Q848. How should I calculate and report GHG emissions from pulp and paper waste streams present at my facility under Subpart TT?

A848. Historically, Subpart TT has provided a single degradable organic carbon (DOC) value and a set range of decay rates (k-values) for general Pulp and Paper waste (other than industrial sludge) in Table TT-1 (Table 1 below).

As part of the Final 2015 Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rule (published December 9, 2016 at 81 FR 89188), Table TT-1 of Subpart TT was amended to include four new, specific categories of Pulp and Paper waste types (Table 2 below). These new Pulp and Paper waste types include boiler ash, kraft recovery (causticizing) wastes, wastewater sludge, and other Pulp and Paper wastes (e.g. hydropulper rejects, bark wastes, digester knots, etc.).  With these more specific waste types, DOCs, and k-values in Table TT-1, reporters who can further segregate their Pulp and Paper waste streams can more accurately account for the greenhouse gas (GHG) emissions from their facility.

All Reporters: For Reporting Year (RY) 2017 and forward, all facilities reporting under Subpart TT must use the values provided in Table 2 below (the newly amended Table TT-1) to calculate GHG emissions from industrial waste landfills.  This table provides reporters with Pulp and Paper wastes either an over-arching DOC value for the Pulp and Paper waste at their facility if their Pulp and Paper waste streams cannot be more specifically segregated (‘Pulp and paper waste streams not segregated into separate streams’), or multiple values for specific known Pulp and Paper waste types if their Pulp and Paper waste streams can be further segregated (‘Pulp and paper waste streams segregated into separate streams’).  If a facility uses one or more of the new, specific Pulp and Paper waste types (‘Pulp and paper waste streams segregated into separate streams’), then that facility may NOT use the ‘Pulp and paper manufacturing wastes, general’ waste type in the ‘Pulp and Paper wastes not segregated into separate streams’ waste type.

For example, if a Subpart TT facility with Pulp and Paper wastes has enough detail to report their Boiler Ash as its own stream, but does not have enough information to properly segregate their remaining Pulp and Paper wastes, they must use the specific DOC and decay rates for Boiler Ash under the newly amended Table TT-1 for the known quantity, and  the ‘Other Pulp and Paper wastes (not otherwise listed)’ waste type under the same ‘Pulp and paper wastes segregated into separate streams’ field to report their remaining Pulp and Paper wastes.

New Reporters: New Reporters to Subpart TT (those who begin reporting to the Greenhouse Gas Reporting Program for the year 2017 and subsequent years) must use the newly amended Table TT-1 (Table 2 below) in all their report submissions.

Resubmission of reports for RY 2016 and prior: Reporters to Subpart TT who resubmit reports prior to RY 2017 are NOT expected or required to resubmit their waste stream data per the newly amended Table TT-1 and are instead expected to continue using the previous Pulp and Paper DOC default value of 0.20 and one of the three permitted decay rates for dry, moderate and wet climates located in Table 1 below (0.02, 0.03, and 0.04 1/yr respectively).

Table 1. Table TT-1 to Subpart TT of Part 98 – Default DOC and Decay Rate Values for Industrial Waste Landfills, for use in Reporting Years 2016 and prior

^aThe 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 from company records or engineering estimates 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

Alternatively, landfills that use leachate recirculation can elect to use the k value for wet climate rather than calculating the recirculated leachate rate.

Table 2. Amended Table TT-1 to Subpart TT of Part 98 – Default DOC and Decay Rate Values for Industrial Waste Landfills, for use in Reporting Years 2017 and after

^aThe 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 from company records or engineering estimates 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.

Alternatively, landfills that use leachate recirculation can elect to use the k value for wet climate rather than calculating the recirculated leachate rate.

^bKraft Recovery Wastes include green liquor dregs, slaker grits, and lime mud, which may also be referred to collectively as causticizing or recausticizing wastes.

^cA facility that can segregate out pulp and paper industry wastewater sludge must apply the 0.12 DOC value to that portion of the sludge.