Date: January 22, 2010 

To: Rachel Schmeltz 

From: Jeff Coburn, RTI International 

Lucy Adams, RTI International 

Subject: Preliminary Threshold Analysis 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 (MSW) and industrial landfills. EPA received 

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

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

content, but the rule would apply to a great number of landfills that have minimal emissions, but 

that are co-located at facilities that exceed the reporting threshold 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 Potential Alternatives for Industrial Landfills 

Alternative 

No. Description 

Number of 

facilities 

reporting 

Percent of 

total 

number of 

facilities 

Total GHG 

emissions 

reported 

(106 mtCO2e) 

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% 
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. 

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 

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. 
3 

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

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. 
4 

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 

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 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 primarily include 
5 

fertilizers, herbacides, 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 CO2 equivalent (tCO2e) 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, 2009). 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 2009). 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 landfills 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 

(CO2e); 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, 2009). 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 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). 

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 
6 

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. 

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 less than the 

25,000 tCO2e 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 tCO2e 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 tCO2e. Specifically, organic waste landfills that dispose of 20,000 

tons/year of waste annually or less will generally have emissions less than 25,000 tCO2e 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. 
7 

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) 

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 (tCO2e/yr) 

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

GHG emissions per 

inorganic waste landfill 

(tCO2e/yr) 

3.2 32 150 500 5000 20,000 N/A 

Cumulative GHG emissions 

for organic waste landfills 

(1,000 tCO2e/yr) 

65.5 313.5 1,456 3,000 10,000 0 14,800 

Cumulative GHG emissions 

for inorganic waste 

landfills (1,000 tCO2e/yr) 

3.5 8.7 22 55 405 100 600 

Cumulative GHG emissions 

for all landfills 

(1,000 tCO2e/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 (tCO2e/yr) 

15 90 600 3,050 30,500 230,000 N/A 

GHG emissions per 

inorganic waste landfill 

(tCO2e/yr) 

0.2 1.5 7 36 360 3,000 N/A 

Cumulative GHG emissions 

for organic waste landfills 

(1,000 tCO2e/yr) 

1.9 4.5 44.4 311 4,790 9,660 14,800 

Cumulative GHG emissions 

for inorganic waste 

landfills (1,000 tCO2e/yr) 

0.05 0.4 2.0 7.3 100 500 600 

Cumulative GHG emissions 

for all landfills 

(1,000 tCO2e/yr) 

2 5 46 318 4,890 10,160 15,400 

Notes: N/A = not applicable 

tCO2e = tonnes (or metric tons) of carbon dioxide equivalence 
8 

The following six “threshold” options were identified and evaluated to determine the relative 

impacts of the different option, beyond the facility-wide reporting threshold of 25,000 tCO2e. 

The precise impacts of the facility-wide 25,000 tCO2e 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. 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 industrial landfills are located at facilities that 

exceed the facility-wide 25,000 tCO2e reporting threshold. 

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

facilities that exceed the 25,000 tCO2e 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 

(106 mtCO2e) 

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% 
9 

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 1a (300,000 Mg 

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 1a 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 1a 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. 

References 

IPCC. 2006. 2006 Intergovernmental Panel on Climate Change (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.html. 

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 Descriptions for Additional Source or Sink 

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

April 15.