TECHNICAL SUPPORT DOCUMENT FOR THE

INDUSTRIAL WASTE LANDFILL SECTOR:
FINAL RULE FOR MANDATORY REPORTING
OF GREENHOUSE GASES

Climate Change Division
Office of Atmospheric Programs
U.S. Environmental Protection Agency

June 9, 2010


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Contents

1.	Industry Description	3

2.	Total Emissions	4

3.	Review of Existing Programs and Methodologies	4

4.	Types of Emissions Information to be Reported	5

4.1	Types of Emissions to be Reported	5

4.2	Other Information to be Reported	5

5.	Options for Reporting Threshold	6

5.1	Summary of Results	7

5.2	Approach	7

5.3	Discussion of Results	12

6.	Options for Monitoring Methods	15

6.1	Calculating Methane Generation using the First-order Decay (FOD) Model	15

6.2	Developing Appropriate Input Parameters for the FOD Model	16

6.2.1	Review of Values for DOC	16

6.2.2	Review of Values for Decay Rate Constant (k) 	18

6.2.3	Recommended Values for DOC and k for Industrial Solid Wastes	19

6.2.4	Measurement Methods for DOC and k for Industrial Solid Wastes	21

6.3	Calculating Potential and Actual Emissions using the IPCC Model	21

7.	Options for Estimating Missing Data	22

8.	QA/QC Requirements	23

9.	References	23

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1. Industry Description

An industrial waste landfill is a landfill containing industrial solid wastes. The New Source
Performance Standard (NSPS) for municipal solid waste (MSW) landfills (40 CFR 60 subpart
WWW) and the Greenhouse Gas (GHG) Mandatory Reporting Rule (MRR) (40 CFR 98 subpart
A) include the following definition for landfills:

"Landfill means an area of land or an excavation in which wastes are placed for
permanent disposal, and that is not a land application unit, surface impoundment,
injection well, or waste pile as those terms are defined under §257.2 [of this
title]."

(Note: 40 CFR 257 is the Criteria for Classification of Solid Waste Disposal
Facilities and Practices. Only the MSW landfill rule includes the bracketed
phrase "of this title.")

An MSW landfill is a landfill in which household waste is placed. An MSW landfill may receive
industrial or commercial wastes, but if the landfill receives household waste, then the landfill is
an MSW landfill. There are two basic types of industrial wastes: 1) hazardous wastes such as
those defined in Subtitle C of the Resource Conservation and Recovery Act (RCRA) or defined
in the Toxic Substance Control Act (TSCA); and 2) non-hazardous wastes as those regulated in
Subtitle D of RCRA. A hazardous waste landfill may accept non-hazardous wastes, but a non-
hazardous waste landfill cannot accept hazardous wastes. As RCRA and TSCA have a
significant restrictions on the types of hazardous wastes that can be landfilled and significant
containment requirements on the landfill, methane production from these hazardous waste
landfills is expected to be negligible. Consequently, a reasonable definition of industrial waste
landfills is:

"Industrial waste landfill means any landfill other than a municipal solid waste
landfill, a RCRA Subtitle C hazardous waste landfill, or a TSCA hazardous waste
landfill, in which industrial solid waste, such as RCRA Subtitle D wastes (non-
hazardous industrial solid waste, defined in 40 CFR 257.2 ), commercial solid
wastes, or conditionally exempt small quantity generator wastes, is placed. An
industrial waste landfill includes all disposal areas at a facility."

After being placed in a landfill, waste is initially decomposed by aerobic bacteria. After the
oxygen has been depleted, the remaining waste is available for consumption by anaerobic
bacteria, which break down organic matter into substances such as cellulose, amino acids, and
sugars. These substances are further broken down through fermentation into gases and short-
chain organic compounds that form the substrates for the growth of methanogenic bacteria.

These CH4-producing anaerobic bacteria convert the fermentation products into stabilized
organic materials and biogas.

Methane generation from a given landfill is a function of several factors, including: (1) the total
amount of waste disposed of in the landfill each year (annual waste acceptance rate); (2) the age
of the landfill (or the total quantity of waste in-place); (3) the characteristics of the waste (i.e.,
composition and organic content of waste); and (4) the climatic conditions (temperature and soil


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moisture content - wet soils promote anaerobic degradation). The amount of methane emitted is
dependent on the amount of CH4 generated less the amount of CH4 that is recovered (and either
flared or used for energy purposes) and the amount of CH4 oxidized near the landfill surface
prior to being released into the atmosphere.

Although federal standards require some MSW landfills to capture and control landfill gas,
industrial waste landfills are not subject to similar federal standards.

2.	Total Emissions

According the Inventory of Greenhouse Gas Emissions and Sinks: 1990-2006 (US EPA, 2008a),
the majority of the CH4 emissions from on-site industrial waste landfills occur at pulp and paper
facilities and food processing facilities. In 2006, these landfills emitted 14.6 Tg C02e of
methane, with pulp and paper facilities emitting 7.3 Tg C02e of methane and food processing
facilities emitting 7.2 Tg C02e of methane. Based on the Report to Congress: Solid Waste
Disposal in the United States (US EPA, 1988), there were 180 pulp and paper facilities and 189
food processing facilities with onsite landfills in 1985. Other industry sectors that are expected
to landfill organic waste materials that contribute to methane emissions (and the number of
facilities within the sector that had onsite landfills in 1985) include: organic chemical
manufacturers (13); plastics and resins manufacturers (29), water treatment facilities (67);
petroleum refineries (31); rubber and miscellaneous product manufacturers (24); selected
chemical and allied product manufacturers (15); textile manufacturers (10); and leather and
leather product manufacturers (7). [U.S. EPA, 1988]

3.	Review of Existing Programs and Methodologies

In developing GHG monitoring and reporting options for landfills, a number of existing
programs and guideline methodologies were reviewed for solid waste landfills. In addition to the
NSPS and Emission Guidelines for MSW landfills, the following resources were examined:

1.	2006 Intergovernmental Panel on Climate Change (IPCC) Guidelines for National
Greenhouse Gas Inventories. Volume 5, Waste.

2.	U.S. Department of Energy (DOE). 2007. Technical Guidelines: Voluntary Reporting Of
Greenhouse Gases (1605(B)) Program.

3.	CARB (California Air Resource Board). 2008. Regulation For The Mandatory
Reporting of Greenhouse Gas Emissions: Second 15-Day Modified Regulatory
Language For Public Comment. May 15.

4.	Environment Canada (2006). Guidance Manual for Estimating Greenhouse Gas
Emissions. http://www.ghgreporting.gc.ca/GHGInfo/Pages/pagel 5.aspx?lang=E.

