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MEMORANDUM 

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

Programs Division, Fuel and Incineration Group 

FROM: Eastern Research Group, Inc. (ERG) 

DATE: April 2014 

SUBJECT: Cost and Emissions Impacts Resulting from the Landfills NSPS Review 

Introduction 

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

emission reductions for the 2014 review of the new source performance standards (NSPS) for municipal 

solid waste (MSW) landfills. These impacts were calculated for new landfills that are projected to 

commence construction, reconstruction, or modification in the first 5 years after proposal (between 2014 

and 2018). The equations and data inputs used to estimate the impacts are discussed in other memoranda 

in the docket. 1,2,3

Results are presented in 2012 dollars ($2012) and are based on the annualized costs in 2023 using 

an interest rate of 7 percent. By 2023, the new model landfills have reached a point in their lifecycle at 

which at least half of the models trigger the NMOC emission threshold, install controls, and therefore 

incur costs and emission reductions for most of the options under consideration in this review. 

The results of the impacts analysis are presented for the proposed changes to the NSPS (the 

proposal) as well as several options. The results are presented as incremental impacts relative to impacts 

associated with the current design capacity and NMOC emission thresholds currently in 40 CFR part 60, 

subpart WWW. Landfill-specific details of each option under consideration are documented in the 

modeling database.4

 This memorandum is organized as follows: 

1.0 Overview of Regulatory Options 

2.0 Estimating Cost Impacts 

3.0 Estimating Emission Reductions Impacts 

4.0 Estimating Impacts for Enhanced Surface Emission Monitoring 

5.0 References 

Appendix A: Index of Regulatory Options 

Appendix B: Charts Tracking Impact of NMOC Emission Thresholds and Lag Times Over Time 

Appendix C: Detailed Cost and Emission Reduction Impacts 

1. Overview of Regulatory Options 

Descriptions of the current regulatory baseline, the proposed revision, and alternative options are 

included in this section. 
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1.1 Baseline 

 Currently, 40 CFR part 60, subpart WWW requires all landfills with a design capacity of 

2.5 million megagrams (Mg) and 2.5 million cubic meters or greater to report their NMOC 

emission rate. When the NMOC emission rate exceeds 50 Mg/yr, a landfill is required to control 

its emissions within 30 months of submitting a report in which the NMOC emissions exceeded 

the threshold. Based on the characteristics of the 21 modeled new landfills expected to commence 

construction, reconstruction, or modification in the first 5 years after proposal, 17 landfills are 

expected to meet the design capacity threshold. Of these 17 landfills, eight are expected to exceed 

the NMOC emission threshold and install a gas collection and control system (GCCS) by 2023. 

1.2 Proposal 

 The proposal reduces the NMOC emission threshold from 50 Mg/yr to 40 Mg/yr. The number of 

landfills subject to the rule remains the same as the baseline because the design capacity threshold 

remains the same. However, 11 landfills are expected to exceed the NMOC emission threshold 

and install a GCCS by 2023. The installation of the GCCS is accelerated under this option, 

because landfills will exceed the emission threshold earlier, as shown in Table 1. 

 Consistent with the current baseline, the proposal employs a modeled initial GCCS installation 

lag time of 3 years after exceeding the NMOC threshold, and an average GCCS expansion lag 

time of 4 years as discussed in another memorandum.2

 As a result, 2020 is the earliest year any 

cost and emission reduction impacts would be realized from the projected new landfills as shown 

in Table 1. 

Table 1. Total Number of New Landfills Projected to Control Landfill Gas Emissions over the 

Initial 10-year Period 

Control Parameters

Number of Landfills with Control 

Systems Installed 

By Year

2014-

2019 2020 2021 2022 2023

Baseline (2.5/50) 0 0 6 7 8 

Proposal (2.5/40) 0 3 6 7 11 

1.3 Alternative Regulatory Options 

The impacts of several regulatory options other than proposed option 2.5/40 were also 

considered. The options varied one or more of the control parameters and/or lag times to install and 

expand on the GCCS. 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. 

 Some options incorporated a further reduction in the NMOC threshold, to 34 Mg/yr. These 

options also made a corresponding reduction in the design capacity threshold, from 2.5 million 

Mg to 2.0 million Mg in order to include any smaller landfills that might exceed this lower 

NMOC emission threshold. While these landfills would be expected to achieve additional 

reductions over the lifetime of the landfill when compared to the baseline emission threshold of 

50 Mg/yr, there can be some variation of how much additional emission reductions, if any, would 

be achieved in any particular year. A lower NMOC emission threshold would result in earlier 
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installation of controls, and these initial systems would be designed smaller than a system that 

was installed at a later point in the landfill lifecycle. As a result, the amount of reductions 

achieved in any particular year may fluctuate above or below the baseline as shown in Chart B-1 

of Appendix B. 

 Other options considered increasing the design capacity threshold to 3.0 million Mg from 

2.5 million Mg along with a reduced NMOC emission threshold of 40 Mg/yr. This option 

evaluated any potential reduction in the reporting burden from landfills that are subject to the rule 

but have not yet exceeded the emission threshold. 

