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 Treatment Source 

Category, Costs for Final Rule Monitoring Requirements - Revised 

40 CFR Part 98, known as the Greenhouse Gas (GHG) Reporting 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 applies 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 sludge, and biogas destruction devices. 

Operators are required to report the amount of methane (CH4) these processes emit each year. 

The regulation specifies how operators must estimate methane emissions. These estimation 

methodologies require operators to monitor the amount of wastewater entering the anaerobic 

treatment process, the concentration of organic material in the wastewater prior to treatment, the 

amount of biogas recovered, and the concentration of methane 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 facilities 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 costs; 

• Annualized cost calculation; 

• EPA’s estimates of the number of facilities required to 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, the 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 requirements are summarized in Table 1. 
Memorandum 

March 5, 2010 

Page 2 

Table 1. Industrial Wastewater Treatment Monitoring Requirements 

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 

BOD5 concentration 

Once each calendar week that the system operates, 

with at least three days between measurements 

Biogas recovered from anaerobic Biogas flow rate Continuously 

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 following the Subpart II monitoring requirements. 

For requirements that are not routinely followed, EPA estimated the costs that a typical facility 

would incur to meet the requirement. The estimates include one-time costs to purchase and 

install monitoring devices and recurring costs for analytical 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 are required to 

measure the flow rate of wastewater entering anaerobic wastewater treatment process once each 

calendar week, with at least three days between measurements. The flow measurement location 

and collection period must correspond to the location and period used to collect samples 

analyzed for COD or BOD5 concentration. 

EPA assumed that facilities do not currently measure the 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 facility 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 designed 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 the 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 from R.S. Means Building Construction 

Cost Data, 59th Edition, 2001), and costs for permits, scheduling, and contractor markup 

(handling, procuring, subcontracting, change orders, overhead and profit). These meters are 

factory calibrated, have no moving parts, and require minimal maintenance. For these reasons, 

EPA did not include costs for flow meter maintenance or calibration. Flow meter cost is based on 

the pipe size and flow measured, as presented in Table 2. 
Memorandum 

March 5, 2010 

Page 3 

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 from a cost curve developed from costs for the 8, 16, and 

24 inch meters. 

EPA assumed that facilities would incur labor costs for collecting and organizing flow rate 

measurement data. EPA assumed that this activity would require two hours per month 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 flow measurement 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 anaerobic wastewater treatment process. The 

samples must be collected after all preliminary and primary 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 BOD5 concentration once each calendar 

week, with at least three days between measurements. 

EPA assumed that facilities that treat wastewater with anaerobic lagoons or reactors currently 

sample and analyze their treated wastewater discharges according to their permit requirements. 

These requirements may be imposed by a National Pollution 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 they have all necessary capital equipment, 

such as automatic compositors, to conduct wastewater sampling activities. 

EPA assumed that facilities would contract with an analytical laboratory for analysis of their 

samples. EPA assumed the cost for analysis for COD or BOD5 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 collecting the sample. EPA 

assumed that this activity would require one hour per sample 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 estimated 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, digester, or lagoon) 

from which biogas is recovered, facilities must continuously measure the gas flow rate and 
Memorandum 

March 5, 2010 

Page 4 

determine the cumulative volume of gas recovered. Facilities must also determine the methane 

concentration at a location near or representative of the location of the gas flow meter. Facilities 

must install, operate, maintain, and calibrate a gas flow meter capable of continuously measuring 

the volumetric flow rate of the recovered biogas using one of the methods specified in 

paragraphs §98.354 (g)(1) through (g)(8) or as specified by the manufacturer. 

EPA assumed that facilities that recover biogas from wastewater treatment processes such as 

anaerobic reactors, digesters, or lagoons currently operate 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, facilities must measure the methane 

concentration either continuously or intermittently at least once each calendar week that the 

system operates, with at least three days between measurements. 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 methane concentration. Facilities are also 

required to calibrate the gas composition monitors prior to 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 wastewater treatment processes do not 

currently monitor the gas composition and would incur costs 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 estimate compliance costs, EPA 

assumed that facilities would install and operate an Inova 1316-1 multi-gas nondispersive 

infrared (NDIR) monitor, or equivalent, at an installed cost 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 from the elements. EPA further 

assumed that the monitor would be installed following in-line devices that control the moisture 

and hydrogen sulfide content of the biogas stream. 