Additional programs and methodological guidance reviewed included: Inventory of Greenhouse
Gas Emissions and Sinks: 1990-2006 (US EPA, 2008a) and 1990-2007 (US EPA 2009a),

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California Climate Action Registry, EPA Climate Leaders, EU Emission Trading System, The
Climate Registry, EPA's Landfill Methane Outreach Program, Australia's National Mandatory
GHG Reporting Program (draft), and the WRI/WBCSD GHG Protocols.

Each of these sources was reviewed to determine the types of emissions to be reported, the
facility reporting thresholds, and the monitoring methodologies recommended. The reporting
and monitoring options presented in Sections 4, 5, and 6 are commensurate with the
methodologies used in these existing programs and guidelines.

4. Types of Emissions Information to be Reported

4.1	Types of Emissions to be Reported

Based on the review of existing programs and the emission sources at landfills, GHG reporting
for landfills is limited to CH4 because the CO2 produced from the landfills is considered
biogenic. There are potentially other sources of GHG emissions at facilities that operate
landfills. For reporting options for stationary combustion sources (including landfill gas
combustion for energy and combustion of fossil fuels used to assist gas combustion efficiency),
refer to the Technical Support Document for Stationary Fuel Combustion Emissions. Biogenic
emissions of C02 from flaring without energy recovery are not reported.

In the case of industrial facilities with onsite landfills, industrial process emissions of greenhouse
gases may be occurring onsite as well. Reporting options for industrial waste landfill emissions
are detailed here, but for reporting options for other industrial process emissions, refer to the
Technical Support Document for that industry sector.

4.2	Other Information to be Reported

In order to check the reported GHG emissions for reasonableness and for other data quality
considerations, additional information about the emission sources is needed. In addition to
actual methane emissions, each reporting landfill should also report methane generation and, if
applicable, methane combustion annual quantities. Additionally, the following data should also
be submitted with the annual report:

Data to report—industrial waste landfills

•	General information about the landfill, such as an indication of the landfill as "open" or
"closed," the year in which the landfill first started accepting waste for disposal, the last
year the landfill accepted waste or the projected year of landfill closure, the capacity of
the landfill, and an indication of whether leachate recirculation is used at the landfill.

•	Waste characterization information, such as the number of waste steams or waste stream
types accepted at the landfill and a description of each waste stream.

•	Waste stream-specific information, such as the decay rate (k) value used in the
calculations, the method(s) for estimating historical waste disposal quantities, and the
range of years for which each method applies. When historical disposal rates are
estimated based on production or filled capacity, the production or filled capacity
parameters needed to estimate the historical disposal rates must also be reported.

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•	Historic and current annual landfill operating information, such as the quantity of waste
disposed of in the landfill for each waste stream type for each year, the degradable
organic carbon content value for each waste stream or waste stream type for each year
and an indication as to whether this was the default value or a value determined through
sampling and analysis, and the fraction of CH4 in the landfill gas for each year and an
indication as to whether this was the default value or a value determined through
measurement data.

•	Description of the landfill cover, such as the type(s) of cover material used, and the
landfill surface area at the start of the reporting year associated with each cover type.

•	Modeled CH4 generation rate for the reporting year.

•	Methane generation (MG), which is the modeled CH4 generation rate adjusted for
oxidation (landfills with gas collection systems must report both MG from modeled CH4
generation and MG back-calculated from CH4 recovery).

•	Annual CH4 emissions (landfills with gas collection systems must report both CH4
emissions from modeled CH4 generation adjusted for recovery and CH4 emissions back-
calculated from CH4 recovery).

•	Annual quantity of CH4 recovered (for landfills with landfill gas collection systems).

•	An indication of whether passive vents and/or passive flares are present at the landfill.

•	Information about active landfill gas collection systems (if present), such as the total
volumetric flow of landfill gas collected for destruction, the measured CH4 concentration,
monthly average measured temperature, pressure, and moisture content, a description of
the gas collection system (manufacture, capacity, number of wells, etc.), the gas
collection efficiency, annual operating hours of gas collection system, and the surface
area, waste depth and cover type for areas within the landfill serviced by the landfill gas
collection system.

•	Information about landfill gas destruction devices (for landfills with gas collection
system), such as an indication of whether destruction occurs onsite or offsite, the
destruction device efficiency, an indication of whether a back-up destruction device is
available and the annual operating hours for primary destruction and back-up destruction
devices.

5. Options for Reporting Threshold

The precise impacts of the facility-wide reporting threshold (in terms of tCC^e emissions) could
not be directly evaluated, because many of the industrial waste landfills are expected to be co-
located at facilities that have other reportable GHG emissions. In fact, most facilities that have
industrial waste landfills will also have stationary combustion sources or other regulated sources
that would cause the facility to exceed a facility-wide 25,000 reporting threshold regardless of
how little or how much emissions are generated from the landfill. For example, all pulp and
paper facilities (U.S. EPA, 2009c), 97 percent of petroleum refineries (U.S. EPA, 2008b), and 99
percent of petrochemical production facilities (U.S. EPA, 2008c), which includes certain organic
chemical and plastic manufacturers, are projected to exceed the 25,000 reporting threshold based
on sources other than landfills at the facility. Food processing facilities are the exception
wherein the industrial waste landfill is the primary GHG emissions source at the facility (U.S.
EPA, 2009d). Consequently, we did not differentiate between options for all industrial landfills

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to report and options for industrial landfills to report if they are located at a facility that exceed a
facility-wide reporting threshold (in terms of tC02e emissions). Instead, different reporting
"threshold" options were identified and evaluated to determine the relative impacts of the
different options assuming all industrial landfills were located at facilities that already exceeded
a facility-wide reporting threshold of 25,000 tCC^e.

Based on the analysis that is described in greater detail in the remainder of this section, two of
these options were inferior to other similar options (higher costs with less of the nationwide
GHG emissions reported). Consequently, the following four reporting "threshold" options were
identified as viable alternatives.

•	All industrial landfills report (i.e., assumes all industrial landfills are co-located at
facilities that exceed the 25,000 tC02e threshold).

•	Only "organic" waste industrial landfills report.

•	Only "organic" waste industrial landfills with design capacity of 300,000 Mg or more
report.

•	Only "organic" waste industrial landfills that accept 20,000 tons/yr or more of waste
report

5.1 Summary of Results

Table 1 provides a summary of the alternatives that were considered viable.

Table 1. Threshold Analysis of Potential Alternatives for Industrial Landfills

Alternative
No.

