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Comment 54 for Short-Lived Climate Pollutant Draft Strategy (slcpdraftstrategy-ws) - 1st Workshop.


First Name: Jim
Last Name: Stewart
Email Address: drjimstewart@gmail.com
Affiliation:

Subject: Research to include in regulating landfills
Comment:
Landfill Gas-to-Energy Projects May Release More Greenhouse Gases
Than Flaring 
Prepared by Jim R. Stewart, PhD, January 2013 
When preparing regulations for landfills, published research shows
there are 3.8 - 7.8 times more net GHG emissions from energy
recovery projects compared to flaring. 
See attached paper.
Summary of Policy Recommendations 
In summary, to reduce global warming requires the following steps
to be implemented immediately:

1. Use current GHG impact value of 33 (over 100 years) or 105 (over
20 years) for methane to calculate the impacts of methane emissions
from landfills. 
2.	Divert all organics (except sewage sludge) from landfills to
reduce uncollected emissions. 

3.	Either compost all organics or digest them in sealed processors
that capture all methane. 

4.	Segregate remaining organics in landfills for the most effective
and cost-efficient gas collection (always maintaining high
suction). 

5.	Keep out all liquids from landfills (including not recirculating
leachate) to reduce fugitive emissions. 

6.	Cap landfills with temporary covers over the working face to
keep out rain and then install permanent synthetic covers and gas
collection systems as soon as possible (within months is
important). (The current 5-year NSPS requirement harms our
environment and health.) 

7.	All captured methane should be burned in a flare, boiler or a
high efficiency turbine, or used to replace natural gas for heating
or fuel cells (after proper filtration to remove harmful gasses);
internal combustion (IC) engines should not be used because of
unburned methane releases. 

8.	Stop new landfill gas to energy projects and don't give
“renewable energy” credits to landfill gas (unless capture rates
over the entire landfill and destruction efficiencies are
constantly monitored and demonstrated to be equal to those of a
flare.) (The argument that credits should be given if gas
collection projects are installed earlier than local or NSPS
requirements should not apply, since fugitive emissions have been
found to be so large. The only way to eliminate these fugitive
emissions is to eliminate organics from landfills, which would make
landfill gas to energy projects uneconomic. Giving renewable energy
credits to landfill gas allows it to undercut clean sources like
wind and solar and, most importantly, puts source reduction, reuse,
recycling, diversion, composting, and anaerobic digestion at a
competitive disadvantage.) 



Attachment: www.arb.ca.gov/lists/com-attach/59-slcpdraftstrategy-ws-VTkHYF0yUGdQMAlg.pdf

Original File Name: Landfill-gas-to-energyIncreasesGHG-Jan30,2013.pdf

Date and Time Comment Was Submitted: 2015-10-30 06:27:36



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