### MEMORANDUM

TO: Rachel Schmeltz, EPA

FROM: Betsy Bicknell, Amie Aguiar, and Deb Bartram, ERG

DATE: March 5, 2010

SUBJECT: Greenhouse Gas Reporting Rule, Industrial Wastewater Treatm ent Source

Category, Costs for Final Rule Monitoring Requirements - Re vised

40 CFR Part 98, known as the Greenhouse Gas (GHG) Reportin g Rule, requires facility operators to report annual emissions of GHGs. Subpart II of this rule applies to the Industrial Wastewater Treatment Source Category. This subpart appl ies to certain processes used to treat industrial wastewater and wastewater treatment sludges at pulp and paper mills, food processing facilities, ethanol production facilities, and petroleum refineries. These processes are: anaerobic reactors, anaerobic lagoons, anaerobic digesters for sl udge, and biogas destruction devices. Operators are required to report the amount of methane ( CH 4 ) these processes emit each year. The regulation specifies how operators must estimate me thane emissions. These estimation methodologies require operators to monitor the amount of wastewater entering the anaerobic treatment process, the concentration of organic materi al in the wastewater prior to treatment, the amount of biogas recovered, and the concentration of meth ane in the recovered biogas. EPA estimated that these monitoring requirements would cost, on average, $4,083 per year per facility (total annualized costs) or $1.4 million for the 358 facilit ies estimated to incur monitoring costs.

This memorandum describes how EPA estimated Subpart II monitoring costs. It describes:

• Wastewater and biogas monitoring required by 40 CFR 98.354;

• Monitoring device, labor, and operating costs;

• Estimated facility wastewater flow rates and meter co sts;

• Annualized cost calculation;

• EPA’s estimates of the number of facilities required t o monitor and source category monitoring costs; and

• Changes from proposal.

Wastewater and biogas monitoring required by 40 CFR Part 98.354

Facilities that meet the reporting threshold specified in §98.351 are required to monitor the amount of wastewater treated in anaerobic processes, t he concentration of organic material in the wastewater prior to this treatment, the amount of biogas recovered, and the concentration of methane in the recovered biogas. These monitoring requireme nts are summarized in Table 1.Memorandum

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Table 1. Industrial Wastewater Treatment Monitoring Requirem ents

Material Measured Monitoring Requirement Frequency

Wastewater flow rate Once each calendar week that the system operates, with at least three days between measurements Wastewater influent to anaerobic lagoons and anaerobic reactors

Wastewater COD or

BOD 5 concentration Once each calendar week that the system operates, with at least three days between measurements

Biogas flow rate Continuously Biogas recovered from anaerobic lagoons, anaerobic reactors, and anaerobic sludge digesters Biogas methane

concentration Once each calendar week that the system operates, with at least three days between measurements

Monitoring device, labor, and operating costs

EPA evaluated whether facilities are currently followi ng the Subpart II monitoring requirements. For requirements that are not routinely followed, EPA e stimated the costs that a typical facility would incur to meet the requirement. The estimates include o ne-time costs to purchase and install monitoring devices and recurring costs for analytic al services, supplies, and labor. The one-time costs are capital costs, while recurring costs are annual costs.

Wastewater Flow Rate. When the treatment system is operating, facilities ar e required to measure the flow rate of wastewater entering anaerobic wastewater treatment process once each calendar week, with at least three days between measur ements. The flow measurement location and collection period must correspond to the location an d period used to collect samples analyzed for COD or BOD 5 concentration.

