adsorption bed s after the dehumidification step.

Power Production
Producing electricity from LFG continues to be the most common beneficial

- use application, accounting for about three

- fourths of all U.S. LFG energy projects (EPA, 2012m ). Electricity can be produced by b urning LFG in an internal combustion engine, a gas turbine, or a
microturbine.
The majority (more than 70 percent) of LFG energy projects that generate electricity do so by combusting LFG in internal combustion engines. Advantages of this technology inclu de: low capital cost, high efficiency, and adaptability to variations in the gas output of landfills

. Internal combustion engines are well

- suited for 800 kilowatt (kW) to 3 megawatt (MW) projects, but multiple units can be used together for projects larger than 3 MW. Internal combustion engines are relatively efficient at converting LFG into electricity, achieving efficiencies in the range of 25 to 35 percent.
Gas turbines are more likely to be used for large projects, where LFG volumes are
sufficient to generate a minimum of 3 MW and typically more than 5 MW. Unlike most internal combustion engine systems, gas turbine systems have significant economies of scale. The cost per kW of generating capacity drops as gas turbine size increases, and the electric g eneration efficiency generally improves as well.
Microturbines, as their name suggests, are much smaller than turbines, with a single unit having between 30 and 250 kW in capacity, and thus are generally used for projects smaller than
1 MW. Small internal combustion engines are also available for projects in this size range and are generally less costly

. Microturbines may be selected for certain projects (rather than internal combustion engines) because they can operate with as little as 35 percent methane and less than 300 cfm, and also produce low nitrogen oxide emissions.*** Draft

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29 An LFG energy project may use multiple units to accommodate a landfill’s specific gas flow over time. For example, a project might have three internal combustion engines, two gas
turbine s, or an array of 10 microturbines, depending on gas flow and energy needs. The costs of energy generation using LFG vary greatly; they depend on many factors including the type and size of electricity generation equipment, the necessary compression and

t reatment system, and the interconnect equipment. Table 6 presents examples of typical costs for several technologies, including costs for a basic gas treatment system typically used with each technology.
Table 6 Average LFG Power Production Technology Costs

Technology Typical Capital Costs ($/kW) a Typical Annual O&M Costs ($/kW) a
Internal combustion engine (>800 kW) $1,700 $180 Small internal combustion engine (<1 MW) $2,300 $210
Gas turbine (>3 MW) $1,400 $130 Microturbine (<1 MW) $5,500 $380
Source: EPA 2010 d

a 2010 $’s

Cogeneration
LFG energy cogeneration applications, also known as combined heat and power (CHP) projects, provide greater overall energy efficiency and are growing in number. In addition to producing electricity, these projects recover and beneficially use the heat from the unit combusting LFG. LFG cogeneration projects can use internal combustion engine, gas turbine, or microturbine technologies. Less common LFG electricity generation techno logies include a few boiler/steam turbine applications in which LFG is combusted in a large boiler to generate steam which is then used by

a steam turbine to create electricity. A few combined cycle applications have also been implemented. These combine a gas turbine that combusts LFG with a steam turbine that uses steam generated from the gas turbine’s exhaust to create electricity. Boiler/steam turbine and combined cycle applications tend to be larger in scale than the majority of LFG electricity projects that use internal combustion engines.*** Draft

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30 Direct Use
The simplest and often most cost

- effective use of LFG is direct use as a fuel for boilers and other direct thermal applications to produce useful heat or steam. However, this is only an option if there is an end user located near the landfill who is willing and able to use the LFG. An
end use r ’ s energy requirements are an important consideration when evaluating the sale of LFG for direct use. Because no economical way to store LFG exists, all gas that is r ecovered must be
used as available ; gas that cannot be immediately used in energy recovery equipment is flared
and the associated revenue opportunities are lost . The ideal gas customer, therefore, will have a steady annual gas demand compatible with the la ndfill’s gas flow. When a landfill does not have adequate gas flow to support the entire needs of a facility, LFG can still be used to supply a portion of the needs. The number and diversity of direct