 Some options shortened the initial lag times for installing the GCCS. For example, shortening the 

initial lag time from 3 years to 2 years would require some landfills to install the controls earlier 

and would also trigger an earlier installation schedule for each subsequent expansion. However, 

because the same subset of landfills would require controls to be installed under the current 3-

year lag times, the overall additional emission reductions are not as significant over time. Further, 

when installing controls a year earlier as a result of a shortened lag time, the initial system will be 

designed slightly smaller than a system designed to capture gas in a subsequent year. 

 Some options shortened the expansion lag times. Reducing the expansion lag time achieves a 

larger net emission reduction over time because each subsequent expansion is on a shorter 2-year 

cycle. However, the same subset of landfills would still require controls to be installed under 

either lag time. 

 Other options shortened both the initial and expansion lag times. This combination of initial and 

expansion lag time reductions achieved the largest amount of reductions over time because they 

achieved an earlier installation start date, paired with a tighter frequency of subsequent 

expansions. 

 Finally, some options combined reduced design capacity or NMOC emission threshold with a 

shortened initial and/or expansion lag time. 

Charts displaying the patterns of emission reductions as a function of various lag times are shown 

in Appendix B. The patterns of emission reductions follow a step-wise pattern over time. 

2. Estimating Cost Impacts 

For each option, the cost impacts analysis compares net annualized costs of the baseline option in 

2023 to the net annualized costs of each regulatory option in 2023. The costs incorporate 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 another memorandum.2

 

In addition to the control costs to comply with the regulation, the costs also include testing and 

monitoring costs to demonstrate compliance. The testing and monitoring costs include the labor, 

equipment rental, and any capital expenses involved with preparation of NMOC emission rate reports, 

conducting initial performance tests, monthly wellhead monitoring, continuous combustor monitoring, 

and quarterly surface emission monitoring. The detailed testing and monitoring equations are shown in 

another memorandum.3

The costs and revenues associated with the baseline and proposal are shown in Table 2. 
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Table 2. Summary of Cost Impacts for Proposal in 2023 

Option 

Annualized 

Control 

Cost 

Average 

Annualized 

Revenue 

Average 

Annualized 

Testing and 

Monitoring 

Cost 

Average 

Net Total 

Annualized 

Cost 

Total Costs of Baseline ($2012) 

Baseline 

2.5/50 23,956,900 21,315,300 66,400 2,708,000 

Incremental Costs above Baseline ($2012) 

Proposal 

2.5/40 3,178,800 2,713,700 5,900 471,000 

The incremental costs associated with the other regulatory alternatives as well as a summary of 

each individual cost component are shown in Appendix C. 

3. Estimating Emission Reduction Impacts 

The emission reductions of each regulatory option are presented in terms of NMOC (Mg/yr), 

methane (Mg/yr), and carbon dioxide equivalents (Mg CO2e/yr) based on a global warming potential of 

25 for methane. The detailed emission reductions equations are shown in another memorandum.2

 The 

reductions associated with the baseline and the proposal are shown in Table 3. 

Table 3. Summary of Emission Reductions for Proposal in 2023 

Option 

NMOC 

Reductions 

(Mg/yr) 

Methane 

Reductions 

(Mg/yr) 

Methane 

Reductions 

(Mg 

CO2e/yr) 

Incremental 

Annual 

NMOC 

Reductions 

(Mg/yr) 

Incremental 

Annual 

Methane 

Reductions 

(Mg/yr) 

Incremental 

Methane 

Reductions 

(Mg 

CO2e/yr) 

Baseline 610 94,800 2,371,000 N/A N/A N/A 

Proposal 

2.5/40 

689 107,100 2,678,300 79 12,300 307,600 

Detailed annual emission reductions for other options for each affected landfill are shown in the 

landfill modeling database outputs.4 

Table 4 summarizes the overall and incremental cost effectiveness of the proposal. 

Table 4. Summary of Overall Cost-Effectiveness 

Option $/Mg NMOC $/Mg Methane $/CO2e 

Baseline 

2.5/50 4,400 29 1.1 

Proposal 

2.5/40 6,000 38 1.5 

The overall cost effectiveness of the baseline is provided for reference and it 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 
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costs of the proposal by the incremental reductions of the proposal. 

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

alternatives can be found in Appendix C. 

4. Estimating Impacts for Enhanced Surface Emission Monitoring 

In the notice to propose amendments to the landfills NSPS, the EPA is requesting public 

comment on adopting an enhanced surface emissions monitoring (SEM) program. Using the methodology 

outlined in another memorandum3

, SEM costs were estimated for both the proposed SEM program and 

the enhanced SEM program.3

 The costs for the proposed SEM program are included as one element of the 

estimated testing and monitoring costs shown in Table 2 of this memo. 