EPA assumed that facilities do not currently measure t he flow of wastewater into the anaerobic treatment process. Thus, facilities would be required to install meters to meet the GHG Reporting Rule monitoring requirements. EPA assumed that each fac ility would install a flow meter, such as the McCrometer Ultra Mag ® electromagnetic flow meter, equipped with a standard keypad display, or equivalent. Because these meters are designe d to measure flow in full pipes, EPA assumed the wastewater from the industrial facility drops into a wet well/lift station and is pumped from there into the anaerobic treatment unit. The flow meter is placed on the positive pressure pipe from the lift station at a point near th e lagoon or reactor where influent sampling would occur. Installation costs include welded flanges to attach meters to existing piping, plumbing and electrical (based on cost factors obtained f rom R.S. Means Building Construction

Cost Data , 59th Edition, 2001), and costs for permits, scheduling, and c ontractor markup (handling, procuring, subcontracting, change orders, overhead a nd profit). These meters are factory calibrated, have no moving parts, and require minima l maintenance. For these reasons,

EPA did not include costs for flow meter maintenance o r calibration. Flow meter cost is based on the pipe size and flow measured, as presented in Table 2.Memorandum

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Table 2. Wastewater Flow Meter Installed Costs (2009$)

Pipe diameter (inches) Flow

(MGD) Meter Cost ($ ) Installation Cost Total Installed Cost ($)

4 0.01 to 2.8 4,266 a

8 0.05 to 11 3,685 3,550 7,235

16 0.16 to 44 5,830 5,922 11,752

24 0.4 to 99 8,910 9,064 17,974

a

– Installed costs for the 4 inch meter were extrapolated f rom a cost curve developed from costs for the 8, 16, an d

24 inch meters.

EPA assumed that facilities would incur labor costs fo r collecting and organizing flow rate measurement data. EPA assumed that this activity would requ ire two hours per month of a Grade 8 wastewater treatment plant operator. EPA further assu med the labor cost for a Grade 8 operator is $20/hour, so that the annual labor costs for flow measur ement are estimated as 2 hour/month x $20/hour x 12 month/year = $480/year. (See further discussion of labor costs below.)

Concentration of Organic Material in the Wastewater Prior to Treatment. Facilities are required to collect samples of the wastewater entering the ana erobic wastewater treatment process. The samples must be collected after all preliminary and pri mary treatment steps (e.g., after grit removal, primary clarification, oil-water separation, dissolved air flotation, or similar solids and oil separation processes). When the treatment system is operating, facilities are required to collect and analyze wastewater samples for COD or BOD 5 concentration once each calendar week, with at least three days between measurements.

EPA assumed that facilities that treat wastewater wi th anaerobic lagoons or reactors currently sample and analyze their treated wastewater discharges a ccording to their permit requirements. These requirements may be imposed by a National Pollutio n Discharge Elimination System (NPDES) permit (for facilities that discharge to lakes or streams) or pretreatment permits (for facilities that discharge to municipal sewer systems). Because facilities currently sample and analyze their treated wastewater, EPA assumed that th ey have all necessary capital equipment, such as automatic compositors, to conduct wastewater sam pling activities.

EPA assumed that facilities would contract with an ana lytical laboratory for analysis of their samples. EPA assumed the cost for analysis for COD or BOD 5 were the same, $30/sample. Costs for sample analysis were thus estimated as $30/sample x 1 sample/week x 52 weeks/year = $1,560/year.

EPA further assumed that facilities would incur labor costs for coll ecting the sample. EPA assumed that this activity would require one hour per samp le of a Grade 8 wastewater treatment plant operator. EPA further assumed the labor cost for a Grade 8 operator is $20/hour, so that the annual labor costs for sample collection are estimate d as 1 hour/week x $20/hour x 52 weeks/year = $1,040/year. Total annual costs for wastewater sampling and analysis were estimated as $1,560 + $1,040 = $2,600/year.

Biogas Flow Rate. For each anaerobic process (such as anaerobic reactor, di gester, or lagoon) from which biogas is recovered, facilities must continuous ly measure the gas flow rate andMemorandum

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determine the cumulative volume of gas recovered. Facil ities must also determine the methane concentration at a location near or representative o f the location of the gas flow meter. Facilities must install, operate, maintain, and calibrate a gas fl ow meter capable of continuously measuring the volumetric flow rate of the recovered biogas using on e of the methods specified in paragraphs §98.354 (g)(1) through (g)(8) or as specified by the man ufacturer.