Description

Number of
facilities
reporting

Percent of

total
number of
facilities

Total GHG
emissions
reported
(10s mtC02e)

Percent of
total GHG
emissions
reported

1

All industrial landfills report

2,310

100%

15.4

100%

2

Only "organic" waste industrial
landfills report

607

26.3%

14.8

96.1%

3

Only "organic" waste industrial
landfills with design capacity of
300,000 Mg or more report

200

8.7%

13.7

89.0%

4

Only "organic" waste industrial
landfills that accept 20,000 tons/yr
or more of waste report

100

4.3%

13.0

84.4%

5.2 Approach

Data from the 1988 Report to Congress: Solid Waste Disposal in the United States (US EPA,
1988), which contains data regarding 1985 waste management practices, was used to
characterize the number of industrial landfills, the landfill capacities, and the annual waste
disposal rates for various industry categories. While these data are 25 years old, they represent
the only complete industrial waste survey data available. Tables 2 through 4 provide key data
taken from the 1988 Report to Congress.

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Table 2. Characteristics of Industrial Landfills by Industry Category

Industry Category

Number
of active
landfill
units1

Number of
facilities
with active
landfills1

Number of
facilities
with
closed
landfills1

Waste
quantities
disposed in

landfills2
(1000 tons)

Total design
capacity3
(1000 tons)

Remaining

design
capacity3
(1000 tons)

Organic chemicals

17

13

39

263

6,284

4,011

Primary iron and steel

201

177

104

3,687

61,056

42,870

Fertilizer and agricultural
chemicals

31

30

45

5,789

149,252

63,307

Electric power generation

155

126

89

53,449

999,469

874,358

Plastics and resins
manufacturing

32

28

46

86

2,200

1,514

Inorganic chemicals

120

81

115

3,220

69,167

8,593

Stone, clay, glass, and
concrete

1257

1153

454

7,571

8,883,934

8,538,009

Pulp and paper

259

180

179

5,873

108,457

229,337

Primary nonferrous metals

111

90

93

1,375

21,460

13,818

Food and kindred products

194

189

140

3,595

23,758

13,078

Water treatment

121

69

29

157

3,374

1,782

Petroleum refining

61

41

66

272

9,200

2,357

Rubber and misc. products

77

36

93

520

18,456

5,657

Transportation equipment

63

56

127

172

7,335

2,003

Selected chemicals and
allied products

21

19

33

112

3,056

3,285

Textile manufacturing

28

25

84

69

697

728

Leather and leather
products

9

9

23

9

178

120

Totals

2,757

2,322

1,759

86,219

10,367,333

9,804,827

'From Table 4-3 of US EPA, 1988.
2From Table 4-8 of US EPA, 1988.
3From Table 4-13 of US EPA, 1988.

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Table 3. Waste Disposal Rates for Industrial Landfills by Industry Category1

Industry Category

Number of establishments by quantity of waste landfilled in 1985 (1,000 tons)

Less
than 0.5

0.5-5

5.1 - 20

21 -100

101-
1000

More
than 1000

Totals

Organic chemicals

2

4

4

2

1

0

13

Primary iron and steel

69

55

29

13

9

0

175

Fertilizer and agricultural
chemicals

25

2

0

0

2

1

30

Electric power generation

23

13

6

23

57

3

125

Plastics and resins
manufacturing

18

6

2

2

0

0

28

Inorganic chemicals

30

31

10

9

0

1

81

Stone, clay, glass, and
concrete

873

129

85

46

10

0

1,143

Pulp and paper

26

14

83

44

12

0

179

Primary nonferrous metals

32

35

7

13

2

0

89

Food and kindred products

127

22

17

12

11

0

189

Water treatment

33

33

0

3

0

0

69

Petroleum refining

21

9

8

1

1

0

40

Rubber and misc. products

2

22

2

10

0

0

36

Transportation equipment

37

8

7

7

1

0

60

Selected chemicals and
allied products

6

6

6

1

0

0

19

Textile manufacturing

12

6

7

0

0

0

25

Leather and leather
products

8

0

1

0

0

0

9

Totals

1,344

395

274

186

106

5

2,310

'From Table 4-9 of US EPA, 1988.

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Table 4. Design Capacity for Industrial Landfills by Industry Category1



Number of establishments by landfill design capacity (1000 tons)

Less
than 0.5

0.5-5

5.1 - 20

21 -100

101-
1000

More
than 1000

Totals

Organic chemicals

1

0

2

5

4

1

13

Primary iron and steel

3

24

51

25

49

11

163

Fertilizer and agricultural
chemicals

19

1

4

2

0

3

29

Electric power generation

6

5

5

12

21

74

123

Plastics and resins
manufacturing

8

2

8

4

7

0

29

Inorganic chemicals

1

12

20

18

20

3

74

Stone, clay, glass, and
concrete

177

234

176

127

162

71

947

Pulp and paper

0

1

17

47

79

26

170

Primary nonferrous metals

9

13

26

8

20

3

79

Food and kindred products

91

33

4

18

39

1

186

Water treatment

24

3

28

7

4

1

67

Petroleum refining

2

5

8

9

6

1

31

Rubber and misc. products

0

0

0

2

11

11

24

Transportation equipment

31

1

2

10

5

2

51

Selected chemicals and
allied products

0

1

4

5

4

1

15

Textile manufacturing

1

2

0

5

2

0

10

Leather and leather
products

0

3

3

0

1

0

7

Totals

373

340

358

304

434

209

2,018

'From Table 4-12 of US EPA, 1988.

The industrial categories were characterized as either producing "organic" waste or "inorganic"

waste.	The following industrial categories were assumed to produce inorganic wastes:

•	Primary iron and steel

•	Fertilizer and agricultural chemicals

•	Electric power generation

•	Inorganic chemicals

•	Stone, clay, glass, and concrete

•	Primary nonferrous metals

•	Transportation equipment

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The wastes produced by these industries would generally have minimal degradable organic
content (DOC). Note that it is assumed the "fertilizer and agricultural chemicals" industry does
not include agricultural wastes (such as those produced in animal feeding operations, which
could contain significant organic matter); this category is expected to include primarily
fertilizers, herbicides, and pesticides. Plastics, metals, glass, and other "inert" wastes are
generally considered to have negligible DOC (IPCC, 2006). At DOC levels below
approximately 0.5 wt%, even the largest industrial landfills would not generate enough methane
to exceed a 25,000 tonne C02 equivalent (tC02e) emissions threshold. Consequently, while
there is no industry accepted definition of "inorganic waste," for the purposes of this analysis,
"inorganic waste" (i.e., waste generated by the above 7 industry categories) was assumed to have
a DOC of 0.5 weight percent (wt%) or less.

