Municipal Solid Waste Landfills                       &EPA
Final Rule: Mandatory Reporting of Greenhouse Gases                               Environmental protector
United States
Environrr
Agency
Under the Mandatory Reporting of Greenhouse Gases (GHGs) rule, owners or operators of municipal
solid waste (MSW) landfills (as defined below) must report emissions from MSW landfills and all other
source categories located at the landfill for which methods are defined in the rule. Owners or operators
are required to collect emission data; calculate GHG emissions; and follow the specified procedures for
quality assurance, missing data, recordkeeping, and reporting.

How Is This Source Category Defined?

The landfill source category consists of MSW landfills that accepted waste on or after January 1, 1980
and generate methane (CH4) in amounts equivalent to 25,000 metric tons of carbon dioxide equivalent
(CO2e) or more per year. This definition is based on the amount of CH4 generated (adjusted for soil
oxidation, but not considering whether any gas is collected and destroyed) and not the amount of CH4
actually emitted. The MSW landfill consists of the landfill, landfill gas collection systems, and landfill
gas destruction devices (including flares).

This source category does not include industrial, hazardous waste, or construction and demolition
landfills.

What GHGs Must Be Reported?

MSW landfill owners and operators must report:

   •   Annual modeled CH4 generation and CH4 emissions from the landfill.
   •   Annual CH4  destruction (for landfills with gas collection and control systems).
   •   Annual CO2, CH4, and nitrous oxide (N2O) emissions from stationary fuel combustion devices
       using the calculation methods specified in 40  CFR part 98, subpart C (General Stationary
       Combustion Sources). The information sheet on general stationary fuel combustion sources
       summarizes calculating and reporting emissions from these units.

How Must GHG Emissions Be Calculated?

MSW landfills must calculate  modeled annual CH4 generation based on:

   •   Measured or estimated values of historic annual waste disposal quantities; and
   •   Appropriate values for model inputs (i.e., degradable organic carbon fraction in the waste, CH4
       generation rate constant). Default parameter values are specified for bulk municipal waste and
       individual waste materials.

Landfills that do not collect and destroy landfill gas must adjust the modeled annual CH4 generation to
account for soil oxidation (CH4 that is converted to CO2 as it passes through the landfill cover before
being emitted) using a default soil oxidation factor. The resulting value represents both CH4 generation
(adjusted for oxidation) and CH4 emissions.

Facilities that collect and control landfill gas must calculate the annual quantity of CH4 recovered and
destroyed based on continuous monitoring of gas flow rate and continuous or weekly monitoring of CH4
concentration, temperature, pressure, and moisture content of the collected gas prior to the destruction
device. CH4 destruction efficiency must be based on the manufacturer's specified efficiency or 99
percent, whichever is less.
40 CFR 98, subpart HH                          1                             EPA-430-F-09-009R
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Those facilities that collect and control landfill gas must then calculate CH4 emissions in two ways and
report both results. Emissions must be calculated by:
        1.   Subtracting the measured amount of CH4 recovered from the modeled annual CH4 generation
           (with adjustments for soil oxidation and destruction efficiency of the destruction device).
        2.   Applying a gas collection efficiency to the measured amount of CH4 recovered to account for
           CH4 that is emitted through the landfill surface (adjusted for soil oxidation). Default
           collection efficiencies are specified that take into account collection system coverage and
           landfill cover materials.
A checklist for data that must be monitored is available at:
www.epa.gov/climatechange/emissions/downloads/checklists/mswlandfills.pdf
When Must Reports be Submitted?

The submission date for the annual GHG report can vary in the first 3 years of the program.

    •   Reporting Year 2010.  The report was required to be submitted by September 30, 2011.