EPA assumed that facilities that recover biogas from w astewater treatment processes such as anaerobic reactors, digesters, or lagoons currently operat e continuous gas flow rate measurement devices that meet the requirements of §98.354 (g) and thus would incur no additional capital or operating costs to comply with this monitoring requirement

.

Biogas Methane Concentration. For each anaerobic process (such as an anaerobic reactor

, digester, or lagoon) from which biogas is recovered, faci lities must measure the methane concentration either continuously or intermittently a t least once each calendar week that the system operates, with at least three days between mea surements. As specified in §98.353(c), they must also determine the temperature, pressure, and moisture content of the recovered biogas as necessary to accurately determine the gas flow rate and m ethane concentration. Facilities are also required to calibrate the gas composition monitors prior t o the first reporting year and recalibrate the monitors either annually or at the minimum frequency specified by the manufacturer.

For the purpose of estimating costs for compliance with Subpart II of the GHG Reporting Rule, EPA assumed that facilities that recover biogas from w astewater treatment processes do not currently monitor the gas composition and would incur cost s to install and operate gas composition monitors. EPA assumed that facilities would conduct semi-continuous monitoring, such that they determine methane concentration once per week. There are many different methods for measuring biogas methane concentration. To es timate compliance costs, EPA assumed that facilities would install and operate an Ino va 1316-1 multi-gas nondispersive infrared (NDIR) monitor, or equivalent, at an installed c ost of $5,900. NDIR monitors do not require temperature or moisture compensation. EPA assumed that the monitor would be housed in a temperature-controlled, NEMA enclosure, protected fro m the elements. EPA further assumed that the monitor would be installed following in-l ine devices that control the moisture and hydrogen sulfide content of the biogas stream.

EPA assumed that facilities would purchase gas calibrati on supplies at a cost of $200/year. EPA

further assumed that facilities would incur labor costs fo r calibration of the gas analyzer and reporting annual methane recovery and emissions. EPA assume d that this activity would require 14 hours per year at a labor rate of $50/hour, so that the a nnual labor costs for monitoring methane concentration and reporting methane emissions w ere estimated as 14 hours/year x $50/hour = $700/year.

Labor Costs. EPA assumed that wastewater samples and emission calc ulations will be performed by a Grade 8 Wastewater Treatment Plant Operator. Grade 8 wastewater treatment plant operators provide secondary treatment of wastewater in addition to the pretreatment and primary treatment performed at Grade 7. Grade 8 operators do more extensive testing than Grade 7 operators to determine such things as BOD 5 , suspended and dissolved solids, and dissolved oxygen. Operators at this level record the results in sta ndardized reports designed to meetMemorandum

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Federal and State regulations. 1 Labor costs for a Grade 8 wastewater treatment plant operator are estimated to be $20 an hour on average. 2 EPA assumed that labor costs for a treatment plant supervisor is $40 per hour. EPA also assumed that operation o f biogas monitoring equipment requires more skilled staff. These tasks are assumed to require labor at a cost of $50 per hour.

Monitoring Cost Elements. Unit costs EPA assumed that facilities would incur to c omply with Subpart II of the GHG Reporting Rule are summarized in T able 3.