Of the remaining industries that are expected to produce "organic waste," the majority of
landfills are located at either pulp and paper facilities or food and kindred products facilities.
Industrial wastes at these industries in the U.S. have been evaluated and are expected to contain
approximately 20 to 26 wt% DOC measured on a wet basis (US EPA, 2009a). Consequently, it
was assumed that the waste generated by the "organic" industry categories listed in Tables 1
through 3 (industries other than the 7 listed "inorganic" industries) has an average DOC of
approximately 20 wt%.

Industrial landfills are not known to have gas collection systems. Therefore, methane emissions
from industrial landfills can be estimated from the modeled methane generation by accounting
for the fraction of the generated methane that is oxidized near the soil surface, which is assumed
to be 10% (IPCC, 2006 and U.S. EPA 2009a). Methane emissions (modeled methane
generation less 10% soil oxidation) were projected for various sizes of landfills based on the
waste disposal rate ranges and the design capacity ranges reported in the 1988 Report to
Congress (see Tables 3 and 4, respectively) using the IPCC waste model (IPCC, 2006). Each of
these differently sized landfills was assumed to contain 25 years of waste within the range of
values reported for that group of landfills. An average DOC value of 0.0025 was used for
inorganic waste, and an average DOC value of 0.20 was used for organic waste. The decay rate
of 0.057 yr"1 was used for modeling purposes because only 25 years of waste was used and much
of the organic industrial waste is expected to have high water content.

Model landfill sizes were initially selected from a midpoint in each range, and nationwide
emissions were projected based on the number of landfills in that range. The size of the model
landfill (and consequently the projected emissions) for selected ranges were subsequently
adjusted (but well within the range limits for a given range) so that nationwide industrial landfill
emissions were estimated to be 15.4 teragrams per year (Tg/yr) of carbon dioxide equivalence
(C02e); this is the quantity of methane emissions projected for 2007 in the Inventory of U.S.
Greenhouse Gas Emissions and Sinks: 1990-2007 (US EPA, 2009a). This methodology was
done both considering the annual waste disposal rates and the landfill design capacity
(essentially assuming the landfills are now nearing capacity). Although the number of landfills
responding to the two different survey questions for the 1988 Report to Congress were slightly
different, the response rate for these questions was quite high (99.3 percent for annual quantity of
waste landfilled in 1985 and 87 percent for the design capacity).

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This analysis only considers the landfills that were active in 1985 based on the assumption that,
like MSW landfills, it would be impractical to require reporting of landfills that closed prior to
1980. Although some of the landfills that reported that they were closed in 1985 may have
operated past 1980, the number of active landfills in 1985 provides the best number of likely
affected sources. No attempt was made to delineate what fraction of landfills may still be
operating; all landfills that operated in 1985, whether still operating or closed were assumed to
be potentially subject to a GHG reporting rule for industrial landfills. While the industrial waste
disposal practices may have shifted over the past 25 years and, this "model landfill" approach
provides a reasonable means by which to estimate the impacts of different regulatory alternatives
for industrial landfills.

5.3 Discussion of Results

Table 5 presents the estimated emissions for the model landfills, the number of landfills, and the
cumulative emissions for each landfill range. Using the data in Table 5, various applicability
levels or thresholds can be evaluated. While certain industrial facilities may have landfills as the
only reportable GHG emissions source (so that only landfills with emissions greater than the
25,000 tC02e reporting threshold would need to report), it is anticipated that nearly all industrial
landfills will be co-located at facilities that already exceed the reporting threshold. As such,
alternatives to the facility-wide 25,000 tC02e reporting threshold were evaluated. There are
three obvious parameters that can be used to affect the applicability of the industrial landfill rule:
1) the type of waste disposed (organic versus inorganic); 2) the annual quantity of waste
disposed; and 3) the design capacity of the landfill.

Modeling results indicate that wastes that have an organic content of 0.5 wt% or less do not
contribute significantly to the total emissions from industrial sources; therefore, an exemption or
applicability exclusion for waste with an organic content less than 0.5 wt% appears reasonable.
Modeling results also indicate that smaller organic waste industrial landfills will generally have
emissions of less than 25,000 tC02e. Specifically, organic waste landfills that dispose of 20,000
tons/year of waste annually or less will generally have emissions less than 25,000 tC02e as do
organic waste landfills with a capacity of 300,000 Mg (330,000 tons) or less.

Based on the data in Table 5, the number of industrial establishments (reporting entities) and the
quantity of emissions that would be reported under different applicability or threshold levels
were estimated. The inorganic waste and 20,000 tons of annual waste quantity thresholds are
directly evaluated by the data in Table 5. The 300,000 Mg landfill design capacity threshold
requires additional assumptions for the landfills within the 101,000 to 1,000,000 ton capacity
range. For this capacity range, it was assumed that two-thirds of the landfills within this range
are over the 300,000 Mg capacity threshold simply based on the given range (i.e., assuming the
landfills are fairly evenly dispersed within the range). However, because the larger landfills in
this range will have higher emissions than the smaller landfills within this range, the emissions
distribution will tend to be weighted toward the larger landfills. As such, it was assumed that
landfills greater than 300,000 Mg capacity accounted for 85% of the cumulative emissions from
the overall range.

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Table 5. Emission Projections for Model Industrial Landfills



Parameter values for specified ranges of the annual quantity of waste landfilled







annual waste quantities in 1,000 tons)





Less







101-

More



Parameter

than 0.5

0.5-5

5.1 - 20

21 -100

1000

than 1000

Totals

Number of organic waste

255

122

130

75

25

0

607

landfills















Number of inorganic waste

1089

273

144

111

81

5

1,703

landfills















GHG emissions per organic

257

2,570

11,200

40,000

400,000

2,400,000

N/A

waste landfill (tC02e/yr)















GHG emissions per

3.2

32

150

500

5000

20,000

N/A

inorganic waste landfill















(tC02e/yr)















Cumulative GHG emissions

65.5

313.5

1,456

3,000

10,000

0

14,800

for organic waste landfills















(1,000 tC02e/yr)















Cumulative GHG emissions

3.5

8.7

22

55

405

100

600

for inorganic waste















landfills (1,000 tC02e/yr)















Cumulative GHG emissions

69

322

1,478

3,055

10,405

100

15,400

for all landfills















(1,000 tC02e/yr)

















Parameter values for specified ranges of landfill design capacity (1000 tons)



Less







101-

More





than 0.5

0.5-5

5.1 - 20

21 -100

1000

than 1000

Totals

Number of organic waste

127

50

74

102

157

42

552

landfills















Number of inorganic waste

246

290

284

202

277

167

1,466

landfills















GHG emissions per organic

15

90

600

3,050

30,500

230,000

N/A

waste landfill (tC02e/yr)