This section compares the costs of the proposed SEM program to the costs of the enhanced SEM 

program as they would apply to the baseline and proposal. The significant driver associated with the 

increased costs of an enhanced SEM program is the time it takes to walk a tighter traverse path. Under the 

proposed SEM program, the traverse path is every 30 meters (~100 feet), but under an enhanced 

approach, this traverse is every 25 feet, or approximately four times the distance of the current approach. 

There are also additional costs associated with an increased frequency of cover deficiencies identified and 

repaired as a result of walking a tighter path. 

Table 5. Summary of Costs for Proposed Versus Enhanced Surface Emission Monitoring Program 

Control 

Option 

Surface 

Monitoring 

Option 

No. of 

Landfills 

Conducting 

Surface 

Monitoring 

Average 

Annual 

Cost 

Incremental 

Cost 

Average 

Annual Cost 

Per 

Controlled 

Landfill 

Incremental 

Annual Cost per 

Controlled 

Landfill 

Baseline 

(2.5/50) 

No change (30-

meter traverse) 8 42,300 N/A 5,300 N/A 

Enhanced (25-

foot traverse, 

integrated 

sample) 

8 312,800 270,500 39,100 33,800 

Proposed 

(2.5/40) 

No change (30-

meter traverse) 11 50,000 7,700 4,500 700 

Enhanced (25-

foot traverse, 

integrated 

sample) 

11 362,900 320,600 33,000 29,100 

5. References 

1. ERG. 2014. Summary of Landfill Dataset Used in the Cost and Emission Reduction 

Analysis of Landfill Regulations. 

2. ERG. 2014. Methodology for Estimating Cost and Emission Impacts of Proposed MSW 

Landfill Regulations. 

3. ERG. 2014. Methodology for Estimating Testing and Monitoring Costs for MSW Landfill 

Regulations. 

4. ERG. 2014. Modeling Database Containing Inputs and Results of Proposed Revisions to 

MSW Landfill NSPS. 
A-1 

Appendix A: Index of Regulatory Options for Landfill NSPS 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 Proposed 

(2.5/40) 

Same as current rule, except:  NMOC cutoff = 40 Mg/yr 

4 2.5/40, IL, EL Same as current rule, except:  NMOC cutoff = 40 Mg/yr 

 Expansion lag time = 2 years 

 Initial lag time = 2 years 

5 2.0/40 Same as current rule, except:  Design capacity cutoff = 2.0 million Mg 

 NMOC cutoff = 40 Mg/yr 

6 2.0/40, IL Same as current rule, except:  Design capacity cutoff = 2.0 million Mg 

 NMOC cutoff = 40 Mg/yr 

 Initial lag time = 2 years 

7 2.0/34 Same as current rule, except:  Design capacity cutoff = 2.0 million Mg 

 NMOC cutoff = 34 Mg/yr 

8 2.0/34, IL, EL Same as current rule, except:  Design capacity cutoff = 2.0 million Mg 

 NMOC cutoff = 34 Mg/yr 

 Expansion lag time = 2 years 

 Initial lag time = 2 years 

9 3.0/40 Same as current rule, except:  Design capacity cutoff = 3.0 million Mg 

 NMOC cutoff = 40 Mg/yr 

10 3.0/40, EL Same as current rule, except:  Design capacity cutoff = 3.0 million Mg 

 NMOC cutoff = 40 Mg/yr 

 Expansion lag time = 2 years 

11 2.0/50 Same as current rule, except  Design capacity cutoff = 2.0 million Mg 

12 2.5/50, EL Same as current rule, except  Expansion lag time = 2 years 
B-1 

Appendix B. Charts Displaying the Impact of Variations in NMOC Emission Thresholds 

and Lag Times 

Figure B-1. Impact of Reduced NMOC Emission Threshold 

Figure B-2. Impact of Shortened Initial Lag Time 

0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

6,000,000

2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

Methane Emission Reductions (Mg

CO2e/yr)

NMOC = 50 Mg/yr NMOC = 40 Mg/yr NMOC=34 Mg/yr

Threshold:

Design Capacity:

2.0 million Mg

NMOC: various

‐1,000,000

0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

6,000,000

2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

Methane Emission Reductions

(Mg CO2e/yr)

Net Impact of Reduced Initial Lagtime Initial Lag = 3 years Initial Lag = 2 years

Thresholds:

Design Capacity:

2.5 million Mg

NMOC: 50 Mg/yr
B-2 

Figure B-3. Impact of Shortened Expansion Lag Time 

Figure B-4. Impact of Shortened Initial and Expansion Lag Times

0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

6,000,000

2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

Methane Emission Reductions

(Mg CO2e/yr)

Net Impact of Reduced Expansion Lagtime Expansion Lag = 4 years Expansion Lag = 2 years

Thresholds:

Design Capacity:  2.5

million Mg

NMOC: 50 Mg/yr

0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

6,000,000

2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

Methane Emission Reductions (Mg

CO2e/yr)

Net Impact of Reduced Initial and Expansion Lagtimes

Initial Lag = 3 yrs; Expansion Lag = 4 yrs

Initial and Expansion Lags = 2 years

Thresholds:

Design  Capacity:

2.5 million Mg

NMOC: 40 Mg/yr