Table 3. Monitoring Cost Elements (2009$)

Monitoring Element Equipment Assumptions Capital Cost (total installed) Operation Assumptions Annual

Costs

Wastewater influent to anaerobic lagoons and anaerobic reactors

Wastewater flow rate no baseline flow meters

costs for McCrometer UltraMag, plus installation;

cost based on flow $4,266 to $10,116 a no calibration required

no maintenance required collect and organize flow

data 1x/month

2 hr/month of Grade 8 WWTP operator @ $20/hr $480

Wastewater COD or

BOD 5 concentration all plants have needed sampling equipment 0 analysis cost $30/sample 52 samples/year 1 hr labor/sample @ $20/hr $2,600

Calculations and reporting na 0 8 hr/yr of Grade 8 WWTP operator @ $20/hr + 1 hr review, supervisor @ $40/hr $200

Biogas recovered from anaerobic lagoons, anaerobic reactors, and anaer obic sludge digesters

Biogas flow rate all plants that recover biogas

have continuous flow meters

installed 0 no additional calibration

and maintenance $0

Biogas methane

concentration No baseline gas composition

monitors. Costs for Inova 1316-1 multi-gas NDIR monitor, includes installation $5,900 gas analyzer calibration supplies $200

Calculations and reporting na $0 labor to report annual methane recovery and

emissions and to calibrate the gas analyzer: 14 hr/yr @ $50/hr $700

a

– Flow meter cost is a function of flow, see Table 5.

Estimated facility wastewater flow rates and meter costs

EPA assumed that facilities do not currently measure t he flow of wastewater into the anaerobic treatment process and thus would be required to install met ers. Flow meter cost is based on the pipe size and flow measured (see Table 2). For this reaso n, EPA estimated facility wastewater

1 Federal Wage System Job Grading Standard for Wastewater Treatment Plant Operating, 5408, TS-64 May 1992.

2 U.S. Office of Personnel Management, Salaries and Wages , SALARY TABLE 2009-GS, January 2009.Memorandum

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flow rates. EPA estimated wastewater flow rates for pulp and paper mills, food processing facilities, ethanol production facilities, and petroleum refineries.

Pulp and Paper Mills. EPA most recently revised the regulations limiting pollutan t discharges for the pulp, paper, and paperboard industry in 1998. Informatio n collected in support of this rulemaking, is available in the Development Document for Proposed Effluent Limitations Guidelines and Standards for the Pulp, paper, and Paperboard Point Source Category , EPA821-R-93-019, October 1993. Table 11-24 of this document presents the fl ow rate of wastewater

treated in 16 aerated stabilization basins. The flow rat es ranged from 1 to 50 million gallons/day (MDG) with median approximately 10 MGD. EPA assumed that flow rates of wastewater treated in anaerobic lagoons are similar to the flow rates tre ated in aerobic stabilization basis. EPA further notes that pulp and paper mills are among the largest industrial water users and many mills have flow rates greater than 50 MGD. For estimat ing costs of wastewater flow meters, EPA assumed the meter sizes presented in Table 4 would be requi red.

Table 4. Wastewater Flow Meters for Pulp and Paper Mills

Percent of Pulp and Paper Mills Meter Size (pipe diameter, inches) Flow Range (MGD)

50 8 0.05 to 11

40 16 0.16 to 44

10 24 0.4 to 99

Based on this distribution and the meter costs presented in Table 2, EPA estimated the average wastewater flow meter cost for a pulp and paper mill woul d be $10,116.

Food Processing Facilities. EPA most recently revised regulations limiting pollutant d ischarges for meat and poultry products category in 2004. Information c ollected in support of this rulemaking, is available in the Technical Development Document for the Final Effluent Limitations Guidelines and Standards for the Meat and Poultry Products Point Sourc e Category (40 CFR 432) , EPA-821-R-04-011, 2004. Table 6-3 of this document reports that a ho g plant and a cattle plant each generated 4 MGD of wastewater. EPA also found wastewater treatment design flow data reported in its NPDES monitoring databases for f acilities in SIC 2011 (meat packing plants) or 2013 (sausages and other prepared meat products). Th e average design flow was 0.8 MGD. EPA concluded that food processing flows are typica lly less than 11 MGD. Further, for purposes of estimating monitoring costs, EPA assumed food p rocessing facilities would require an 8 inch flow meter, at an installed cost of $7,235.