GHG emissions per

0.2

1.5

7

36

360

3,000

N/A

inorganic waste landfill















(tC02e/yr)















Cumulative GHG emissions

1.9

4.5

44.4

311

4,790

9,660

14,800

for organic waste landfills















(1,000 tC02e/yr)















Cumulative GHG emissions

0.05

0.4

2.0

7.3

100

500

600

for inorganic waste















landfills (1,000 tC02e/yr)















Cumulative GHG emissions

2

5

46

318

4,890

10,160

15,400

for all landfills















(1,000 tC02e/yr)















Notes: N/A = not applicable

tC02e = tonnes (or metric tons) of carbon dioxide equivalence

13


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The precise impacts of the facility-wide 25,000 tC02e reporting threshold could not be directly
evaluated, but it was assumed that very few, if any, industrial landfills would be excluded from
the reporting requirements based on the facility-wide threshold. Consequently, no differentiation
was made between options for all industrial landfills to report and options for industrial landfills
to report if they are located at a facility that exceed a facility-wide reporting threshold (in terms
of tC02e emissions). The following six "threshold" options were initially identified and
evaluated to determine the relative impacts of the different option (beyond a facility-wide
reporting threshold of 25,000 tC02e).

•	All industrial landfills report (i.e., assumes all industrial landfills are co-located at
facilities that exceed the 25,000 tC02e threshold).

•	Only industrial landfills with design capacity of 300,000 Mg or more report.

•	Only "organic" waste industrial landfills report.

•	Only industrial landfills that accept 20,000 tons/yr or more of waste report.

•	Only "organic" waste industrial landfills with design capacity of 300,000 Mg or more
report.

•	Only "organic" waste industrial landfills that accept 20,000 tons/yr or more of waste
report

Table 6 summarizes number of reporting facilities and the projected industrial landfill emissions
that would be reported for these six different regulatory alternatives.

Table 6. Threshold Analysis Results for Industrial Landfills

Option
No.

Description

Number

of
facilities
reporting

Percent of

total
number of
facilities

Total GHG
emissions
reported
(10s mtC02e)

Percent of
total GHG
emissions
reported

1

All industrial landfills report

2,310

100%

15.4

100%

la

Only industrial landfills with design capacity of
300,00 Mg or more report

730

31.6%

14.3

92.9%

2

Only "organic" waste industrial landfills report

607

26.3%

14.8

96.1%

2a

Only landfills that accept more than 20,000
tons/yr of waste report

292

12.6%

13.5

87.7%

3

Only "organic" waste industrial landfills with
design capacity of 300,00 Mg or more report

200

8.7%

13.7

89.0%

4

Only "organic" waste industrial landfills that
accept more than 20,000 tons/yr of waste
report

100

4.3%

13.0

84.4%

Assuming that the costs associated with each threshold is proportional to the number of landfills
in the threshold, the number of applicable landfills included for a given alternative provides a
good estimate of the relative costs of the alternative. On this basis, Option la (300,000 Mg

14


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capacity threshold) is inferior to Option 2 (inorganic waste exclusion) because it impacts more
facilities while including less GHG emissions than Option 2 (i.e., Option la costs more for less
reported GHG emissions than Option 2). Similarly, Option 2a (20,000 tons/yr annual waste
disposal rate threshold) is inferior to Option 3 (combination of inorganic waste exclusion and
300,000 Mg capacity threshold). Consequently, these options (Options la and 2a) can be
excluded from further analysis. The remaining four options (Options 1, 2, 3, and 4) are
recommended for further analysis. Note that the options that include an annual waste disposal
threshold (Options 2a and 4) intrinsically put more importance on the annual waste disposal
quantities than the other options. As such, these options would likely require a more accurate
(and costly) monitoring method for waste disposal quantities than the other options to simply
determine applicability to the rule.

6. Options for Monitoring Methods

There are two cost-effective potential monitoring methods: (1) calculation of methane
generation using the IPCC waste model for landfills that do not have landfill gas collection
systems; and (2) use of gas flow and composition metering for landfills that have gas collection
systems, in addition to calculating methane generation with the IPCC waste model. Direct
methane emission measurement from the landfill surface using optical remote sensing
technologies is also a potential monitoring method. However, these techniques are expensive,
and they typically provide only short-term measures of emissions. Using optical remote methods
for a one-time or annual test to estimate annual methane emissions has a high level of uncertainty
as short-term emissions from a landfill are expected to vary with temperature and barometric
pressure fluctuations, soil moisture content, and rainfall events. Even though remote sensing
methods may accurately measure the methane emissions from the landfill over the course of
several hours, the uncertainty of this method in estimating annual average emissions is
comparable to the other monitoring methods identified above, but the costs are much higher.

6.1 Calculating Methane Generation using the First-order Decay (FOD) Model
The 2006 IPCC Guidelines' Waste Model produces emissions estimates that reflect the
degradation rate of wastes in a landfill (IPCC, 2006). To assist in developing CH4 emission
estimates for solid waste disposal sites (SWDS), the IPCC developed the Waste Model and
improved default values for degradable organic content (DOC) and degradation rate constants for
different types of waste materials. The basic FOD equation for the methane generation rate in
the IPCC Waste Model using the "bulk waste" option and a time delay of 6 months is presented
below (see Equation 1). This is the simplest calculation performed by the model.

Equation 1.

A = CH 4 Generatiorij {Mg I yr)

j Wx x DOCx xMCFxDOCp xFx x —x	-e^(r-x)) j

_x=S I	12	J

Where:

15


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DOCf
MCF
Fx
k

A
X

s

T

Wx

DOCx

Modeled methane generation rate in reporting year T (metric tons CH4).
Year in which waste was disposed.

Start year of calculation.

Reporting year for which emissions are calculated.

Quantity of waste disposed in the industrial waste landfill in year X (metric
tons, as received (wet weight)).

Degradable organic carbon for year X [fraction (metric tons C/metric ton
waste)].

Fraction of DOC dissimilated (fraction).

Methane correction factor (fraction).

Fraction by volume of CH4 in landfill gas (fraction, dry basis).

Decay rate constant (yr"1).

The IPCC model includes the delay time (in months) for CH4 generation as an input parameter to
the model, and adjusts the emission calculations accordingly. The IPCC default value for this
delay time is 6 months, so that Equation 1 effectively implements the IPCC Waste Model at the
recommended value for the delay time.