- use LFG applications is continuing to

grow. Boilers are the most common type of direct use , and LFG is used in boilers at a wide variety of industrial manufacturing facilities as well as commercial and institutional buildings.
Boilers can often be easily converted to use LFG alone or in combination with fo ssil fuels. Equipment modifications or adjustments may be necessary to accommodate the lower Btu value of LFG, and the costs of modifications will vary. If retuning the boiler burner is the only modification required, costs will be minimal. However, retrof itting a n existing natural gas boiler to include LFG may cost between $100,000 and $400,000, depending on the extent of the
retrofit. Direct thermal applications include kilns (e.g., cement, pottery, and brick), tunnel furnaces, process heaters, and bla cks mithing forges . In addition, infrared heaters can use LFG to fulfill space heating needs. Greenhouses can combust LFG in boilers to provide heat for the greenhouse and to heat water used in hydroponic plant culture. LFG can be used to heat the boilers in p lants that produce biofuels including biodiesel and ethanol

. Table 7 presents typical cost ranges for the components of a direct

- use project. The costs shown below for the gas compression and treatment system include compression, moisture removal, and filt ration equipment typically required to prepare the gas for transport through the pipeline and for use in a boiler or process heater. If more extensive treatment is required to remove other impurities, costs will be higher. The gas pipeline costs also assum e typical construction conditions and pipeline design. Pipelines can range from less than a mile to more*** Draft

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31 than 30 miles long, although most are shorter than 10 miles because length has a major effect on costs. In addition, the costs of direct

- use pipelines are often affected by obstacles along the route, such as highway, railroad, or water crossings. End users will likely need to modify their equipment to make it suitable for combusting LFG, but these costs are usually borne by the end
user and are site

- spec ific to their combustion device

. Table 7 Average LFG Direct

- use Project Components Costs

Component Typical Capital Costs a Typical Annual O&M Costs a
Gas compression and treatment $960/scfm $90/scfm Gas pipeline and condensate management system $330,000/mile Negligible

Source: EPA 2010 d

a 2010 $’s, based on a 1,000 scfm system scfm: standard cubic feet per minute

Alternative Fuel
Production of alternative fuels from LFG, by upgrading the gas using high

- Btu conversion technologies, is becoming more prevalent. LFG can be used to produce the equivalent of pipeline

- quality gas (natural gas), compressed natural gas (CNG), or liquefied natural gas (LNG). Pipeline

- quality gas can be injected into a n atural gas pipeline and used by residential, commercial, or industrial end users along the pipeline. CNG and LNG can be used to fuel vehicles at the landfill (e.g., water trucks, earthmoving equipment, light trucks, autos), fuel
refuse

- hauling tucks (long

- haul refuse transfer trailers and route collection trucks), and supply the general commercial market

. Although only a handful of these projects are currently operational, several more are in the construction or planning stages.
LFG can be converted into a high

- Btu gas by increasing its methane content and, conversely, reducing its carbon dioxide, nitrogen, and oxygen content. In the U nited States , three methods have been commercially employed (i.e., beyond pilot testing) to remove carbon dioxide from LFG, i ncluding membrane separation, molecular sieve (also known as pressure swing adsorption or PSA), and amine scrubbing. Recent capital costs of high

- Btu processing equipment have ranged from $2,600 to $4,300 per standard cubic foot per minute (scfm) of LFG. T he annual cost to provide electricity*** Draft

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32 to, operate, and maintain these systems ranges from $875,000 to $3.5 million (EPA 2010 d ). Costs will depend on the purity of the high

- Btu gas required by the receiving pipeline or energy
end user as well as the size of the project, since some economies of scale can be achieved when producing larger quantities of high

- Btu gas.

6.4.2 Revenues and Incentives
Landfill owners can receive revenue from the sale of carbon credits, the sale of electricity generated from LFG to the lo cal power grid, or from the sale of LFG to a direct end user or pipeline. H owever, the revenue received represents only a small percentage of the operating
costs of a landfill.