Ethanol Production Facilities. In support of EPA’s inventory of greenhouse gas emissions, EP A reviewed ethanol production in the United States and made ini tial estimates of the GHG emissions from wastewater treatment operations conduct ed at these facilities. The results of this review are presented in Memorandum: Assessment of Greenhouse Gas Emissions from Wastewater Treatment of U.S. Ethanol Production Wastewaters , ERG, 2006. EPA found that wastewater discharges from dry milling ethanol plants ra nged from 0.04 to 0.6 MGD. Although flow rates for wet milling plants were not presented in the memorandum, the authors noted that wet milling operations were generally smaller than dry mi lling operations. EPA concluded that ethanol production facility flows are typically less t han 3 MGD. Further, for purposes ofMemorandum

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estimating monitoring costs, EPA assumed ethanol productio n facilities would require a 4 inch flow meter, at an installed cost of $4,266.

Petroleum Refineries. EPA’s Office of Water reviewed petroleum refinery polluta nt discharges in 1992 – 1993, and published the results in the Preliminary Data Summary for the Petroleum Refining Category , April 1996. At that time, EPA found that wastewater flow s ranged from 0.4 to 8 MGD, with median flow rate of 1.5 MGD. EPA concluded that petroleum refinery flows are typically less than 11 MGD. Further, for purposes of es timating monitoring costs, EPA assumed petroleum refineries would require an 8 inch flow meter, at an installed cost of $7,235.

Meter Capital Costs. The flow rates and meter sizes and costs that EPA as sumed that facilities would incur to comply with Subpart II of the GHG Reporting Rule are summarized in Table 5.

Table 5. Wastewater Flow Meter Sizes and Costs

Source Category Flow Range (MGD) Meter Size

(pipe diameter, inches) Meter Installed Cost (2009 $)

Pulp and Paper Mills 1 to 100 8 to 24 10,116

Food Processing Facilities less than 11 8 7,235

Ethanol Production Facilities less than 3 4 4,266

Petroleum Refineries less than 11 8 7,235

Annualized costs

EPA assumed that the capital equipment lifetime was 20 years and used that lifetime and an interest rate of 7 percent to annualize capital costs. Annualized capital costs were calculated using the formula:

Annual cost = capital cost* 

## { [0.07*(1+0.07) 20 ]/[(1+0.07) 20-1 ] 

## }

Estimated number of facilities required to monitor and sour ce category monitoring costs

Only facilities that meet the reporting thresholds specif ied in §98.351 are required to report the

methane emitted from their industrial wastewater treat ment operations. Thus, only a subset of pulp and paper mills, food processing facilities, ethanol pr oduction facilities, and petroleum refineries must meet the monitoring requirements in §98.354. Further, only this subset of facilities will incur monitoring costs.

EPA estimated the number of pulp and paper mills, food proc essing facilities, ethanol production facilities, and petroleum refineries that would be requir ed to report in order to estimate monitoring costs. EPA’s estimates follow the assumptio ns used in EPA’s Inventory of U.S.

Greenhouse Gas Emissions and Sinks: 1990 – 2007. April 2009 (the 2007 Inventory).

Pulp and Paper Mills. For the purpose of this cost estimate, EPA assumed that there are 565 pulp and paper mills ( Development Document for Proposed Effluent Limitations Guidelines and Standards for the Pulp, paper, and Paperboard Point Source Category , EPA-821-R-93-019, October 1993). Based on assumptions presented in Table 8-11 of th e 2007 Inventory, EPAMemorandum

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estimated that 25% (141) of these mills have anaerobic seco ndary treatment. Further, EPA assumed that all 141 mills with anaerobic secondary treat ment would be required to report their

methane emissions 3 . EPA estimated that none of these mills recover bioga s from their anaerobic wastewater treatment. Thus, EPA assumed that 141 pulp and pa per mills would incur costs for monitoring wastewater flow rate and for collecting and analyzing samples for COD or BOD 5 concentration. EPA estimated that no mills would incur costs for monitoring biogas flow rate or biogas methane concentration. EPA estimated that pulp an d paper mills would incur $598,000 in total annualized costs to meet the monitoring requirements of the GHG reporting rule.