Waste disposal quantities are occasionally directly measured at industrial waste landfill facilities,
but the waste quantities are more commonly estimated based on other company records, such as
process unit feed rates less production rates (i.e., mass balances around the process unit) or
vehicle load counts. Waste generation rates may also be estimated as a percentage of production
rate. As methane generation occurs slowly over a number of years, waste disposal data are
needed for approximately a 50 year period prior to the year of the emissions estimate.

The FOD model can also be applied to different waste streams that are land disposed by applying
Equation 1 to each landfilled waste stream and sum of the modeled methane generation across all
of the waste streams. This approach requires disposal quantities for each individual waste stream
and appropriate values of DOC and k by waste type.

6.2 Developing Appropriate Input Parameters for the FOD Model

As appropriate values for DOC and k are critical to the application of the FOD model, a literature
review was conducted to develop default parameters for these model parameters. Also, potential
measurement methods were evaluated. The results of these investigations are summarized in this
section

6.2.1 Review of Values for DOC

The IPCC Guidelines provides default values for DOC for several different types of industrial
wastes (IPCC, 2006); the IPCC default DOC values are provided in Table 7. The IPCC notes
that DOC values can vary widely by facility within a given industry. Flores et al. (1999)
conducted analyses of food waste in Iowa. The carbon content (assumed to be all degradable)
calculated from the non-aqueous waste streams analyzed by Flores et al. (1999) are provided in
Table 8. The data from Flores et al. suggests that the average moisture content of food wastes in
the may U.S. may be approximately 40 to 45 percent rather than 60 percent used in the default

16


-------
values for IPCC. Other things being equal, the IPCC DOC content of food waste at 40 to 45
percent moisture content would be 22 percent. This value compares well with the median and
average values as well as for raw scrap, cooked scrap, and sausage casings. While Table 8
shows that different waste streams may have significantly different DOC values, a central
tendency DOC value for food processing waste of 22 percent (or 0.22) is recommended.

Table 7. IPCC Default Values for Degradable Organic Content (DOC) for Industrial

Waste Streams (

[PCC, 2006)

Industry Type

DOC

(wt%, wet)

Total
Carbon
(wt%, wet)

Water
Content
(wt%)

Food, beverages and tobacco (other than sludge)

15

15

60

Textile

24

40

20

Wood and wood products

43

43

15

Pulp and paper (other than sludge)

40

41

10

Plastics

-

80

0

Rubber

(39)a

56

16

Construction and demolition

4

24

0

a Natural rubbers would likely not degrade under anaero

jic conditions.

Table 8. Carbon Content of Food Industry Waste Derived from Data Reported by

Flores et al. (1999)

Originating

SIC

Description

Moisture

(%)a

Carbon

(% Dry
Basis)b

Carbon
(% Wet
Basis)

2013

Raw Scrap

55.81

64.93

28.69

2013

Cooked Scrap

69.28

69.45

21.34

2013

Rendering Grease I

17.47

90.96°

75.07

2013

Rendering Grease II

86.55

20.13

2.71

2015

Offal

68.47

72.42

22.83

2096

Popcorn feed and tailings, REC

13.93

46.4

39.94

2087

Spent diatomaceous earth

42.89

7.18

4.10

2096

Corn and chip waste

3.94

54.49

52.34

2096

Wet waste solid (corn)

78.33

38.02

8.24

2052

Egg shell

32.98

8.77

5.88

2013

Sausage casings

46.06

50.6

27.29

2048

Dust collection

2.38

11.09

10.83

2048

Floor sweepings

2.46

12.17

11.87



Median—all

42.9

46.4

21.3



Mean—all

40.0

42.0

23.9

a As reported by Flores et al. (1999).

bCarbon content was not directly reported, but the % Nitrogen (dry basis) and the carbon to nitrogen ratio
were reported. Carbon content was calculated as the %Nitrogen (dry basis) times the carbon to nitrogen
ratio, except where noted otherwise.

17


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cCarbon content calculated from carbon to nitrogen ratio lead to unrealistic value (102%). Calculated
carbon content as %Fat+%Fiber+%Protein-%Nitrogen-%Ash.

Pulp and paper waste, the IPCC default DOC value is based on 10 percent moisture content.
However, Kraft and Orender (1993) present data for some pulp and paper waste streams
suggesting the moisture content is commonly 50 percent, so that the carbon content (wet weight)
is between 12 and 25 percent (see Table 9). National Council for Air and Stream Improvement,
Inc. (NCASI) calculated methane generation potential of four different pulp and paper wastes.
The methane generation potential ranged from 70 to 101 m3 of methane per Mg waste (Miner,
2008); this translates into DOC values of 0.14 to 0.20. Correcting the IPCC default DOC value
for pulp and paper waste to be on a wet basis of 50 percent moisture, the IPCC value would be
0.22. Considering all of these data, a default DOC value of 0.20 is recommended for the pulp
and paper industry.

Table 9. Sludge and Bark Analysis Data from Krai

't and Orender (1993)

Material

Moisture (% by W'l)

Carbon (% by \Yl)

Deinking Sludge 1

58

12.1

Deinking Sludge 2

58

13.07

Pulp Mill Sludge

58

21.66

Bark

50

25.15



Average

18.0

Bronstein and Coburn (2010) evaluated available U.S. data for construction and demolition
(C&D) wastes. The average wood content in C&D waste from a number of studies ranged from
10 to 33 percent. Combined with the DOC content of wood and wood product waste of 0.43
(IPCC, 2006), this wood content in C&D waste suggests that bulk C&D waste could have DOC
value between 0.04 and 0.14. Not all of the wood waste in C&D waste would be degradable, as
some of the wood is pressure treated. Nevertheless, these data suggest that the IPCC default
value for DOC for C&D waste may be low compared to typical U.S. C&D waste. The weighted
average wood content of all of the C&D waste studies reviewed by Bronstein and Coburn was
22.6 wt%, suggesting a DOC of approximately 0.10. Assuming 20 percent of the wood is
pressure treated, the DOC value of 0.08 is recommended for C&D waste.

6.2.2 Review of Values for Decay Rate Constant (k)

The IPCC Guidelines also provides recommended ranges and default values for the decay rate
constant (k). These values vary by type of waste and climate (average temperature and soil
moisture in the landfill). The ranges for k for temperate regions (i.e., annual average temperature
less than or equal to 68°F), which should be applicable for most parts of the U.S., are provided in
Table 10. Note that IPCC encourages countries using its methods to collect and use national
data, where available, and also comments that the default data are very uncertain.

