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Comment 7 for LCFS Program Review Advisory Panel (2011) (lcfsadvisorypanel-ws) - 4th Workshop.


First Name: Harvey
Last Name: Eder
Email Address: harveyederpspc@yahoo.com
Affiliation: PSPC Public Solar Power Coalition

Subject: 10/21/11 Last Day Comments to be in 45 Day Doc10/31/11 LCFS NAT GAS lcfs HE/PSPC
Comment:
This is the last day for comments to be contained in the Oct
31,2011 45 day public review document that will go to CARB BOARD in
min Dec,2011 and implimented into law Jan. 1,2011 for LCFS.
The notice dist. last Friday gave to Oct 24 and this is not enough
time. Important information was send out Wed. Occt 19 on sect V
Harmonizing with other State National and Regional programs. This
is part 1 of 3 or more submittals that may be the foundation of
future litagation in Court in this regard.
     Attached is a paper By Dr. Jim Steward from July 30.2011 that
is related to natural gas emissions the true competittor of
solar/renewables ( electric, hydrogen etc . Dr Steward teaches
Physics at University of the West in Rosemead Ca. having earned his
phd in Physics from Yale. In paragraph 2 of page 1 it states
that"The latest research from NASA shows the impact of methane to
be over 34 times that of CO2 in 2009 over 100 years and 105 over 20
years." see page one footnote 4 Drew T. Shindell,et al., Improved
Attribution of Climate Forcing and venting,", Science 326 716
(2009) This is all incorporated into the ffffffrecord for comments
in the 45 day document and should be included in the LCFS CI
GREET/GTAP for natural gas /methane for CNG and LNG as well as for
biogas natural gas from landfills. This will affect the credits
counted and the cost of trading them in the market CARB is
establiching for LCSF GHG More comments will follow before 5pm
today, This and other informations on methane and nitrogem oxidesa
N2O  was submitted to John Curtis and his Kevin Cleary over the
past several years before the scoping plant and ignored etc.
including communications will Anel Prubu etc. all of the
communications on the phoine and here and via email are now part of
the officail record and must be consider and included in the
natural gas pathways  all types as well as the Washington DC Bus
Study done in 2006 which shows what happens over the life of a
vehicle published by NREL/DOE/ Uof WV
etc and was submitted to staff several years ago as well as the
Natural Gas refuse truck study done and provided by SCD staff via
Henry Hogo and Pandal Passic over 6 months ago which was done by
Dr. Gautum of the University of West Virginal these fhow rLandfill
Gas-to-Energy Projects May Release More Greenhouse Gases Than
Flaring
Prepared by Jim R. Stewart, PhD,1 July 30, 2011
Executive Summary
This paper compares the net greenhouse gas (GHG) effects of most
landfill-gas-to-energy projects with
the traditional practice of burning the captured methane in a
flare. Based on studies by government
agencies, consultants to the waste industry, and academic
institutions, a potential result is 3.8 - 7.8 times
more net GHG emissions for energy recovery projects compared to
flaring. This outcome is based
on the larger fugitive emissions from “wet” landfills used for
energy recovery compared to those from
“dry” landfills used for flaring. Since the GHG savings from
replacing fossil fuel with the landfill
methane could be negated by GHG impacts of the fugitive emissions,
“renewable energy” credits should
not be given to landfill gas, except when operators can demonstrate
no more emissions than flaring.
Introduction
All decomposing organic materials in landfills release methane,2 a
greenhouse gas (GHG) much more
potent than carbon dioxide. The Intergovernmental Panel on Climate
Change (IPCC) estimated in 19953
that the global warming effect of methane was 21 times that of CO2,
averaged over a 100-year period, or
75 times CO2, averaged over a 20-year period. The latest research
from NASA in 2009 shows the
impact of methane to be 34 times that of carbon dioxide over 100
years and 105 times over 20 years.4
The next 20 years are critical because of the imminent danger of
releasing billions of tons of Arctic
methane clathrates,5 which could lead to irreversible runaway
global heating.
