Q673. My facility generates a number of individual waste streams and some, but not all, are defined as inert under Subpart TT.  Must I report the waste streams that are defined as inert?  Furthermore, I tested one of my waste streams and determined the DOC value to be 0.2 wt%, which is therefore exempt under §98.460(c)(2).  If I have to report information for waste streams that are defined as inert, what DOC value must be used for this waste stream?

A673. If the facility is required to report emissions from an industrial waste landfill, that is, if all waste streams are not exempt from reporting under the provisions in §98.460(c)(2), the rule requires reporting of information about each waste stream regardless of whether it is inert. Reporting requirements include a description of the waste stream and the quantity of waste disposed of in the landfill for each waste stream, among other data elements.

With regard to the appropriate DOC value to use for inert waste streams, the reporter may use either the default value in Table TT-1, DOC=0 for inert wastes listed in §98.460(c)(2), or measurement data (measured DOCx from an anaerobic biodegradation test or a DOCx value imputed from measured volatile solids concentration). If the Table TT-1 default value for DOC is used, the GHG emissions from the inert waste will also be zero. Even if the GHG emissions from the waste stream is zero, information about that waste stream, as mentioned above, must still be reported.

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Source: This question and answer was developed by EPA subpart TT SMEs.

Approval / Publishing History: Version 1

Expiration : none

Relevant Subparts:  Subpart TT
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