The U.S. EPA has also defined 3 different values for k in its greenhouse gas inventories (U.S.
EPA, 2009a) for "bulk wastes" depending on precipitation range. These k values were
determined by statistical best fit of methane generation rates calculated from U.S. landfills with
landfill gas collection and destruction systems. The EPA inventory k values follow:

k = 0.02 yr"1 for areas where the precipitation is <20 inches/year;

18


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k = 0.038 yr"1 for areas with precipitation between 20 and 40 inches/year; and
k = 0.057 yr"1 for areas where precipitation is greater than 40 inches/year.

Table 10. Ranges of k Values by Waste Type for Temperal

e Climates (IPCC, 2006)

Waste Type (and examples)

k Values (yr1)

Dry Climates3

Wet Climates3

Slowly degrading wastes (paper, textiles, wood or straw)

0.01 to 0.05

0.02 to 0.07

Moderately degrading wastes (Other [non-food] organic
putrescible/garden and park waste)

0.04 to 0.06

0.06 to 0.1

Rapidly degrading wastes (food waste and sewage sludge)

0.05 to 0.08

0.1 to 0.2

Bulk wastes

0.04 to 0.06

0.08 to 0.1

aDry climate is defined as areas where the annual average precipitation rate is less than the potential
evapotranspiration rate, and a wet climate is one where the annual average precipitation rate is greater
than the potential evapotranspiration rate.

For the pulp and paper industry, NCASI derived k values for 4 types of pulp and paper
wastewater treatment residuals through field testing and best fit analysis (Miner, 2008); these
values are presented in Table 11.

Table 11. NCASI k Values for Pulp and Paper Wastes (Miner 2008

Residual Description

k, yr"1

Bleached Kraft, combined

0.0034

Deinked, combined

0.020

Deinked, primary

0.014

Nonintegrated, primary

0.016

Average

0.013

Comparisons between these different sources of k values are not easy, because the values do not
represent the same waste materials or climate. The bulk waste decay rates from the U.S. data
appear to be slower than indicated by the IPCC defaults. The pulp and paper waste decay rates
from the NCASI study is within the range (albeit the lower end of the range) of the decay rates
for slowly degrading wastes provided by IPCC.

6.2.3 Recommended Values for DOC and k for Industrial Solid Wastes

Based on a review of all of the available data as described above, recommended values for DOC
and k were developed. As described in Section 6.2.1, the central tendency DOC values of 0.22
for food processing waste and 0.20 for pulp and paper wastes are recommended. The IPCC
Guideline's DOC value of 0.43 for wood and wood product wastes is recommended (IPCC,
2006). For C&D waste, the DOC value of 0.08 is recommended based on the mass fraction of
wood waste in C&D waste in the U.S. (Bronstein and Coburn, 2010) and the default DOC value
for wood waste. Inert wastes, such as glass, concrete, metals, and plastics, are expected to have
negligible DOC; the recommended DOC value for these waste materials is zero. Data are not
readily available for other types of industrial wastes, but the average DOC value for bulk wastes

19


-------
in an MSW landfill is 0.20. MSW landfills may also accept industrial solid wastes, so this bulk
waste DOC value may also represent other industrial solid wastes. Given that inert materials are
assumed to have no DOC, and seeing other industrial wastes appear to have a DOC value of
0.20, this value is recommended for "other" industrial solid wastes. However, we note that there
is significant variability in DOC content for different types of waste streams. As such,
measurement methods for determining waste stream-specific DOC values should provide as
good or better estimates of the DOC content of industrial wastes than the default values provided
in Table 12.

Table 12 also provides recommended values for the decay rate constant, k. As the soil moisture
content (which is generally related to rainfall amounts) are an important driver for the value of k,
three rainfall categories (dry, moderate, and wet) are recommended for assessing the appropriate
value for k. This approach prevents the significant shift in k for moderate rainfall areas (where
the annual average precipitation rate is approximately equal to the potential evapotranspiration
rates) caused by the two rainfall category system suggested by IPCC. The use of direct rainfall
data should also be easier to implement by reporters, as they would not need to determine or find
potential evapotranspiration rates applicable to their landfill site. To account for the effect of
leachate recirculation (to the extent it is used at industrial waste landfills), leachate recirculation
rates are added to precipitation rates for determining the appropriate rainfall category. Values of
k for food processing wastes were selected from the IPCC ranges for rapidly degrading wastes.
Values of k for pulp and paper wastes, wood and wood product wastes, and C&D wastes were
selected from the IPCC ranges for slowly degrading wastes. The k values for other industrial
wastes were selected from the default values for bulk wastes, rounded to one significant digit.
Inert wastes have no DOC, so these wastes do not need to be modeled at all, but default k values
of zero are included in Table 12 for these wastes for completeness.

Table 12. Recommended DOC and Decay Rate Values for Industrial Waste Landfills



DOC

k

k

k



(weight

|drv

| moderate

| wet



fraction, wet

climale"|

climate1'!

climate"!

Indiistry/W aste Type

basis)

(yr')

(yr1)

(\r ')

Food Processing

0.22

0.06

0.12

0.18

Pulp and Paper

0.20

0.02

0.03

0.04

Wood and Wood Product

0.43

0.02

0.03

0.04

Construction and Demolition

0.08

0.02

0.03

0.04

Inert Waste (glass, metal, plastic)

0

0

0

0

Other Industrial Solid Waste (not

0.20

0.02

0.04

0.06

otherwise listed)









a The applicable climate classification is determined based on the annual rainfall plus the recirculated
leachate application rate. Recirculated leachate application rate (in inches/year) is the total volume of
leachate recirculated and applied to the landfill divided by the area of the portion of the landfill containing
waste [with appropriate unit conversions].

•	Dry climate = precipitation plus recirculated leachate less than 20 inches/year

•	Moderate climate = precipitation plus recirculated leachate from 20 to 40 inches/year (inclusive)

•	Wet climate = precipitation plus recirculated leachate greater than 40 inches/year

20


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6.2.4 Measurement Methods for DOC and k for Industrial Solid Wastes

Various test methods for determining DOC and k values were assessed. Traditionally, DOC
values (or "methane generation potential, Lo" values) are estimated from landfills with gas
collection systems or from long-term laboratory studies. Values for k are generally estimated
using a best fit regression analysis of the methane generated over time once the "measured"
methane generation potential is established. Unfortunately, these methods are not suitable for
reasonably quick and repeatable determinations of DOC and k values for specific waste streams.
As such other approaches for determining these parameters were investigated.

There are a variety of test methods for determining the total organic carbon (TOC) content, the
chemical oxygen demand, or the biological oxygen demand of a waste material. Any of these
measured parameters would be a reasonable proxy for estimating DOC; however, these methods
appear to be only applicable to wastewaters or dilute sludges. The tests are targeted to the
dissolved organic compounds and the waste must be able to pass through a pipette for the
analyses. As such, these methods are generally not applicable to industrial solid wastes.