Figure 1. Global Warming
Impact of Carbon Dioxide
(set arbitrarily at 1)
compared with Methane
over a hundred year period
and over a twenty year period
Many organizations urge the diversion of all organics from
landfills. This practice would end new
methane emissions from landfills. An key concern is the fact that a
large fraction of the emissions from
wet organics occur in the first three years, usually before the gas
cap and capture systems are put in
place, as shown in Figure 2.6 The reason for the delay putting on
the cover is the operator is still adding
waste to that section of the landfill.
1 Dr. Stewart earned a PhD in Physics from Yale University and
teaches at the University of the West in
Rosemead, CA, Jim@EarthDayLA.org, 213-487-9340.
2 Methane is emitted from the bacterial process known as anaerobic
digestion, which requires liquids, organic
materials, and absence of oxygen.
3 IPCC Second Assessment Report: Climate Change 1995 (not available
on line – replaced by the 2007 report).
4 Drew T. Shindell, et al., “Improved Attribution of Climate
Forcing to Emissions,” Science 326, 716 (2009).
5 Climate Progress, Vast East Siberian Arctic Shelf methane stores
destabilizing and venting, March 4, 2010
(http://climateprogress.org/2010/03/04/science-nsf-tundra-permafrost-methane-east-siberian-arctic-shelf-venting)
6 Chicago Climate Exchange, Avoided Emissions from Organic Waste
Disposal, Offset Project Protocol, 2009
(www.chicagoclimatex.com/docs/offsets/CCX_Avoided_Emissions_Organic_Waste_Disposal_Final.pdf)
Note this report does not show the later wave of gas generation
expected decades hence, after the landfill closes,
maintenance ends, the protective cover begins to leak, and rain
water stimulates more anaerobic digestion.
Jim Stewart, PhD Landfill gas to energy GHG impacts July 23, 2011
2
Figure 2. Much Methane
Escapes in the First 3 Years,
Usually Before Capping
To get the above data, the Chicago Climate Exchange uses a decay
model to calculate GHG emissions
from a landfill, which is described in detail in their paper. 7 The
bottom line is, if there are any organics
in the landfill, we need to deal with the ongoing methane emissions
from the remaining waste. For
many years people installed impermeable caps and gas collection
systems to capture the methane and
put it into a flare to burn it. Every ton of methane captured and
burned avoids the effect of adding 104
tons of CO2 to the atmosphere (calculated over a 20-year period).8
Wet vs. Dry Landfills
But then people thought, why waste that biomethane burning it in a
flare? Why not use it to replace
fossil fuels? It sounded like a good idea, except, if you take the
methane from a dry landfill and try to
burn it in an engine or turbine, it is inefficient. The normal
methane flow from a “dry tomb” landfill is
so slow and impure, that the operator doesn't make enough money to
pay for the additional capital and
operating expenses of an engine or turbine. So they need more
moisture in the landfill. As the chart
below from research done for the U.S. EPA shows, wet landfills
generate 2.3 times more methane than
dry ones (based only on measuring the collected gas, not the total
emitted, which was not looked at in
these studies).9 If the collection efficiency were the same in both
cases, the result is up to 2.3 times
more GHG emissions for energy recovery sites.10
Figure 3. Moisture
Greatly Increases
Methane Emissions
7 Chicago Climate Exchange, Avoided Emissions from Organic Waste
Disposal, Offset Project Protocol, 2009
(www.chicagoclimatex.com/docs/offsets/CCX_Avoided_Emissions_Organic_Waste_Disposal_Final.pdf)
8 Calculated from methane global warming factor 105 minus the 1
part CO2 from the flare burning the methane.
9 Reinhart, D.R. et al. First-Order Kinetic Gas Generation Model
Parameters for Wet Landfills, report prepared
for US EPA, 2005, p. 4-5.
(http://www.epa.gov/nrmrl/pubs/600r05072/600r05072.pdf). See also
Sally Brown,
“Putting the Landfill Energy Myth to Rest,” BioCycle, May 2010, p.
5.
10 We note that these data are from experimental sites; some energy
recovery sites may not be this wet.
Jim Stewart, PhD Landfill gas to energy GHG impacts July 23, 2011
3
Since it is supposed to be illegal to deliberately add water to a
landfill, waste engineers came up with a
variety of ideas to increase the gas production in the short term
and decrease costs so they could make
more money, including such methods as11:
• Leaving the cap off as long as possible so more water from rain
and snow can enter.
