### Date: January 22, 2010

To: Rachel Schmeltz

From: Jeff Coburn, RTI International

Lucy Adams, RTI International

Subject: Preliminary Threshold Analys is for Industrial Waste Landfills

Purpose

This memorandum provides a preliminary threshold analysis for various regulatory alternatives

for the mandatory reporting of greenhouse gas emissions from industrial landfills.

Background

On April 10, 2009, EPA proposed mandatory GHG reporting requirements for a variety of

sources including municipal solid waste (M SW) and industrial landfills. EPA received

numerous public comments on the proposed regula tion, including comments that EPA’s impact

analysis for industrial landfills focused on a few i ndustries with wastes that have high organic

content, but the rule would appl y to a great number of landfills th at have minimal emissions, but

that are co-located at facilitie s that exceed the reporting threshol d due to other sources at the

facility. On October 30, 2009, EPA finalized GHG reporting requirements for several sources

including MSW landfills, but postponed final action on industrial landfills to better address the

public comments.

Summary of Results

Table 1 provides a summary of the alternatives that are recommended for additional evaluation.

Table 1. Threshold Analysis of Potentia l Alternatives for Industrial Landfills

Alternative

No. Description Number of

facilities

reporting Percent of

total

number of

facilities Total GHG

emissions

reported

(10 6 mtCO 2 e) 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

300,00 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%

### Approach

Data from the 1988 Report to Congress: Solid Waste Disposal in the United States (US EPA,

1988), which contains data regarding 1985 wa ste management practices, was used to

characterize the number of indus trial landfills, the landfill capa cities, and the annual waste

disposal rates for various industr y categories. While these data are 25 years old, they represent

the only complete industrial wast e survey data available. Tabl es 2 through 4 provide key data

taken from the 1988 Report to Congress

.

Table 2. Characteristics of Industrial Landfills by Industry Category

Industry Category Number

of active

landfill

units 1 Number of

facilities

with active

landfills 1 Number of

facilities

with

closed

landfills 1 Waste

quantities

disposed in

landfills 2

(1000 tons) Total design

capacity 3

(1000 tons) Remaining

design

capacity 3

(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

1 

### From Table 4-3 of US EPA, 1988.

2 

### From Table 4-8 of US EPA, 1988.

3 

### From Table 4-13 of US EPA, 1988.



### 2

### Table 3. Waste Disposal Rates for I ndustrial Landfills b y Industry Category 1

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

Industry Category 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

1 

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



### 3

### 4 Table 4. Design Capacity for Industrial Landfills by Industry Category 1

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

1 

### 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

The wastes produced by these industries woul d generally have minimal degradable organic

content (DOC). Note that it is assumed the “fer tilizer 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 primarily include

### fertilizers, herbacides, and pesticides. Plasti cs, m etals, 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 industria l landfills would not generate enough methane

to exceed a 25,000 tonne CO 2 

### equivalent (tCO 2 

### e) emissions threshold. Consequently, while

there is no industry accepted defi nition of “inorganic waste,” for the purposes of this analysis,

“inorganic waste” (i.e., waste gene rated by the above 7 industry cate gories) was assumed to have

a DOC of 0.5 weight per cent (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 faci lities 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, 2009). Consequently, it

was assumed that the waste generated by the “org anic” industry categorie s listed in Tables 1

through 3 (industries other than the 7 listed “ino rganic” industries) ha s an average DOC of

approximately 20 wt%.

Industrial landfills are no t known to have gas collection system s. 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 2009). Me thane emissions (modeled methane generation

less 10% soil oxidation) were proj ected for various sizes of landfills based on the waste disposal

rate ranges and the design capaci ty 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 or ganic 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 landfills sizes were ini tially 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 pe r year (Tg/yr) of carbo n dioxide equivalence

(CO 2 

### e); this is the quantity of methan e emissions projected for 2007 in the Inventory of U.S.

Greenhouse Gas Emissions and Sinks: 1990-2007 (US EPA, 2009). This methodology was

done both considering the annual waste dis posal rates and the landfill design capacity

(essentially assuming the landfill s are now nearing capacity). Although the number of landfills

responding to the two different survey questions were slightly different, the response rate for

these questions was quite high (99.3 percent fo r annual quantity of waste landfilled in 1985 and

87 percent for the design capacity).

This analysis only considers the landfills that were active in 1985 based on the assumption that,

like MSW landfills, it would be impractical to requ ire reporting of landfills that closed prior to

1980. Although some of the landfills that reporte d 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 deli neate what fraction of landfills may still be

5

### operating; all landfills that operated in 1985, whet her still operating or closed were assum ed to

be potentially subject to a GHG reporting rule for industrial landf ills. While the industrial waste

disposal practices may have shifted over the pa st 25 years and, this “model landfill” approach

provides a reasonable means by which to estimate th e impacts of different regulatory alternatives

for industrial landfills.

Discussion of Results

Table 5 presents the estimated emissions for th e model landfills, the number of landfills, and the

cumulative emissions for each landfill range. Usi ng the data in Table 5, various applicability

levels or thresholds can be evaluated. While cer tain industrial facilities ma y have landfills as the

only reportable GHG emissions source (so that on ly landfills with emissions less than the

25,000 tCO 2 

### e 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 tCO 2 

### e reporting threshold were evaluated. There are

three obvious parameters that can be used to aff ect the applicability of th e industrial landfill rule:

1) the type of waste disposed (organic vers us inorganic); 2) the annual quantity of waste

disposed; and 3) the design capacity of the landfill.