Greenhouse Gas Credits
Voluntary greenhouse gas trading programs purchase credi ts from landfills that capture LFG to destroy or convert methane contained in the gas and obtain credit for the reduction of greenhouse gas in terms of carbon equivalents. In order to qualify for these programs, the
emission reductions must be in addition to regulated actions and have recent project installation. Examples of companies operating on the voluntary carbon market include Climate Action Reserve, EcoSecurities, Evolution Markets, AgCert, Blue Source, GE/AES, and Chicago Climate Exchange (EPA 2012 a ). Bilateral trading and greenhouse gas credit sales are other voluntary sources of revenue. Bilateral trades are project

- specific and are negotiated directly between a buyer and seller of greenhouse gas credits. In these cases, corporate entities or publi c institutions, such as universities, may wish to reduce their “carbon footprint” or meet internal sustainability goals, but do not have direct access to developing their own project. Therefore, a buyer may help finance a specific project in exchange for t he credit of offsetting greenhouse gas emissions from their organization. Many state and regional government entities are establishing their own greenhouse gas initiatives to cap or minimize greenhouse gas emissions within their jurisdictions. Examples
in clude the Regional Greenhouse Gas Initiative (RGGI), the Washington carbon dioxide offset program, and the Massachusetts carbon dioxide reduction from new plants. Some of these programs establish a cap

- and

- trade program on carbon dioxide emissions, while o thers require*** Draft

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33 new fossil

- fueled boilers and power plants to either implement or contribute to funding of offset projects, including LFG. Certain LFG energy projects may qualify for participation in nitrogen oxides cap

- and

trade programs, such as the nitro gen oxides State Implementation Plan (SIP). The revenues for these incentives vary by state and will depend on factors such as the allowances allocated to each project, the price of allowances on the market, and if the project is a CHP project (typically C HP projects receive more revenue due to credit for avoided boiler fuel use).

Electricity Project Revenue
The primary revenue component of the typical electricity project is the sale of electricity to the local utility. This revenue stream is affected by th e electricity buy

- back rates (i.e., the rate at which the local utility purchases electricity generated by the LFG energy project). Electricity buy

- back rates for new projects depend on several factors specific to the local electric utility and the type of contract available to the project, but typically range between 2.5 and 7 cents per
kilowatt

- hour (kWh) (EPA, 2010 d ). When assessing the economics of an electricity project, it is also important to consider the avoided cost of the electricity used on

- site . Electricity generated by the project that is used in other operations at the landfill is, in effect, electricity that the landfill does not have to purchase from a utility. This electricity is not valued at the buy

- back rate, but at the rate the landfill is charged to purchase electricity (i.e., retail rate). The retail rate is often significantly higher than the buy

- back rate. LFG energy projects can potentially use a variety of additional environmental revenue streams, which typically take advantage of the fact that LFG is recognized as a renewable, or “green,” energy resource. These additional revenues can come from premium pricing, tax credits, greenhouse gas credit trading, or incentive payments. They can be reflected in an economic analysis in vario us ways, but typically, converting to a cents/kWh format is most useful. LFGcost accommodates four common types of electric project credits: a direct cash grant, a renewable energy tax credit expressed in dollars per kWh, a direct greenhouse gas (carbon)

c redit expressed in dollars per metric ton of carbon dioxide equivalent (discussed in
Section 6.3.2.1 ), and a direct electricity tax credit expressed in dollars per kWh. This section*** Draft

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34 includes discussion of the available environmental revenue streams that an LFG e lectricity project could possibly use. Premium pricing is often available for renewable electricity (including LFG) that is included in a green power program, through a Renewable Portfolio Standard (RPS), a Renewable Portfolio Goal (RPG), or a volun tary utility green pricing program. These programs could provide additional revenue above the standard buy