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

further assumed that facilities would incur labor costs for calibration of the gas analyzer and 

reporting annual methane recovery and emissions. EPA assumed that this activity would require 

14 hours per year at a labor rate of $50/hour, so that the annual labor costs for monitoring 

methane concentration and reporting methane emissions were estimated as 14 hours/year x 

$50/hour = $700/year. 

Labor Costs. EPA assumed that wastewater samples and emission calculations 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 BOD5, suspended and dissolved solids, and dissolved 

oxygen. Operators at this level record the results in standardized reports designed to meet 
Memorandum 

March 5, 2010 

Page 5 

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 of 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 comply with 

Subpart II of the GHG Reporting Rule are summarized in Table 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 

$10,116a 

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 

BOD5 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 anaerobic 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 the flow of wastewater into the anaerobic 

treatment process and thus would be required to install meters. Flow meter cost is based on the 

pipe size and flow measured (see Table 2). For this reason, 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 

March 5, 2010 

Page 6 

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 pollutant discharges 

for the pulp, paper, and paperboard industry in 1998. Information 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 flow rate of wastewater 

treated in 16 aerated stabilization basins. The flow rates 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 treated 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 estimating costs of wastewater flow meters, EPA 

assumed the meter sizes presented in Table 4 would be required. 

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 would be $10,116. 

Food Processing Facilities. EPA most recently revised regulations limiting pollutant discharges 

for meat and poultry products category in 2004. Information collected 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 Source Category 

(40 CFR 432), EPA-821-R-04-011, 2004. Table 6-3 of this document reports that a hog 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 facilities in SIC 2011 (meat packing 

plants) or 2013 (sausages and other prepared meat products). The average design flow was 0.8 

MGD. EPA concluded that food processing flows are typically less than 11 MGD. Further, for 

purposes of estimating monitoring costs, EPA assumed food processing 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, EPA 

reviewed ethanol production in the United States and made initial estimates of the GHG 

emissions from wastewater treatment operations conducted 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 ranged 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 milling operations. EPA concluded that 

ethanol production facility flows are typically less than 3 MGD. Further, for purposes of 
Memorandum 

March 5, 2010 

Page 7 

estimating monitoring costs, EPA assumed ethanol production 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 pollutant 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 flows 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 estimating 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 assumed 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 source category monitoring costs 

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

methane emitted from their industrial wastewater treatment operations. Thus, only a subset of 

pulp and paper mills, food processing facilities, ethanol production 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 processing facilities, ethanol production 

facilities, and petroleum refineries that would be required to report in order to estimate 

monitoring costs. EPA’s estimates follow the assumptions 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 the 2007 Inventory, EPA 
Memorandum 

March 5, 2010 

Page 8 

estimated that 25% (141) of these mills have anaerobic secondary treatment. Further, EPA 

assumed that all 141 mills with anaerobic secondary treatment would be required to report their 

methane emissions3. EPA estimated that none of these mills recover biogas from their anaerobic 

wastewater treatment. Thus, EPA assumed that 141 pulp and paper mills would incur costs for 

monitoring wastewater flow rate and for collecting and analyzing samples for COD or BOD5

concentration. EPA estimated that no mills would incur costs for monitoring biogas flow rate or 

biogas methane concentration. EPA estimated that pulp and 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 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 assumed only food processing facilities that 

exceed 25,000 metric tons CO2e per year in emissions from industrial wastewater treatment 

would incur monitoring costs. 

EPA’s estimates of the number of food processing facilities 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 emitted from their industrial wastewater 

treatment operations. EPA did not have sufficient information to estimate the number of poultry 

processing facilities that exceed the 25,000 metric ton threshold, but estimated that up to 50 

facilities emitted more than 10,000 metric tons CO2e per year. 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 facilities exceed the 25,000 metric tons CO2e 

per year threshold and thus they would not be required to report. 