• Regrading the slopes to drain rain into the landfill.
• Recirculating the liquid leachate flowing from the bottom of the
landfill back into the top.12
• Turning off gas collection wells on a rotating basis in order to
give each field time to recharge
moisture removed by the gas extraction process itself.
• Reducing the vacuum pump pull on gas collection wells when
imperfections in the landfill cover
allow air to be drawn into the waste mass. Pulling lower amounts
into the collection system allows
more methane to escape. (Note: While landfills that just flare gas
can accept 3%-5% oxygen
infiltration before risking igniting fires, those recovering energy
are restricted to as low as 0.1%
because a high rate of methane production depends upon having an
oxygen-starved environment.)
• Installing more gas collection wells at the center of the
landfill, where methane ratios are greatest,
and less at the periphery, which could allow more gas to escape
with no wells to capture it.
Result of Increasing Moisture is More Uncollected, Fugitive
Emissions
The problem is that these aids to more profitable “energy recovery”
result in much more uncaptured
methane. A report for the US EPA analyzed fugitive emissions for
three types of approaches: (1) normal
dry tomb landfill, (2) closed landfill, but circulating leachate to
provide moisture for energy recovery,
and (3) active landfill circulating leachate to provide moisture
for energy recovery. The results are
shown in Figure 4. The closed, but wet landfill had 1.9 times more
escaping emissions, while the active
wet landfill designed for maximum energy production had 4.7 times
more emissions.13
Figure 4. Moisture Increases
Fugitive Methane Emissions
from a Landfill, by up to 4.7
times
11 List compiled in March 2010 by Peter Anderson, RecycleWorlds
Consulting, based on these publications:
- Augenstein, Don, Landfill Operation for Carbon Sequestration and
Maximum Methane,
(http://www.osti.gov/bridge/purl.cover.jsp?purl=/795745-EMfXDz/native).
- Institute for Environmental Management (IEM), Emission Control:
Controlled Landfilling Demonstration
Cell Performance for Carbon Sequestration, Greenhouse Gas Emission
Abatement and Landfill Methane
Energy, Final Report, February 26, 2000.
- Augenstein, Don, et. al., Improving Landfill Methane Recovery -
Recent Evaluations and Large Scale
Tests (2007)
(http://4.36.57.37/expo_china07/docs/postexpo/landfill_augustein_paper.pdf)
- Oonk, Hans, Expert Review of First Order Draft of Waste Chapter
to IPCC’s 4th Assessment Rpt, 2008
(http://scp.eionet.europa.eu/publications/wp2008_1/wp/wp1_2008)
- SCS Engineers, Technologies and Management Options for Reducing
Greenhouse Gas Emissions From
Landfills, 2008
(http://www.calrecycle.ca.gov/publications/Facilities/20008001.pdf).
- U.S. Environmental Protection Agency, 40 CFR Part 60 WWW
(proposed and final rule).
- Sierra Club LFGTE Task Force, Sierra Club Report on
Landfill-Gas-to-Energy, January 2010
(http://sierraclub.org/policy/conservation/landfill-gas-report.pdf)
12 "[Director of Butte County's solid waste program] Mannel
explained that in this process, liquid is introduced into
the sealed "waste cells" in the landfill. The addition of the
liquid improves the production of methane up to five
times more than the unaugmented process.” Chico Enterprise-Record,
6/14/2010 (chicoer.com/news/ci_15292646)
13 Mark Modrak, et al., Measurement of Fugitive Emissions at a
Bioreactor Landfill (2005) (available at
http://clubhouse.sierraclub.org/people/committees/lfgte/docs/measurements_fugitivieemissions.pdf)
Jim Stewart, PhD Landfill gas to energy GHG impacts July 23, 2011
4
The IPCC estimated that, over the long term, including the
extensive times (before and after installation
of the gas capture systems) when there is little or no gas
collection, the average total fraction captured
may be as low as 20%.14 U.S. EPA’s Compilation of Air Pollutant
Emission Factors (AP-42) assumes a
range from 60 to 85 percent, with 75 percent as “typical” for sites
having a well-designed active
collection control system in place.15 However, EPA gives no
estimates of the amounts lost before the
installation of the gas capture system and after landfill
maintenance ends, which often are very large.16
A report by consultants for the solid waste industry17 provides
their view of the ranges of gas collection
values: 50-70% for an active landfill, 54-95% for a inactive
landfill or portions of a landfill that contain
an intermediate soil cover, or 90-99% for closed landfills that
contain a final soil and/or geomembrane
cover systems. Their view is stated as, “The high ends of the range
of these values are proposed for sites
with NSPS or similar quality LFG collection systems which are
designed for and achieve compliance
with air quality regulations and surface emissions standards.” “The
low end of the range would be for
full LFG systems that are installed and operated for other
purposes, such as energy recovery, migration
control, or odor management; . . .” (emphasis added). Our
interpretation of these statements is the high
ends of the ranges apply to sites using flaring, while the low ends
apply to those doing energy recovery.