Method 2540G "Total, Fixed, and Volatile Solids in Solid and Semisolid Samples" of the
Standard Methods for the Examination of Water and Wastewater (21st edition, 2005) [available
on-line (to subscribers) at http://www.standardmethods.org/store/1 may be a reasonable, quick,
and inexpensive means to estimate the DOC content of solid wastes. Particularly, degradable
organic carbon is expected to be a primary component of the volatile solids content. Das et al.
(1998) measured the volatile solids and carbon content of pulp and paper wastes used in a
composting test. Zhang et al. (2007) performed similar measurements of chicken wastes, and
Barlaz (1998) measured these parameters for components of MSW. Pertinent data from these
studies are summarized in Table 13. As seen from the data in Table 13, except for the one ratio
of 0.41 for office paper, the carbon content to volatile solids content ratios ranged from 0.46 to
0.61. The average ratio of all values is 0.53. As the carbon-to-volatile solids content ratio for
different types of wastes is consistently within a fairly narrow range, the use of volatile solids
content as a proxy for DOC appears to be reasonable. A ratio of 0.6 appears to be a reasonable
high-range estimate of the DOC content per mass of volatile solids, while 0.53 is the central
tendency of the data identified from the literature.

No reasonable test methods were identified for determining values for k, the decay rate constant.
As such, the recommended default values for the decay rate constant presented previously in
Table 12 should be used.

6.3 Calculating Potential and Actual Emissions using the IPCC Model

Potential emissions are calculated from the methane generation rate and the assumed oxidation
factor according to Equation 2.

Equation 2.

Potential emissions = A x (1 - OX)

Where,

A = modeled methane generation rate (derived in Equation 1)

21


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OX = oxidation factor, default rate is 0.1 (10%)

For landfills without gas collections systems, which include nearly all industrial waste landfills,
the potential and actual emissions are identical. That is, Equation 2 also provides the actual
emissions for landfills without gas collection systems. Few, if any, industrial waste landfills
have landfill gas collection systems. For landfills with gas collection systems, measurement of
the quantity and quality (i.e., methane content) of landfill gas generated at the landfill provides a
second and often more accurate means of determining methane generation rates. Measurement
methods associated with landfill gas collection systems were covered in the general landfill
technical support document (EPA, 2009b). As landfill gas collection systems are not typically
used in conjunction with industrial waste landfills, the reader is referred to EPA, 2009b if more
information on measurement methods for gas collection systems is desired.

Table 13. Volatile Solids (VS) and Carbon (C) Content of Waste Materials



%VS

%C

Carbon to VS



Parameter

(dry basis)

(dry basis)

Ratio

Reference

Seedl

48.2

27.37

0.57

Barlaz (1998)

Seed2

42.4

25.93

0.61

Barlaz (1998)

Grass

85

44.87

0.53

Barlaz (1998)

Leaves

90.2

49.4

0.55

Barlaz (1998)

Branches

96.6

49.4

0.51

Barlaz (1998)

Food

93.8

50.8

0.54

Barlaz (1998)

Coated paper

74.3

34.3

0.46

Barlaz (1998)

Newsprint

98.5

46.2

0.47

Barlaz (1998)

Corrugated container

98.2

46.9

0.48

Barlaz (1998)

Office paper

98.6

40.3

0.41

Barlaz (1998)

Sludge

57

35

0.61

Das et al. (1998)

Bark

90.8

45.3

0.50

Das et al. (1998)

Grit

90.8

48.9

0.54

Das et al. (1998)

Ash

34.2

20.8

0.61

Das et al. (1998)

Poultry Litter

87.6

43.4

0.50

Das et al. (1998)

Chicken waste

54.7

29.1

0.53

Zhang et al. (2007)

7. Options for Estimating Missing Data

As only annual measurement quantities are required for Equation 1, these values must be
measured or estimated. For gas collection systems, if present, the missing value for the CH4
content and/or the missing gas flow rates should be the arithmetic average of the values
immediately before and immediately after the missing data incident.

22


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8. QA/QC Requirements

In order to ensure the quality of the reported GHG emissions, the following quality

assurance/quality control (QA/QC) activities are recommended:

(1)	Reporters are to maintain annual records on waste quantity measurements and waste
composition.

(2)	Reporters are to maintain records of Waste Model input values used (historical waste
disposal quantities, DOC values, k values, etc.) and the procedures used to develop those
values.

(3)	Reporters are to maintain records on daily or weekly gas flow and methane content to the
combustion device, if applicable.

(4)	All fuel flow meters and gas composition monitors, and/or heating value monitors that are
used to provide data for the GHG emissions calculations should be calibrated prior to the
first reporting year, using a suitable method published by a consensus standards
organization (e.g., ASTM, ASME, API, AGA, etc.). Alternatively, calibration procedures
specified by the flow meter manufacturer may be used. Fuel flow meters and gas
composition monitors should be recalibrated either annually or at the minimum frequency
specified by the manufacturer.

(4) Documentation of the procedures used to ensure the accuracy of the estimates of fuel usage,
gas composition, and/or heating value including, but not limited to, calibration of weighing
equipment, fuel flow meters, and other measurement devices should maintained. The
estimated accuracy of measurements made with these devices should also be recorded, and
the technical basis for the estimates should be provided.

9. References

Barlaz, Morton A. (1998). "Carbon storage during biodegradation of municipal solid waste

components in laboratory-scale landfills." GlobalBiogeochemical Cycles. Vol. 12, No. 2,
pp. 373-380. June.

Bronstein, K. and J. Coburn (2010). Memorandum from Kate Bronstein and Jeff Coburn, RTI
International, to Rachel Schmeltz, U.S EPA. "GHG inventory improvement -
construction & demolition waste DOC and Lo value." April 15.

CARB (California Air Resource Board). 2008. Regulation For The Mandatory Reporting of
Greenhouse Gas Emissions: Second 15-Day Modified Regulatory Language For Public
Comment. Available at: http://www.arb.ca.gov/regact/2007/ghg2007/ghgattachmentl.pdf.
May 15.

Das, K. C., E. W. Tollner, and T.G. Tornabene (1998). "Composting pulp and paper industry

wastes: process design and product evaluation." Compost in the Southeast: Proceeding

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of the 1998 Conference. Athens, Georgia. September 9-11. Pp. 129-134. Available at:
http://www.p2pavs.org/ref/12/11563.pdf

Environment Canada (2006). Greenhouse Gas Emissions Reporting: Technical Guidance on
Reporting Greenhouse Gas Emissions. Available at:
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