- back rate because LFG electricity is generated from a renewable resource. Renewable energy certificates (RECs) are sold through voluntary markets to consumers seeking to reduce their environmental footprint. They are typically offered in 1 megawatt

- hour (MWh) units, and are sold by LFG electricity generators to industries, commercial businesses, institutions, and even private citizens who wish to achi eve a corporate renewable energy portfolio goal or to encourage renewable energy. If the electricity produced by an LFG energy project is not being sold as part of a utility green power program or green pricing program, the project owner may be able to sel l RECs through voluntary markets to generate additional

revenue. Tax credits, tax exemptions, and other tax incentives, as well as federal and state grants,
low

- cost bonds, and loan programs are available to potentially provide funding for an LFG

energy p roject. For example, Section 45 of the Internal Revenue Code provides a per

- kWh federal production tax credit for electricity generated at privately owned LFG electricity projects. To qualify for the credit, which was 1.1 cent per kWh for the 2009 taxable year, all electricity produced must be sold to an unrelated person during the taxable year. Under legislation passed in February 2009, the placed

- in

- service date deadline for LFG energy projects to be eligible for the first 10 years of production is Decemb er 31, 2013. Another popular funding option is the Clean Renewable Energy Bond (CREB) program, which allows electric cooperatives, government entities, and public power producers to issue bonds to finance renewable energy projects including LFG electricity projects. The borrower pays back the principal of the CREB, and the
bondholder receives federal tax credits in lieu of the traditional bond interest.

Direct

- use Project Revenues
The primary source of revenue for direct

- use projects is the sale of LFG to the end user; the price of LFG, therefore, dictates a project ’s revenue. Often LFG sales prices are indexed to*** Draft

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35 the price of natural gas, but prices will vary depending on site

- specific negotiations, the type of contract, and other factors. In recent years , typical LFG prices have ranged from $4.00 to $8.00 per million British thermal units (MMBtu) or 0.38¢ to 0.75¢ per megajoule. In general, the price paid by the end user must provide an energy cost savings that outweighs the cost of required
modifications to boilers, process heaters, kilns, and furnaces in order to burn LFG. Federal and state tax incentives, loans, and grants are available that may provide
additional revenue for direct

- use projects. Greenhouse gas emissions trading programs are also poten tial revenue streams for direct

- use projects.

7 References

Alva, 2010. “Successfully Permitting a Solid Waste Landfill in a Metropolitan Area: Sunshine Landfill Expansion Project.” Paul Alva. Solid Waste Association of North America (SWANA) WASTECON 2010.
ATSDR, 2001. Landfill Gas Primer

– An Overview for Environmental Health Professionals, Chapter 2: Landfill Gas Basics. Agency for Toxic Substances and Disease Registry (ATSDR). November 2001. http://www.atsdr.cdc.gov/hac/landfill/html/ch2.html BioCycle. 2010. “17 th Nationwide Survey of MSW Management in the U.S.: The State of Garbage in America.” October 2010. < http://www.biocycle.net/2010/10/the

- state

- of

- garbage

- in

america

- 4/ >. Bloomberg Businessweek. 2012BIN. Financial Statements for Progressive Waste Solutions (BIN). Annual Income Statement as o f December 31, 2011.
< http://investing.businessweek.com/research/stocks/financials/financials.asp?ticker=BIN:CN > Bloomberg Businessweek. 2012RSG. 201 2 SEC Filings

- Republic Services Inc (RSG). 10

- K, Annual Financials, February 17, 2012.
< http://investing.businessweek.com/research/stocks/financials/se cfilings.asp?ticker=RSG >. Bloomberg Businessweek. 2012WCN. 2012 SEC Filings

- Waste Connections Inc (WCN). 10

- K, Annual Financials, February 8, 2012.
< ht tp://investing.businessweek.com/research/stocks/financials/secfilings.asp?ticker=WCN > Bloomberg Businessweek. 2012WM. 2012 SEC Filings

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