Food Processing Facilities. Food processing facilities are required to report their G HG emissions if they exceed 25,000 metric tons CO2e per year in combined emissions from stationary fuel combustion units, industrial landfills, and industrial wastewater treatment. However, for the purpose of this cost estimate, EPA as sumed only food processing facilities that exceed 25,000 metric tons CO2e per year in emissions from i ndustrial wastewater treatment would incur monitoring costs.

EPA’s estimates of the number of food processing facili ties meeting the reporting threshold are presented in the Technical Support Document for Industrial Wastewater Treatment . EPA estimated that 13 meat processing facilities exceed the 25,000 metric tons CO2e per year threshold and would be required to report the methane emitte d from their industrial wastewater treatment operations. EPA did not have sufficient informa tion to estimate the number of poultry processing facilities that exceed the 25,000 metric ton thr eshold, but estimated that up to 50 facilities emitted more than 10,000 metric tons CO2e per ye ar. For the purpose of this cost estimate, EPA assumed that all 50 of these facilities would incur monitoring costs. EPA estimated that no fruit and vegetable processing faciliti es exceed the 25,000 metric tons CO2e per year threshold and thus they would not be required to re port.

Thus, EPA assumed that 63 food processing facilities (13 mea t processors and 50 poultry processors) would be required to report the methane emitted from their industrial wastewater treatment operations. EPA estimated that none of these plants recover biogas from their anaerobic wastewater treatment. Thus, EPA assumed that 63 food processing facilities would incur costs for monitoring wastewater flow rate and for collecting and analyzing samples for

COD or BOD 5 concentration. EPA estimated that no food processing facilities would incur costs for monitoring biogas flow rate or biogas methane concent ration. EPA estimated that food processing facilities would incur $250,000 in total annualized cos ts to meet the monitoring requirements of the GHG reporting rule.

Ethanol Production Facilities. Ethanol production facilities are required to report the ir GHG emissions if they exceed 25,000 metric tons CO2e per year in combined emissions from stationary fuel combustion units, industrial landfills, and industrial wastewater treatment. However, for the purpose of this cost estimate, EPA as sumed only ethanol production facilities that exceed 25,000 metric tons CO2e per year in emissions f rom industrial wastewater treatment would incur monitoring costs.

3 Pulp and paper mills are required to report if they emit 25,000 metric tons CO2e or more per year in combined emissions. See §98.2(a)(2).Memorandum

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Using data reported by the Renewable Fuels Association, EPA estimated there were 170 operating ethanol production facilities as of January 2009. E PA estimated that 85% (145) of these facilities used dry milling operations and 15% (25) used wet milling. Based on assumptions presented in Table 8-11 of the 2007 Inventory, EPA estimated that anaerobic wast ewater treatment is used by 75% (108) of the dry milling facilities a nd 33% (8) of the wet milling facilities, or a total of 116 ethanol production facilitie s.

EPA’s estimates of the number of ethanol production fac ilities meeting the reporting threshold are presented in the Technical Support Document for Industrial Wastewater Treatment . EPA assumed that four (4) of the 116 ethanol production facilit ies that use anaerobic wastewater treatment emits methane in excess of the 25,000 metric to ns CO2e per year threshold. EPA also assumed that these four facilities recover biogas from its anaerobic wastewater treatment. EPA estimated ethanol production facilities would incur $20,600 in t otal annualized costs to meet the monitoring requirements of the GHG reporting rule.