However, we note that the Palos Verdes landfill study in the
1990’s, which was cited by SCS Engineers
for its “capture efficiencies above 95%,”18 was for a landfill that
had been closed for nearly 20 years and
had a 5-foot thick clay cap installed. That study was recently
reevaluated by the California Air
Resources Board, which found a collection rate of only 85%.19 Thus
for closed landfills with a final
cover, 85% capture is a more substantiated upper limit, meaning
that more than 15% is escaping.
In any event, the SCS report indicates the waste industry
recognizes the potential losses in the collection
efficiency of energy recovery compared to state of the art flaring.
This means that an active landfill
(shown in the left two columns in Figure 5 on the next page) using
an energy recovery system could
have a collection efficiency as low as 50%, compared to about 70%
for one using flaring, which implies
1.6 times more methane is likely escaping when a landfill is used
for energy recovery. A study of Dutch
landfills20 shown in the two right columns found that, averaged
over the life of the landfill, flaring gas
extraction systems designed for minimizing emissions could realize
collection efficiencies only up to
50%, while energy recovery systems averaged only 20% efficiency.
However, the numerical factor is
the same, 1.6 times more methane is likely escaping when a landfill
is used for energy recovery.
Figure 5. Methane Capture
Efficiency in Energy
Recovery Systems is much
less than in Flaring sites,
which increases Escaping
Methane by 1.6 Times
14 Intergovernmental Panel on Climate Change, Fourth Assessment
Report, Waste Chapter 10, p. 600 (2008).
15 Office of Air Quality Planning and Standards and Office of Air
and Radiation, Emission Factor Documentation
for AP-42, Section 2.4, Municipal Solid Waste Landfills (Revised
1997) (http://www.epa.gov/ttnchie1/ap42/ch02)
16 “Critique of SCS Engineers’ Report Prepared for California’s
Landfill Companies on Gas Collection
Performance,” by Peter Anderson, Center for a Competitive Waste
Industry, Sept. 5, 2008.
17 SCS Engineers, Current MSW Industry Position and
State-of-the-Practice on LFG Collection Efficiency,
Methane Oxidation, and Carbon Sequestration in Landfills, for the
Solid Waste Industry for Climate Solutions
(June 2008), p. 16-17
(http://www.scsengineers.com/Papers/FINAL_SWICS_GHG_White_Paper_07-11-08.pdf).
18 California Integrated Waste Management Board, Overview of
Climate Change and Analysis of Potential
Measures to Implement Greenhouse Gas Emission Reduction Strategies,
May 8, 2007.
19 “Initial Statement of Reasons for the Proposed Regulation to
Reduce Methane Emissions from Municipal Solid
Waste Landfills,” (May 2009) p. IV-5 and Appendix D
(http://www.arb.ca.gov/regact/2009/landfills09/isor.pdf).
20 Oonk and Boom, 1995, Landfill gas formation, recovery and
emissions, Chapter 7, TNO-report 95-130.
Jim Stewart, PhD Landfill gas to energy GHG impacts July 23, 2011
5
We note that a recent report21 by Patrick Sullivan, senior vice
president of SCS Engineers, consultants
for the solid waste industry, states, “Opponents of landfills claim
development of LFGTE projects will
increase methane emissions at landfills [in comparison with
flaring]. . . This is simply not true.” Some of the
points he makes are quoted in italics below:
1. “The landfill is required by federal regulations to achieve the
same surface emission limits and LFG
system operational requirements in either case.” Our response is
the landfill operator must
demonstrate there is no increase in fugitive emissions from
practices that aid LFGTE, such as
reducing the vacuum pump pull, as mentioned above.