Modeling results indicate that wa stes that have an organic co ntent of 0.5 wt% or less do not

contribute significantly to the to tal emissions from industrial sour ces; therefore, an exemption or

applicability exclusion for waste with an organi c content less than 0.5 wt% appears reasonable.

Modeling results also indicate that smaller organi c waste industrial landfills will generally have

emissions of less than 25,000 tCO 2 

### e. Specifically, organic waste landfills that dispose of 20,000

tons/year of waste annually or less will ge nerally have emissions less than 25,000 tCO 2 

### e 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 indus trial establishments (re porting entities) and the

quantity of emissions that would be reported under different applicability or threshold levels

were estimated. The inorganic waste and 20,000 t ons 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 landf ills 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 disperse d 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 accoun ted for 85% of the cumulative emissions from

the overall range.

6

### Table 5. Emission Projections for Model Industria l Landfills

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

(annual waste quantities in 1,000 tons)

Parameter Less

than 0.5 0.5

‐ 5 5.1

‐ 20 21

‐ 100 101

–

1000 More

than 1000 Totals

Number of organic waste

landfills 255 122 130 75 25 0 607

Number of inorganic waste

landfills 1089 273 144 111 81 5 1,703

GHG emissions per organic

waste landfill (tCO

2 e/yr) 257 2,570 11,200 40,000 400,000 2,400,000 N/A

GHG emissions per

inorganic waste landfill

(tCO

2 e/yr) 3.2 32 150 500 5000 20,000 N/A

Cumulative GHG emissions

for organic waste landfills

(1,000 tCO 2 e/yr) 65.5 313.5 1,456 3,000 10,000 0 14,800

Cumulative GHG emissions

for inorganic waste

landfills (1,000 tCO 2 e/yr) 3.5 8.7 22 55 405 100 600

Cumulative GHG emissions

for all landfills

(1,000 tCO 2 e/yr) 69 322 1,478 3,055 10,405 100 15,400

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

Less

than 0.5 0.5

‐ 5 5.1

‐ 20 21

‐ 100 101

–

1000 More

than 1000 Totals

Number of organic waste

landfills 127 50 74 102 157 42 552

Number of inorganic waste

landfills 246 290 284 202 277 167 1,466

GHG emissions per organic

waste landfill (tCO

2 e/yr) 15 90 600 3,050 30,500 230,000 N/A

GHG emissions per

inorganic waste landfill

(tCO

2 e/yr) 0.2 1.5 7 36 360 3,000 N/A

Cumulative GHG emissions

for organic waste landfills

(1,000 tCO 2 e/yr) 1.9 4.5 44.4 311 4,790 9,660 14,800

Cumulative GHG emissions

for inorganic waste

landfills (1,000 tCO 2 e/yr) 0.05 0.4 2.0 7.3 100 500 600

Cumulative GHG emissions

for all landfills

(1,000 tCO 2 e/yr) 2 5 46 318 4,890 10,160 15,400



### Notes: N/A = not applicable

tCO 2 

### e = tonnes (or metric tons) of carbon dioxide equivalence



### 7

### The following six “threshold” options were identi fied and evaluated to determ ine the relative

impacts of the different option, beyond the f acility-wide reporting threshold of 25,000 tCO 2 

### e.

The precise impacts of the facility-wide 25,000 tCO 2 

### e 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-w ide threshold. Nearly all industrial facilities

that have landfills will also have stationary combustion sources or other regulated sources that

would cause the facility to report GHG emissions from their industrial landfill regardless of how

little emissions are generated from the landfill. Consequently, the option for all industrial

landfills to report effectively assumes that all indu strial landfills are located at facilities that

exceed the facility-wide 25,000 tCO 2 

### e reporting threshold.

 All industrial landfills report (i.e., assumes all industrial landfills are co-located at

facilities that exceed the 25,000 tCO 2 

### e 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 2 0,000 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 th at 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

(10 6 mtCO 2 e) Percent of

total GHG

emissions

reported

1 All industrial landfills report 2,310 100% 15.4 100%

1a 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%



### 8

### 9 Assuming that the costs associated with each thre shold 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 1a (300,000 Mg

capacity threshold) is inferior to Option 2 (inorg anic waste exclusion) because it impacts more

facilities while including less GHG emissions than Option 2 (i.e., Option 1a costs more for less

reported GHG emissions than Option 2). Sim ilarly, Option 2a (20,000 tons/yr annual waste

disposal rate threshold) is in ferior to Option 3 (c ombination of inorgani c waste exclusion and

300,000 Mg capacity threshold). Consequently, th ese options (Options 1a and 2a) can be

excluded from further analysis. The remaini ng four options (Options 1, 2, 3, and 4) are

recommended for further analysis. Note that th e 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 dis posal quantities than the other options.

References

IPCC. 2006. 2006 Intergovernmental Panel on Climate C hange (IPCC) Guidelines for National

Greenhouse Gas Inventories. Volume 5, Waste; Chapters 2 and 3. Available at:

http://www.ipcc-nggip.iges.or.jp/public/2006gl/vol5.htm l

.

U.S. Environmental Protection Agency (EPA), 1988. Report to Congress: Solid Waste Disposal

in the United States, Volume II. EPA/530-SW-88-011B. Office of Solid Waste,

Washington, DC.

U.S. Environmental Protection Agency. 2009. Inventory of Greenhouse Gas Emissions and

Sinks: 1990-2007. Annex 3. Methodological De scriptions for Additional Source or Sink

Categories. EPA-430-R-09-004. Office of Atmosphe ric Programs, Washington, DC.

April 15.