    •   Reporting Year 2011.  The due date depends on which source categories are included in the
       report. If the report includes one or more of the source categories listed below, then the report
       must be submitted by September 28, 2012. This reporting deadline applies to all subparts being
       reported by the facility. In addition, if the facility contains one or more of these source categories
       and the facility submitted a GHG annual report for reporting year 2010 under another subpart
       (e.g., subpart C for general stationary fuel combustion), then by April 2, 2012 you must notify
       EPA through e-GGRT that you are not required to submit the second annual report until
       September 28, 2012 (the notification deadline according to 4 CFR 98.3(b) is March 31, 2012,
       however, because this date falls on a Saturday in 2012, the notification is  due on the next business
       day).
           o  Electronics Manufacturing (subpart I)
           o  Fluorinated Gas Production (subpart L)
           o  Magnesium Production (subpart T)
           o  Petroleum and Natural Gas Systems (subpart W
           o  Use of Electric Transmission and Distribution Equipment (subpart DD)
           o  Underground Coal Mines (subpart FF)
           o  Industrial Wastewater Treatment (subpart II)
           o  Geologic Sequestration of Carbon Dioxide (subpart RR)
           o  Manufacture of Electric Transmission and Distribution (subpart SS)
           o  Industrial Waste Landfills (subpart TT)
           o  Injection of Carbon Dioxide (subpart UU)
           o  Imports and Exports of Equipment Pre-charged with Fluorinated GHGs or Containing
              Fluorinated GHGs in Closed-cell Foams (subpart QQ)

       If the report contains none of the source categories listed above, then the report must be submitted
       by April 2, 2012 (the deadline is March 31, 2012, however, because this date falls on a Saturday,
       the annual report is due on the next business day).

40 CFR 98, subpart HH                            2                              EPA-430-F-09-009R
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    •  Reporting Year 2012. Starting in 2013 and each year thereafter, the report must be submitted by
       March 31 of each year, unless the 31st is a Saturday, Sunday, or federal holiday, in which case
       the reports are due on the next business day.

What Information Must Be Reported?

In addition to the information required by the General Provisions at 40 CFR 98.3(c), each facility must
report the following landfill information:
    •  Information on the landfill's operating status, first and last year the landfill accepted waste,
       anticipated closure date, capacity, and whether leachate recirculation is used.
    •  Waste disposal quantity for each year of landfilling and description of how it was estimated.
    •  Waste composition data, if available, and how these data were estimated.
    •  Values of all parameters used in the methane generation calculations, including degradable
       organic carbon (DOC) and rate constant (k).
    •  Fraction of CH4 in landfill gas and how this fraction was determined (measured or default
       values).
    •  Surface area of the landfill containing waste, cover type, and surface area and oxidation factor for
       each cover type used to calculate the average oxidation fraction, and the average oxidation
       fraction used.
    •  Annual CH4 generation modeled.
    •  Annual CH4 emissions adjusted for oxidation (for landfills without gas collection).
    •  Annual CH4 emissions. (Facilities with landfill gas collection and control  systems must report
       emissions using both of two estimation methodologies described above and must also report
       annual CH4 destruction by the destruction device).

For landfills with gas collection systems, report:
    •  Total volumetric flow of landfill gas collected for destruction, measured CH4 concentration,
       monthly average measured temperature and pressure, and annual quantity  of CH4 recovered.
    •  For landfill gas destruction devices, the destruction efficiency or whether gas was sent off-site for
       destruction. Indicate if a back-up destruction device is available, its associated destruction
       efficiency and the annual operating hours for primary destruction and back-up destruction
       devices.
    •  The gas collection efficiency used in emissions calculations.
    •  Descriptions of the gas collection system (manufacture, capacity, number of wells,  etc.), surface
       area, waste depth and cover type for areas within the landfill.
    •  Annual operating hours of gas collection system.

EPA has  temporarily deferred the requirement to report data elements in the above list that are used as
inputs to  emission equations (76 FR 53057, August 25, 2011).  For the current status of reporting
requirements, including the list of data elements that are considered to be inputs to emissions equations,
consult the following link:  http://www.epa.gov/climatechange/emissions/CBI.html

For More Information

This document is provided solely for informational purposes. It does not provide legal  advice, have
legally binding effect, or expressly or implicitly create, expand, or limit any legal rights, obligations,
responsibilities, expectations, or benefits in regard to any person. The series of information sheets is
intended  to assist reporting facilities/owners in understanding key provisions of the final rule.
40 CFR 98, subpart HH                            3                              EPA-430-F-09-009R
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Visit EPA's Web site (www.epa.gov/climatechange/emissions/ghgrulemaking.html) for more
information, including the final preamble and rule, additional information sheets on specific industries,
the schedule for training sessions, and other documents and tools. For questions that cannot be answered
through the Web site, please contact us at: GHGreporting(g),epa.gov.
40 CFR 98, subpart HH                            4                              EPA-430-F-09-009R
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