2. “Landfill opponents suggest that LFG engines, which represent
the largest majority of LFGTE devices,
do not destroy methane as well as flares. Indeed, the capacity of
flares to destroy methane is greater
than most LFGTE equipment, but the true difference between the two
devices is very small with
flares and other control devices achieving more than 99% control
and lean-burn LFG engines
achieving more than 98% control of methane (Solid Waste Industry
for Climate Solutions [SWICS],
2007).” He is referencing his own company report, but the report
actually states that methane
destruction efficiency of flares is 99.96% compared to internal
combustion engines 98.34%. As we
will show later, this 1.6% difference is very significant, even
using the outdated GHG multiplier of
21 (and much worse using the 20-year multiplier 105).22 This means
that it is impossible to use
engines and have less net impact than flaring, but turbines with
high destruction efficiency are
acceptable, as are systems that inject the methane directly into
natural gas pipelines for normal uses.
3. “There are some landfills, which are not required by regulation
to collect and control LFG, that are
developed for LFGTE.” Our response is this is a valid point.
Voluntary LFGTE projects undertaken
before the NSPS standards require temporary capping and collection
could significantly reduce GHG
emissions compared to cases where operators wait as long as
possible (up to 5 years is allowed for active
cells) to cap and install collection systems. A consultant report
found a very large collection of methane
before the five year limit produced substantial carbon reduction
credits.23 However we feel the EPA
needs to drastically tighten the NSPS standards, especially in
light of the studies reported above that the
largest emissions from wet organics occur within the first three
years.
Combining the Two Effects Produces Much More Net GHG Emissions for
Energy Recovery
In addition to the increase in fugitive emissions, there is the
effect reported above that wet landfills
produce 2.3 – 4.7 times more methane than dry ones. If we combine
these two observed effects, the net
result would be 3.8 - 7.8 times more net GHG emissions for energy
recovery compared to flaring (a
result that applies irrespective of the value of the GHG multiplier
for methane).
The charts in Figure 6 indicate the actual global warming savings
using the captured methane from
energy recovery to replace the burning of fossil methane are very
small (0.0007 tons of carbon dioxide
equivalent per typical ton of municipal solid waste (MSW)), much
less than the overall impacts of the
escaping methane. The left chart shows a net increase of GHG
emissions of 0.034 CO2 equivalent tons/
MSW ton using the old (1995) multiplier of 21 (which is still used
by the US EPA for “consistency”).
The right chart shows a net increase of GHG emissions of 0.172 CO2
equivalent tons/MSW ton using
the latest (2009) multiplier of 105 over the next critical 20
years. Below the large right red bars for
energy recovery in both figures, there is a very tiny blue line
(that looks almost like a shadow) that
represents the amount of benefit from offsetting the use of fossil
fuels, which in each case is only 0.0007
tons of carbon dioxide equivalent per typical ton of MSW.
21 Patrick Sullivan, SCS Engineers, The Importance of Landfill Gas
Capture and Utilization in the U.S., April 2010, p. 28-30.
(http://www.scsengineers.com/Papers/Sullivan_Importance_of_LFG_Capture_and_Utilization_in_the_US.pdf)
22 It is very unfortunate that EPA 40 CFR Part 98 allows the use of
a default 99% destruction efficiency for
methane for all types of LFG combustion devices, including engines,
ignoring this large GHG impact.
23 McCommas Bluff LFGTE Project, Voluntary Carbon Standard
Assessment, Jan. 2010, by Blue Source LLC,
available from the author, Annika Colson, (212) 253-5348,
acolston@bluesource.com
Jim Stewart, PhD Landfill gas to energy GHG impacts July 23,
2011ates of metnene released of 50-100 grams of methane per mile by
natural gas trach trucks vs. 11 to 17 g per mine methane released
in the Wash D.C Study cited herein  More comments will follow today
before 5 pm

Harvey Eder for self and for PSPC Public Solar Power  Coalition


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Date and Time Comment Was Submitted: 2011-10-21 12:30:04



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