Thus, EPA assumed that 63 food processing facilities (13 meat 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 BOD5 concentration. EPA estimated that no food processing facilities would incur costs 

for monitoring biogas flow rate or biogas methane concentration. EPA estimated that food 

processing facilities would incur $250,000 in total annualized costs to meet the monitoring 

requirements of the GHG reporting rule. 

Ethanol Production Facilities. Ethanol production facilities are required to report their 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 assumed only ethanol production facilities 

that exceed 25,000 metric tons CO2e per year in emissions from 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 

March 5, 2010 

Page 9 

Using data reported by the Renewable Fuels Association, EPA estimated there were 170 

operating ethanol production facilities as of January 2009. EPA 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 wastewater 

treatment is used by 75% (108) of the dry milling facilities and 33% (8) of the wet milling 

facilities, or a total of 116 ethanol production facilities. 

EPA’s estimates of the number of ethanol production facilities 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 facilities that use anaerobic wastewater 

treatment emits methane in excess of the 25,000 metric tons 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 total annualized costs to meet the 

monitoring requirements of the GHG reporting rule. 

Petroleum Refineries. Based on data from the Energy Information Administration, 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. Further, EPA notes that all petroleum 

refineries are required to report their methane emissions4. EPA estimated that none of the 

refineries recover biogas from their anaerobic wastewater treatment. Thus, EPA assumed that 

150 petroleum refineries would incur costs for monitoring wastewater flow rate and for 

collecting and analyzing samples for COD or BOD5 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 in total annualized costs to meet 

the monitoring requirements of the GHG reporting rule.

Estimated Monitoring Costs. The total estimated monitoring costs are presented in Table 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 equipped with flow meters to measure the flow 

of wastewater into the anaerobic treatment units. In response to comments on the proposed rule, 

EPA revised this assumption. The estimated costs presented 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 all source categories and GHGs for which calculation 

methodologies are provided in the rule. See §98.2(a)(1). 
Memorandum 

March 5, 2010 Page 10 

Table 6. Industrial Wastewater Treatment Monitoring Costs 

National (Scaled-Up) Estimated Costs National (Scaled-Up) Esti

Category

No. of 

Plants 

Required 

to Report

%Plants 

with 

Anaerobic 

Treatment

No. of 

Plants 

with 

Anaerobic 

Treatment

No. of 

Plants 

with CH4 

Recovery

WW 

Monitoring 

Costs -Cap

WW 

Monitoring 

Costs -

Annualized 

Cap 

WW 

Monitoring 

Costs -

Annual 

WW 

Monitoring 

Costs -TAC

CH4 

Recovery 

Monitoring 

Costs -Cap

CH4 

Recovery 

Monitoring 

Costs -

Annualized 

Cap 

CH

Reco

Monit

Cos

Ann

Pulp and paper 565 25% 141.25 0 $1,428,843 $134,873 $463,300 $598,173 0 $0 $0 Food Processing 63 100% 63 0 $455,805 $43,025 $206,640 $249,665 $0 $0 $0 Ethanol - wet mill15% of 170 mills 4 100% 4 4 $17,064 $1,611 $13,120 $14,731 $23,600 $2,228 $3,6Ethanol - dry mill85% of 170 mills 

0 75% 0 0 $0 $0 $0 $0 $0 $0 $0 

Petroleum Refineries 

150 100% 150 0 $1,085,250 $102,440 $492,000 $594,440 $0 $0 $0 

Total 355.25 

Cap – capital costs TAC – total annualized costs (annualized capital costs plus annual costs) 
Memorandum 

March 5, 2010 

Page 11 

At proposal, EPA assumed that non-continuous monitoring of biogas recovered from anaerobic 

digestion systems would require a hand held gas composition 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 NDIR monitor (temperature and pressure 

compensation are not required for this type of monitor). EPA estimated the installed cost for this 

monitor to be $5,900. 

At proposal, EPA assumed that wastewater sampling and analysis would be conducted once per 

month. The final regulation requires sampling and analysis once each calendar week that the 

system operates, with at least three days between measurements. EPA increased the estimated 

costs for wastewater sampling and analysis to reflect this increased frequency. EPA did not 

change its estimates of the costs and labor required per sample. 

EPA did not change its estimates of the labor and materials required to conduct the monitoring 

program and report methane emissions to EPA.