Petroleum Refineries. Based on data from the Energy Information Administrati on, EPA determined that there were 150 operable petroleum refineries as of January 2009. Using assumptions presented in Table 8-11 of the 2007 Inventory, EPA estimated that 100% (150) of these refineries have anaerobic secondary treatment. Furt her, EPA notes that all petroleum refineries are required to report their methane emissions 4 . EPA estimated that none of the refineries recover biogas from their anaerobic wastewat er treatment. Thus, EPA assumed that 150 petroleum refineries would incur costs for monitoring wa stewater flow rate and for collecting and analyzing samples for COD or BOD 5 concentration. EPA estimated that no refineries would incur costs for monitoring biogas flow rate or biogas methane concentration. EPA estimated that petroleum refineries would incur $594,000 i n total annualized costs to meet the monitoring requirements of the GHG reporting rule.

Estimated Monitoring Costs. The total estimated monitoring costs are presented in Tabl e 6.

Changes from proposal

The estimated costs presented in this memorandum differ from the estimated costs of the proposed Subpart II as follows:

At proposal, EPA assumed that all facilities were equi pped with flow meters to measure the flow

of wastewater into the anaerobic treatment units. In r esponse to comments on the proposed rule, EPA revised this assumption. The estimated costs presente d in this memorandum are based on the assumption that no facilities currently meter the wastewater flow into their anaerobic

treatment units.

4 All petroleum refineries must report emissions from al l source categories and GHGs for which calculation methodologies are provided in the rule. See §98.2(a)(1).MemorandumMarch 5, 2010Page 10Table 6. Industrial Wastewater Treatment Monitoring CostsNational (Scaled-Up) Estimated CostsNational (Scaled-Up) Estimated CostsNational (ScaledUp) EstimatedCostsCategoryNo. ofPlantsRequiredto Report%PlantswithAnaerobicTreatmentNo. ofPlantswithAnaerobicTreatmentNo. ofPlantswith CH4RecoveryWWMonitoringCosts -CapWWMonitoringCosts -AnnualizedCapWWMonitoringCosts -AnnualWWMonitoringCosts -TACCH4RecoveryMonitoringCosts -CapCH4RecoveryMonitoringCosts -AnnualizedCapCH4RecoveryMonitoringCosts -AnnualCH4RecoveryMonitoringCosts -TACTotal(WW +CH4recovery)Monitoring TACPulp and paper 565 25% 141.25 0 $1,428,843 $134,873 $463,300 $598,173 0 $0 $0 $0.00 $598,173Food Processing 63 100% 63 0 $455,805 $43,025 $206,640 $249,665 $0 $0 $0 $0.00 $249,665Ethanol - wet mill15% of 170 mills4 100% 4 4 $17,064 $1,611 $13,120 $14,731 $23,600 $2,228 $3,600 $5,827.67$20,558Ethanol - dry mill85% of 170 mills0 75% 0 0 $0 $0 $0 $0 $0 $0 $0 $0.00 $0PetroleumRefineries150 100% 150 0 $1,085,250 $102,440 $492,000 $594,440 $0 $0 $0 $0.00 $594,440Total 355.25 $1,447,417Cap – capital costsTAC – total annualized costs (annualized capital costs plusannual costs)Memorandum

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At proposal, EPA assumed that non-continuous monitoring of biogas recovered from anaerobic digestion systems would require a hand held gas compositio n analyzer, a temperature sensor, and a gas pressure sensor. EPA estimated the total cost for these devices to be $1,000. EPA obtained updated information on the installed cost of a multi-gas ND IR monitor (temperature and pressure compensation are not required for this type of monitor). EP A estimated the installed cost for this monitor to be $5,900.

At proposal, EPA assumed that wastewater sampling and a nalysis would be conducted once per month. The final regulation requires sampling and analysi s once each calendar week that the system operates, with at least three days between mea surements. EPA increased the estimated costs for wastewater sampling and analysis to reflect t his increased frequency. EPA did not change its estimates of the costs and labor required pe r sample.

EPA did not change its estimates of the labor and mate rials required to conduct the monitoring program and report methane emissions to EPA.