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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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